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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20235B4531987-09-22022 September 1987 Final Response to FOIA Request for Documents Re Specified Dockets.Documents in App a Already Available in Pdr.Forwards App B Documents.App B Documents Also Available in Pdr. Documents for Listed Dockets Could Not Be Located ML20238D0201987-09-0909 September 1987 Forwards Breakdown of Analysis of Costs for Plant OL Application Reviews for 860622-1216,per 10CFR170.12(b). Invoice Will Be Sent Shortly ML20235B3621987-08-25025 August 1987 FOIA Request for Listed Documents for Specified Dockets ML20237K9961987-08-17017 August 1987 Responds to Requesting re-review of OL Fee Charges Under 10CFR170 as Billed on Invoices F1385 & F1386, ,for Review Period 840624-860621.Charges Billed Applicable to Plant Cases.Supportive Fee Info Encl ML20237L0261987-08-0707 August 1987 Ack Receipt of Invoices Re Plant for 840624-0721.Since All Licensing Activities Suspended in Jan 1984 & CP Surrendered on 850301,review of Charges & Issue of Credit Requested ML20235Q0291987-07-15015 July 1987 Advises That Cost Analyses for OL Application Reviews for 840624-860621 Completed.Breakdown of Review Costs by Program Ofc Encl.Util Will Receive Invoices for Listed Amounts ML20211P1311986-12-16016 December 1986 Advises That Encl Order Terminating CPPR-170 & CPPR-171 for Facility & Notice of Withdrawal of Application for OLs Have Been Forwarded to Ofc of Fr for Publication,Per Return of CPs by Util on 850301 ML20214R5961986-09-23023 September 1986 Responds to 860918 Request & Forwards Printout of Recent Filings in Facility Case.No Ruling Made by ASLB Since 860618 Ruling.Served on 860924 ML20214R6331986-09-22022 September 1986 Advises That Listed Individuals Served W/Author ML20214R6061986-09-18018 September 1986 Requests Confirmation Whether or Not Author on Mailing List & Whether Any Rulings Filed Since 860814.Response Requested ML20214R6381986-09-18018 September 1986 Requests Confirmation Whether or Not Author on Mailing List & Whether Any Rulings Filed Since 860814 ML20203E8271986-07-18018 July 1986 Informs That Recently Received Encl Ltrs Procedurally Insufficient.Requests That Provisions of Sections 2.701, 2.708,2.709 & 2.712 Re Filing & Svc of Documents Be Reviewed.Served on 860722 ML20199L0381986-07-0202 July 1986 Forwards Pleading in Response to Board Memorandum & Order Directing Briefs Be Served on 860602.Response Addresses Indiana Sassafras Audubon Soc & Save the Valley, Inc 860626 Motion ML20141A2171986-04-0101 April 1986 Informs That QA Program Being Revised Due to Cancellation of Const Activities & in Keeping W/Intention of Investment Recovery to Reflect Organizational Structure of Investment Recovery Program ML20138H5461985-12-0909 December 1985 Forwards Overview of Regional Ofc & Detailed Organizational Charts for Ofc Divs Due to Recent Organizational & Staff Changes.W/O Encl ML20137Z7951985-12-0404 December 1985 Forwards Matl to Support Removal of Unqualified Instrumentation from Diesel Generator Engine & Engine Skid. Devices Added to Equipment Q-list to Ensure That Qualification Maintained ML20138Q8301985-12-0303 December 1985 Further Response to FOIA Request for Records Re Voluntary or Required Redress of Sites Where Const Was Terminated, Including Crbr & Legal Analysis.Forwards App E Documents.App D & E Documents Available in Pdr.Photographs Also Available ML20133D1471985-10-0202 October 1985 Notifies That Util Rescinding ASME QA Program.Certificate of Authorization N-2456 & Code N Symbol Stamp Returned to ASME ML20135H7471985-09-17017 September 1985 Requests That Date of 850924 Originally Set for NRC Site Stabilization Survey of Const Site Be Rescheduled to Late Oct or Early Nov 1985 Due to Scheduling Conflicts ML20127P1861985-06-26026 June 1985 Forwards Insp Repts 50-546/85-01 & 50-547/85-01 on 850122-0614.No Violation Identified ML20133C7371985-06-14014 June 1985 Further Response to FOIA Request for Documents Re Site Redress Where Plant Const Begun,Including Clinch River Facility & NRC Legal Analysis Re Redress.Forwards App B Documents.App C Document Withheld (Ref FOIA Exemption 5) ML20134A8941985-06-10010 June 1985 Further Response to FOIA Request for Records Re Ford Amend Study.Records in App K Available in Pdr.Review for Addl Records Continuing ML20117P5131985-05-31031 May 1985 Ack Receipt of 850412 Response to Ltr Disputing Billed Amounts by NRC for OL Reviews.Requests That Due Date for Any Final Payment Be Extended for Reasonable Period of Time to Allow Issues to Be Resolved.Fee Paid ML20116N3691985-05-0101 May 1985 Forwards Response to 850402 Request for Addl Info Re Acreage Disturbed by Project & Emergency Offsite Facility Site Layup Actions.No Addl Permits or Approvals from Other Federal, State & Local Agencies Anticipated ML20100G3251985-04-0404 April 1985 Forwards SW Shields to HR Denton Re Surrendering CPPR-170 & CPPR-171 & Summarizing Util Plan to Stabilize Site & Motion to Terminate Proceeding ML20126J9081985-03-0606 March 1985 Further Response to FOIA Request That All Internal Memos to Div of Licensing from May-Nov 1984 Which Provided Draft SER, SER Sections & Questions or Requests for Addl Info Be Placed in Pdr.App C Documents Placed in PDR ML20102C2331985-03-0101 March 1985 Surrenders CPs CPPR-170 & CPPR-171.All const-related Activities on Site Halted.Site Activities Conducted Per Author .Commitments Contained in Encl Site Stabilization Plan Will Govern Future Activities ML20102B7551985-02-25025 February 1985 Disputes Billing Amounts in NRC 850122 Summary Statement of Costs.Errors & Lack of Documentation Do Not Allow Acceptance of Billing Solely on Basis of NRC Internal Controls.Meeting Re Questioned Items & Extension of Due Date Requested ML20091S4501984-06-0101 June 1984 Responds to NRC Ltr Re Allegations Noted in IE Insp Repts 50-546/84-01 & 50-547/84-01.Corrective Actions:Independent Engineering Consultants Evaluation of Concrete Const Showed Concrete Good to Excellent Quality ML20084P3501984-03-14014 March 1984 Requests Response to Encl W & V Smelser 840210 Inquiry Into NRC Attitude Toward Utils.Concerns Include Marble Hill & Bailly Cancellation,Withdrawal of Util Application for Zimmer & Denial of License for Byron Facility ML20086K1021984-01-20020 January 1984 Forwards Util 840116 Press Release Explaining Financial Reasons for Halting Facility Const.Certificate of Svc Encl ML20080Q9121984-01-18018 January 1984 Notifies of Suspension of Const.Site Work Force Reduced to Less than 1,000.Action Taken Due to Inability to Finance Project.Nrc Should Issue Draft SER as Is,So Benchmark Exists for Licensing Review Process ML20079N4611984-01-11011 January 1984 Responds to NRC Re IE Insp Repts 50-546/83-20 & 50-547/83-21.Const Suspended.Insp Repts & Notice of Violation Will Be Placed W/Util Records of Nonconforming Conditions to Be Addressed When Const Resumed ML20083E2891983-12-22022 December 1983 Informs That Applicant Will Require Time to Consider & Determine Response to Special Task Force of Governor of in Recommendation That Const of Facilities Be Canceled.Aslb Should Defer Further Action.Certificate of Svc Encl ML20083E0501983-12-21021 December 1983 Forwards Revised Affidavit Requesting That Matl Transmitted to NRC in Response to Question 470.7 of NRC Environ Rept - OL Stage Be Withheld Per 10CFR2.790.Revised Affidavit Submitted in Response to NRC 831125 Request ML20083H6691983-12-14014 December 1983 Responds to NRC Re Violations Noted in IE Insp Repts 50-546/83-19 & 50-547/83-20.Corrective Actions:Sys Developed to Identify Matls Requiring Periodic Maint & Storage Procedures Revised to Identify Sys ML20082R6411983-12-0808 December 1983 Forwards Pp 11 Omitted from 831130 Response to Sassafras Audubon Soc & Valley Watch,Inc Contentions ML20082M9481983-12-0202 December 1983 Forwards Amend 30 to FSAR & Suppl 4 to Environ Rept - OL Stage (Filed in PDR Category C).Affidavit of Distribution Encl ML20082M8251983-11-30030 November 1983 Requests Extension Until 840301 for Response to Byron Integrated Design Insp Rept ML20082D2131983-11-14014 November 1983 Responds to IE Bulletin 83-06,Nonconforming Matls Supplied by Tube-Line Corp.... Requests Submittal Extension Until 840331 to Respond to Permit Adequate Review & Evaluation of Vendor Info ML20081K6081983-11-0707 November 1983 Forwards,For Review,Util Response to Generic Ltr 82-33 Re Reg Guide 1.97 Planned Improvement Rept on Instrumentation for light-water-cooled Power Plants to Assess Plant Environs Following Accident ML20086A8591983-11-0101 November 1983 Forwards Addl Copies of Sassafras Audubon/Valley Watch 831022 Joint Suppl.Svc List Requested.W/O Encl ML20078P1541983-10-28028 October 1983 Corrects Ref on Page 10,Line 2,of 831021 Joint Suppl to Sassafras Audubon Soc & Valley Watch Petitions for Intervention in OL Hearing.Certificate of Svc Encl ML20085L3131983-10-11011 October 1983 Responds to NRC Re Violations Noted in IE Insp Repts 50-546/83-15 & 50-547/83-15.Corrective Actions: Directive Will Be Issued to Pullman Const Industries Emphasizing Resposibility for Reporting Nonconformances ML20080N2841983-09-30030 September 1983 Forwards Status of Outstanding Third Quarter 1983 Commitments in Amends to Fsar.Description of Containment Hydrogen Monitoriing Sys Will Be Submitted During First Quarter 1984 ML20080J0201983-09-23023 September 1983 Forwards Changes to Safeguards Vol & Responses to NRC Requests for Addl Info,Included in Amend 28 to OL Application.Changes Withheld (Ref 10CFR73.21) ML20080J0531983-09-21021 September 1983 Forwards Responses to 830824 Requests for Addl Info Re Fsar. Requests Which Pertain to Byron FSAR Not Addressed.Responses Will Be Included in Dec Amend ML20080G2731983-09-16016 September 1983 Discusses Feasibility & Benefits to Util of Eliminating Postulated Pipe Breaks in RCS Primary Loop from Structural Design Basis,Per NRC .Approx 200,000 Manhours of Installation Time Per Unit Will Be Saved ML20024F1781983-09-0202 September 1983 Requests Extension Until 840401 for Submittal of Responses to Generic Ltr 83-28,to Incorporate Efforts Underway on Generic Requirements by Westinghouse Owners Group,Nuclear Util Task Action Committee (Nutac) ML20076D3371983-08-16016 August 1983 Forwards Response to IE Bulletin 83-05 Re Hayward Tyler Pump Co Failure to Effectively Implement QA Program.Pumps Not Commercially Accepted for Installation at Plant Site 1987-09-09
[Table view] Category:NRC TO PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA
MONTHYEARML20214R5961986-09-23023 September 1986 Responds to 860918 Request & Forwards Printout of Recent Filings in Facility Case.No Ruling Made by ASLB Since 860618 Ruling.Served on 860924 ML20203E8271986-07-18018 July 1986 Informs That Recently Received Encl Ltrs Procedurally Insufficient.Requests That Provisions of Sections 2.701, 2.708,2.709 & 2.712 Re Filing & Svc of Documents Be Reviewed.Served on 860722 ML20138Q8301985-12-0303 December 1985 Further Response to FOIA Request for Records Re Voluntary or Required Redress of Sites Where Const Was Terminated, Including Crbr & Legal Analysis.Forwards App E Documents.App D & E Documents Available in Pdr.Photographs Also Available ML20133C7371985-06-14014 June 1985 Further Response to FOIA Request for Documents Re Site Redress Where Plant Const Begun,Including Clinch River Facility & NRC Legal Analysis Re Redress.Forwards App B Documents.App C Document Withheld (Ref FOIA Exemption 5) ML20126L3681981-03-20020 March 1981 Responds to 800926 & 810304 Comments on Util Rept Entitled Evaluation of In-Place Concrete - Marble Hill Nuclear Generating Station,Units 1 & 2. Quality Adequately Assessed by Sargent & Lundy Methodology.Supporting Matl Encl ML20126F9681981-03-18018 March 1981 Discusses NRC Actions Under 10CFR2.206 Taken in Response to Save the Valley 800507 & 14 Comments & Supporting Affidavits.Ltr Concludes NRC Consideration of Filings ML20147D6211978-09-29029 September 1978 Responds to 780911 Request for Lic Bd to Take Action Re Proposed Increase in Fuel Storage Pool.Aslb Has Jurisdiction Only Over the Radon Question 1986-09-23
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20235B4531987-09-22022 September 1987 Final Response to FOIA Request for Documents Re Specified Dockets.Documents in App a Already Available in Pdr.Forwards App B Documents.App B Documents Also Available in Pdr. Documents for Listed Dockets Could Not Be Located ML20238D0201987-09-0909 September 1987 Forwards Breakdown of Analysis of Costs for Plant OL Application Reviews for 860622-1216,per 10CFR170.12(b). Invoice Will Be Sent Shortly ML20237K9961987-08-17017 August 1987 Responds to Requesting re-review of OL Fee Charges Under 10CFR170 as Billed on Invoices F1385 & F1386, ,for Review Period 840624-860621.Charges Billed Applicable to Plant Cases.Supportive Fee Info Encl ML20235Q0291987-07-15015 July 1987 Advises That Cost Analyses for OL Application Reviews for 840624-860621 Completed.Breakdown of Review Costs by Program Ofc Encl.Util Will Receive Invoices for Listed Amounts ML20211P1311986-12-16016 December 1986 Advises That Encl Order Terminating CPPR-170 & CPPR-171 for Facility & Notice of Withdrawal of Application for OLs Have Been Forwarded to Ofc of Fr for Publication,Per Return of CPs by Util on 850301 ML20214R5961986-09-23023 September 1986 Responds to 860918 Request & Forwards Printout of Recent Filings in Facility Case.No Ruling Made by ASLB Since 860618 Ruling.Served on 860924 ML20203E8271986-07-18018 July 1986 Informs That Recently Received Encl Ltrs Procedurally Insufficient.Requests That Provisions of Sections 2.701, 2.708,2.709 & 2.712 Re Filing & Svc of Documents Be Reviewed.Served on 860722 ML20138H5461985-12-0909 December 1985 Forwards Overview of Regional Ofc & Detailed Organizational Charts for Ofc Divs Due to Recent Organizational & Staff Changes.W/O Encl ML20138Q8301985-12-0303 December 1985 Further Response to FOIA Request for Records Re Voluntary or Required Redress of Sites Where Const Was Terminated, Including Crbr & Legal Analysis.Forwards App E Documents.App D & E Documents Available in Pdr.Photographs Also Available ML20127P1861985-06-26026 June 1985 Forwards Insp Repts 50-546/85-01 & 50-547/85-01 on 850122-0614.No Violation Identified ML20133C7371985-06-14014 June 1985 Further Response to FOIA Request for Documents Re Site Redress Where Plant Const Begun,Including Clinch River Facility & NRC Legal Analysis Re Redress.Forwards App B Documents.App C Document Withheld (Ref FOIA Exemption 5) ML20134A8941985-06-10010 June 1985 Further Response to FOIA Request for Records Re Ford Amend Study.Records in App K Available in Pdr.Review for Addl Records Continuing ML20126J9081985-03-0606 March 1985 Further Response to FOIA Request That All Internal Memos to Div of Licensing from May-Nov 1984 Which Provided Draft SER, SER Sections & Questions or Requests for Addl Info Be Placed in Pdr.App C Documents Placed in PDR ML20134B2431983-02-0202 February 1983 Confirmatory Action Ltr Re Problems Identified During 830124-28 Special Insp Concerning safety-related Electrical Work at Facilities.Discussions Lack Continuation of Stop Work Order Encompass Electrical Auxiliary Steel IR 05000546/19820111982-07-30030 July 1982 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in IE Insp Repts 50-546/82-11 & 50-547/82-11 ML20058G3071982-07-20020 July 1982 Discusses Meetings to Review Results of NRC Evaluation of Util Regulatory Performance in Connection W/Nrc Systematic Assessment of Licensee Performance (Salp).Final Rept W/Minor Changes & Comments Encl ML20054M9401982-06-25025 June 1982 Notifies That Addl Time Will Be Allowed to Comply w/10CFR50.34(g), Compliance W/Srp. Required Info Expected within Approx 3 Months from Tendering of OL Application in Dec ML20054L7731982-06-23023 June 1982 Forwards IE Insp Repts 50-546/82-11 & 50-547/82-11 on 820517-21 & Notice of Violation ML20054L7121982-06-22022 June 1982 Forwards IE Insp Repts 50-546/82-10 & 50-547/82-10 on 820501-31 & Notice of Violation ML20132C6521981-06-25025 June 1981 Responds to Encl Re Constituent Mh Schwartz on Resumption of Concrete Work at Site ML20126M8251981-06-16016 June 1981 Advises That Interim Review of Westinghouse Owners Group Submittal for Action Plan Item I.C.1, Guidance for Evaluation & Development of Procedures for Transients & Accidents, Is Complete.Dg Eisenhut Encl ML20126K4311981-05-12012 May 1981 Concurs W/Glenn a Black Lab & State of in Recommendations to Request Determination of Eligibility of Site 12Je4 (Referred to as Mcneil Stone Fort)For Inclusion in Natl Register of Historic Places.Technical Paper Encl ML20126L3681981-03-20020 March 1981 Responds to 800926 & 810304 Comments on Util Rept Entitled Evaluation of In-Place Concrete - Marble Hill Nuclear Generating Station,Units 1 & 2. Quality Adequately Assessed by Sargent & Lundy Methodology.Supporting Matl Encl ML20126F9681981-03-18018 March 1981 Discusses NRC Actions Under 10CFR2.206 Taken in Response to Save the Valley 800507 & 14 Comments & Supporting Affidavits.Ltr Concludes NRC Consideration of Filings ML20148H8081980-10-31031 October 1980 Ack Receipt of 801023 Interim Deficiency Rept Re Substitution of Certain Matls for Those Allowed by Spec for Stainless Steel Liner Work ML20148H6661980-10-31031 October 1980 Ack Receipt of 801024 Interim Deficiency Rept Re Welds on Cable Tray Hangers ML20126M3271979-08-13013 August 1979 Forwards IE Investigation Repts 50-546/79-08 & 50-547/79-08 Re Allegations of Improper Repair of safety-related Concrete Structures & Concealment of Nonconforming Concrete Areas at Facility ML20204C9661978-11-24024 November 1978 Forwards IE Bulletin 78-12A,suppl to IE Bulletin 78-12. W/Encl ANO:7811300055 IR 05000546/19780071978-11-17017 November 1978 Forwards IE Inspec Repts 50-546/78-07 & 50-547/78-07 on 781011-12 During Which No Items of Noncompliance Were Noted ML20148R4541978-11-16016 November 1978 Lists Staff Review Categories 2,3 & 4 for Consideration in Preparation of FSAR & Lic Review.W/Encl Descriptions of Categories 2,3 & 4 ML20148H8521978-11-0606 November 1978 Forwards IE Circular 78-18 ML20150D0241978-10-26026 October 1978 Forwards IE Inspec Repts 50-546/78-06 & 50-547/78-06 on 780906-08 & 780919-20 During Which No Items of Noncompliance Were Noted ML20150B4331978-10-17017 October 1978 Clarifies Concerns Re Intake Screen Design as Related to safety-related Cooling Sys.Previous Staff Ltr Should Have Clarified Apparent Misconceptions Re Const of Intake Discharge & Dredging Sys ML20147D6211978-09-29029 September 1978 Responds to 780911 Request for Lic Bd to Take Action Re Proposed Increase in Fuel Storage Pool.Aslb Has Jurisdiction Only Over the Radon Question ML20134B1491978-04-0404 April 1978 Forwards CPPR-170,CPPR-171 & Fr Notice of Issuance of CPs ML20235D3021975-12-10010 December 1975 Discusses Establishment of Schedule for Review of Application for CP for Facility.Estimates Partial Initial Decision on NEPA & Site Suitability Matters to Be Issued on 770423.Comments on Encl Summary of Milestones Requested ML20235D1171975-11-21021 November 1975 Forwards Addl Questions Requiring Formal Responses.Amended Responses Required to Remainder of Incompletely Answered Questions Listed in Encl 1.Responses Also Needed to Questions Listed in Encl 2.Responses Requested by 751208 ML20132C1641975-11-0303 November 1975 Discusses Qualification Review of Plants for Replication Per 741119 Request.Plant Design Acceptable for Replication 1987-09-09
[Table view] |
Text
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Dr. Michael A. Cassaro Professor of Civil Engineering.
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University of Louisville (.__u. ,. %
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Dear Dr. Cassaro:
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':: I 6 This is in reply to your letters of SeptembeT'26,1980 and March 4, 1981, expressin~g your concerns and evaluation of the Public Service Company 'of Indiana (PSI) Report entitled " Evaluation of In-Place Concrete - Marble Hill Nuclear Generating Station, Units 1 and 2". We understand your principal concern to be that the test program devised by Sargent and lundy (S&L) engineers and conducted'by the Portland Cement Association
- (PCA) does not satisfy the Nuclear Regulatory Commission's (NP,C) criteria for 95% reliability with 95%. confidence factor.
The NRC has reviewed your concerns and concludes that the required reli-ability and confidence can be demonstrated by the methodology described in the S&L revised report. The NRC's basis for this conclusion is outlined in Attachment "A" to this letter which addresses your major concerns and considerations and is summarized as follows:
- 1. The methodology you recommend (MIL-STD-105D) is intended primarily for controlling production quality. The assessment at Marble Hill does n.ot involve production. Testing was performed for the purpose ef-evaluating concrete consolidation at different locations containing var:.ous_ configurations of concrete and embedded reinforcing steel.
- 2. While MIL-STD-105D would require more samples, it would also allow more defectives, whereas the S&L methodology allowed no defectives in the first_ test samples. If a defect were to be found in the first 59 tests, the S&L program requires an increase in the sample size.
- 3. Both MIL-STD-105D and the S&L methodology are based on the same concept; however, their use for a given problem. requires engineering j ud gmt:nt . The S&L program combined the conceptual model wi-h engi-neering judgment to obtain conservative results.
i.
4 MIL-STD-105D does not account for human error. The S&L methodology requirement of 95% reliability and 95% confidence is supported by photographic records, evaluation by drawings, review of placement records, evaluation of concrete cores, and the involvement of three separate organizations in the evaluation process. This has minimized
4974 - -_
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March 20, 1981 Dr. Michael A. Cassaro 5. It is our opinion that the total volu=e of concrete as it relates to locations of potential non-consolidation was accounted for by the S&L program. Moreover, a conservative bias was introduced based on engineering judgment in that the samples were representative of 'all structures with the exception that more examinations were conducted in " congested" areas than a purely randem sample would have provided.
i
- 6. With respect to your concern that defectives were overlooked, the purpose of the S&L methodology wa,s to identify internal concrete consolidation problems. To that extent, the external and known conditions are not considered to have an impact on the methodology l
l used by S&L.
- 7. Another consideration, which has a conservative influence, is that all defects found prior to (or af ter) the subject test and evaluation pregram have been or will be repaired. This reduces the numbers of defectives in the lot (total volume of concrete).
As you know, microseismic testing is but a portion of the overall program
! by which KRC instructed PSI to verify the adequacy of existing concrete f construction at the Marble Hill site. This verification consists of four
! distinct facets as follows:
Examination of Concrete patches: All concrete patches placed prior *.o A.
the suspension of construction will be removed for further examination (destructively evaluated) and repaired in accordance with approved procedures.
l
- 3. Volumetric testing: The interior of the concrete was tested by a l
nondestructive (microseismic) technique. The number of samples to be tested was derived from probabalistic considerations, and test l locations were established using engineering judgment to ensure coverage of all types of structural elements. A sample of the I
condestructive test results The was further examined and verified by destructive testing involved removal of destructive testing.
concrete cores and line drilling for direct examination. The report of this portion of the verification program is the subject of your letter.
C. Surface Exanination: All accessible concrete surfaces will be examined for defects.
l D. Record exar.ination: previous testing results (all record types) for records, the existing concrete, as well as handling and placement have been examined.
Previous NRC inspection findings have also been reviewed.
In our opinion, the evaluation of all four facets of this program will com-prehensively determine the adequacy of all previously placed safety-related concrete. Unsound concrete will be repaired as necessary.
March 20, 1981 Dr. Michael A. Cassaro As noted above, NRC is not relying solely on the microseismic samplin'g exacination to demonstrate the quality of the concrete at Marble Hill.
~
There are three other separate evaluations, one of which includes substan-Based on all of these actions, the NRC has tial destructive examination.
concluded that the quality of the in-place concrete at Marble' Hill has been adequately assessed by the method described in the Sargent and Lundy report. -
To this extent NRC requirements have been met.
However, we would be We believe this letter addresses your concerns.
ple nsd to arrange a meeting with you, Dr. Alexan, der and our technical staff to c'isensa any' areas of further concern on your part regarding this matter.
Sincerely.
mi _
G &J(4 a~
t ' James G. Keppler S
Director
Attachment:
As stated l
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. ATTACHMENT A Summarv You contend that the statistical model used to test-Marble Hill concrete quality'in.S&L Report No. SL-3753, Evaluation of In-Place Concrete, does not provide the confidence.and reliability levels imposed by the NRC.
TheLS&L sampling model is described in Report No. SL-3753, Volume 1, t Section III. NRC believes that the testing method used by PSI has demon-l strated the imposed levels of reliability and confidence as indicated by the following specific responses to your comments:
- 1. - Comment- "The total volume of concrete was not accounted P. 2, line 11 for in the sampling plan".
Resconse The sample size was based on the population size
- (i.e., the total volume of concrete) as it relates to locations where combinations of concrete and reinforcing steel could affect consolidation.
Since the population size was very large (assumed <
to be infinitely large), Eq. 2 established a limit of 59 tests without encountering a defective to achieve 95% reliability with 95% confidence factor.
- 2. - Comment "Nor could a standard multiple sampling plan be
- p. 2, line 12 devised using Equation (2) only".
Response Equation 2 results in different sample sizes for different numbers of defectives. These numbers are given in Report No. SL-3753, Table III-1. If one defective was observed in the first sample of 59 test areas, the test plan required that 93 areas be tested. The fact that the first 60 areas tested l did not have any defects attests to the quality of the in place concrete. The acceptance criteria of l 95% reliability with 95% confidence was met. Hence, i there was no need to proceed to subsequent levels of testing. A " defective" is the existence of unacceptable internal voids or honeycocbs or other consolidation condition as confirmed by additional examination, i.e., drawings review, destructive evaluation (cores from the concrete), and analysis.
" Influence of instrument error and human error en
- 3. Comment
- p. 2, Item I statistical approach".
Response pulse-echo testing has been successfully utilized for in-place concrete examination in the past at nuclear and fossil plants. The testing procedure was also qualified at the Marble Hill site in the m ee m - n-e-,-- ,.r. --e"*e-w +~w-e- +e-- v w- v--m err w + ~<m- = = --s<~s ~ w-wme w e ' % w *+ v = ~rv ~ ~~r-r<+~w aver 4 t- m w w - h m s' -rn-- e r%-* vm+-
k presence of.an NRC inspector. Qualifications entailed the identification and subsequent destructive confirmation of conditions adverse to concrete quality. In every instance, the microseismic results agreed with destructive confirma tions .
The pulse-echo testing detects discontinuities in the.in place concrete. The presence of rebars, conduits, and pipe sleeves could also be recorded n
-as discontinuities. Additional evaluation was always necessary and it was always done.
In all the qualification tests done, the testing procedure has not failed to. detect a-discontinuity if one was present. At Marble Hill, if a discon-tinuity was indicated by the pulse-echo testing but could not be explained by studying the drawings and available data, a core was .taken. Becauseoof the instrument's high sensitivity to discontinuities and because of'the grid system used, it is extremely unlikely that " solid" concrete would be indicated where a void exists. The pulse-echo technique will find discontinuities. The techniques' limitation is the inability to exactly quantify or characterize the discontinuity found. Because of.this, photo-graphs of the electronic indication, construction drawings, and concrete cores were used to confirm any indication. Hence, the reliability of pulse-echo testing results, as far as detecting discontinuities l
in concrete is concerned, is greatly enhanced.
L In the interest of further clarification, the ;
testing of concrete at Marble Hill was done in three stages: pulse-echo testing (photographic records); review of drawings and construction records for correlation with pulse-echo test data, and finally, coring. This sequence of actions has significantly assured that the results of the testing are accurate and that buman error has been minimi:ed to the extent feasible, Once the measuring technique and evaluation methodology were establis.hed, the testing program was based on the conservative assumption of an infinite population size. No qualification of
" human and instrument error" was considered necessary because the potential for such errors was minimized by independent reviews and evalu-ations which confirmed that the indications were not defects.
! 2
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. = _ .
m
' We recognize that the sampling program recommended by you also does not include the uncertainties introduced by human and instrument errors.
With regard to Mr. Muenow's qualifications, he is an internationally known authority in this field with a degree in civil. engineering and more than twenty-five years experience. Mr. Muenow is also the developer of this technology. His extreme care and professionalism in performing the tests was demonstrated to those witnessing the testing, including the.NRC. 'Also, the photographs taken
' of the cathode ray tube. indications represent pe rmanent records, which can be examined by all concerned. It should be recognized that three other separate organizations participated with Mr. Muenow during these examinations. Each had a separate responsibility to minimize error during data acquisition and evaluation. In addition, transducer performance tests were conducted at the beginning and end of each' test period to verify equipment signal response.
These tests would minimize the potential for instrument errors.
- 4. Comment " Random selection not used - defectives overlooked".
p . 4, Item 2 Since the testing program was initiated following the concern expressed by the NRC over the concrete placement procedures at Marble Hill, the question of sampling was addressed using the experience gained in nuclear concrete construction. A higher potential for voids exists in the areas of concrete congested by rebar and embedment arrangement than in concongested areas. Hence, engineering prudence required that a high proportion of these congested areas be included. At the same time, the placement procedures required that like caution be exercised in the concreting of noncongested areas. Therefore, it was considered advisable to include concongested areas also to assure a total cross-section of sampling.
Since the testing progrs= was used to qualify the r
entire volume of in-place concrete at Marble Hill, the sample had to be representative of all structural elements. The test areas covered the containment, fuel handling building, auxiliary I -
l l .2 t
t- - , , _ -. . . . , _ . . _ - . _ , , , , , _ . . _ . . , , . , _ _ _ _ . , .
building, and turbine room at different elevations.
Various structural elements (i.e., basement, wall, beam, column, and floor. slab) were included in the sample.
Such a representative sample could not have been obtained by a purely random sampling devoid of engineering judgment. Since' half of the sample is from congested areas, a conservative bias is
- introduced into the testing. ,
The void under the Auxiliary Building slab, referred to in the Report No. SL-3753,Section VII, was one of the reasons for the testing program. Having been discovered, it could not be included as part of the statistical. sampling program. The program aimed at assessing the quality of the remainder of the concrete.
- 5. C:= ment
. " Risks associated with sampling plan".
p . 4, Item 3-Resconse We agree with the statement that " acceptance sampling (in this context) is not used at Marble Hill to control quality, but rather to determine whether a desired quality exists".
We further believe that the concrete consolidation
- quality can be judged by testing an adequate sample as determined in the biased sampling program dis-cussed above. Also, the testing program was aimed at assessing the percent of defects (concrete conconsolidation); in this sense, past experience has no bearing on the sample size.
We do not share the concern expressed in your state-ment that "it must be considered alarming when a plan detects zero defects where obvious defects exist".
The sampling program did not assure zero defects in the population; but it did require that the frequency of such consolidation defectives be acceptable. The testing program has demonstrated that there was no unacceptable proportion of veids deep inside the structural elements. It should be recognized that in most instances honeycomb will l
not occur without some surface indication of its f presence.
The visible defects were not examined by the pulse-echo testing progra=. These defects were thoroughly inspected under the Construction
_~ --_.__ . . _ _ ._ . ~ . , _ . , _ _ . _ _ . . -.- ,_,., , . _ . _ - -_ ,._ . . . _ . - , x .
Verification Program. The pulse-echo testing strictly aimed at examining the concrete con-solidation inside the structural elements.
- 6. Comment " Proposed sampling plan".
- p. 5, Item 4 Resoonse As explained earlier, a conscientious effort was made to test in areas of potential discontinuities;
' no defective areas were found in 60 tests, The conditions of testing - pass or no pass - met the theoretical concept contained in Eq. 2, and appropriately considered the total volume of the concrete. We feel that with 95% confidence, the percent of defective concrete relative to internal consolidation is less than 5%.
The purpose of Military Standard MIL-STD-105D is to statistically control the quality of production.
It is intended for circumstances of continuous p;cduction; for this reason we do not consider its use <2ppropriate. In contrast, the entire population of in-place concrete at Marble Hill was available for inspection. Production was not involved. A representative sample was selected for testing, as per Eq. 2; hence the S&L plan is considered appropriate for the problem under study. At Marble Hill, an extensive in-process testing program of concrete and of concrete I
constituents has been and still is in effect.
We do not consider production testing as being consistent with a plan to test a given quantity of in-place concrete. The program outlined in the subject S&L Report No. SL-3753 addresses r a fixed quantity of concrete.
Furthermore, while the MIL-STD-105D requires a larger sample size, it also permits a higher number of defectives. It is based on the same I
theoretical concept contained in Eq. 2. However, Eq. 2 as used in the sampling program devised by S&L did not alio. for any defectives for a sample size of 59 (60 actually used) to .aintain a 95%
I reliability / confidence factor; and had a defec:ive i been observed, the sample size would have been increased to 93 as given in Table III-1 of S&L Report No. SL-3753.
l l We do not regard the basis to consider one cubic i
yard of concrete as one unit as meaningful because
! of the nature of the defects which the program is required to identify.
t On the basis of the foregoing. NRC concludes "a
- .he sampling methodology used by S&L, and the adc*.4.ona1 . '
a da a acquisition and eva,uatien, has met er excaadad "-
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'". SE*C*el 4
- e-asteps .ake-e el of du"Iv"S and reli-ccnfidence abilig ,
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