ML20235B715
| ML20235B715 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/20/1987 |
| From: | Howard J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 10100, 10100-V01-R02, 10100-V1-R2, NUDOCS 8902140338 | |
| Download: ML20235B715 (91) | |
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l EMPLOYEE CONCERNS SPECIAL PROGRAM VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 10100 SOPJ l
UPDATED TVA NUCLEAR POWER
$90 'Al'40 338
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 l
.g SPECIAL PROGRAM REPORT TYPE:
- SUBCATEGORY Conrteuction REVISION NUI2ER: 2 (Final Report) i TITLE: Soils PAGE 1 0F 66 l
REASON VOR REVISION:
1 Incorporate TAS and SRP connents; Executive Sunnary; Line Management Response on Corrective Action; and Finalize Report Revision 1 Incorporate IAS and SRP connents and refinalize report Revisic n 2 PREPARATION l
PREPARED Y:
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DATE TAS:
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/ DA'IE CONCURRENCES CEG-H:M,5.tO\\1 6[l'1f 87 SRP 0 s.wE*li/
A d-Y-%f SIGNATURE DATE
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SIGNATUp[
DATE APPROVED BY: (
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~ECSP MANAGER
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'DATEj MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT OtJLY) 03457
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1 Pref ace, Glossary, and List of Actonyms for ECTG Subcategory Reports HISTORY OP' REVISION REV NLMBER PAGES REVISED c1EASON FOR CURECNT REVISION 3
i To clarify that one or more attachments will help the reader find where i particular concern is evaluated j
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' TVA EMPLOYEE CONCERNS REPORT NUYBER: 10100 r
SPECIAL PROGRAM J
FRONT MATTER REV:
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PAGE i 0F vill
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Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority l
(TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTC), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (OND) employee concerns flied befree February 1, 1986. Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns. Each of the concerns was a formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate. The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results of these investigations are communicated by four levels of ECSP reports:
element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for those concerns d. tectly affecting the restart of Seguoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues. An issue is a potential ptoblem identified by ECTG during the avaluation process 3s having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements etrly in the program, but issue definitions emerged from the eva3uation process itself. Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports 'dummarize the evaluation of a number of elements-However, the subcategory report does more than collect element level evaluations. The subcategory level overview of eierent findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparef.t at the element level.
To make the subcategory reports easier to understand, three items have been placed at tha front of each report: a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern nu6bers; identifies other suttategoriec that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
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I TVA EMPLOlEE CONCEMS REPORT NUMBER:
10100
)
l SPECIAL PWOGRAM i
FRONT MATTER REY:
2 PAGE 11 0F vill The subcategories are thenselves sumNSrized in a ceries of eight category reports.
Each category report reviews thh major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations Industrial safety construction
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I material control i
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operations quality assurance / quality control welding engineering
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A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TkA Office of the Inspector General.
Just as the subcategory reports integrute the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying caases of those problems that run across more than one 4
subcategory.
I A final report will integrate and assess the information collected by all of the lower level reports prepared for th'a ECSP. including the Inspector General's report.
For more d2 tail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tannessee Valley Authority Employee Concerns Tast Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities. It also specifies the procedures that were followed in the investigation, reporting, and closecut of the issues raised by employee concerns.
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM FR0hT MATTER REY: 2 PAGE 111 0F viti
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ECSP GLOSSAFY OF REPORT TERMS
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classification of evaluated issues the evaluation of an issue leads'co one of the following determinations:
A Class A: Issue cannot be verified as factual l
Class 8: Issue is factually accurate, but what is described is not a problem (i.e., not a condition requiring corrective action)
Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue j
was undertaken Class D:
Issue is foetual and presents a problem for which corrective j
action has been, or is being, taken as a result of an evaluation i
Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG i
evaluation of an issue raised by an employee concern.
l col'.ective significance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
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concern (see " employee concern")
i corrective cetion steps taken to fix specific deficiencies or discrepancies j
revealed by a negative finding and, when necessary, to correct cauces in order to prevent recurrence.
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I criterion (plural: criterial a basis for defining a performance, behavior, or j
quality which ONP imposes on itself (see also " requirement").
t element or element report an optional level of ECSD report, below the subcategory level, that deals with one or more issues.
emplovee concer,k a f ormal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or j
inappropriate; usually documented on a K-form or a form equivalent to the K-form.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PkOGRAM FRONT MATTER REY:
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PAGE iv 0F viii evnluator(s_1 the individual (s) assigned the responsibi)ity to assess a specific j
grouping of smoloyee concerns, findings includes both statements of fact and tho judgments made about those facts during the evaluation process; negative findings require corrective action.
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Issue a potential problem, as interpreted by the ECTG during the evaluation l
process, raised in onc or more concerns.
K-form (see " employee concern")
reautrement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
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- Terms essential to the program but which require detailed definitdon have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclest-safety-related, unreviewed safety-significant question).
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s TVA EMPLOY 3E CONCERNS REPORT NUMBER: 10100 SPF.CIAL PROGRAM FRONT MATTER REY: 2 PAGE v 0F viii Acronyms AI Administrative Instruction AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society ANSI American National Standards Instituto ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant LAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Conunitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON)
i TVA EMPLOYEE CONCERNd REPORT NdMBER: 10100 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vi 0F viii DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ICN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employse Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design ERT Employee Response Tess or Emergency P.esponse *.ieam FCR Field Vhange Request FSAR Final Eafety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction i
HVAC Heating, Ventilating. Air Conditioning i
II Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice J
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 l
4 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vil 0F vill l
l L/R Labor Relations Staff MLAI Modifications and additions Instructica l
EI Maintenance Instruction MSPB.
Merit Systems Protection Board l
l MT Magnetic Particle Testing l
N"R Nonconforming Condition Report l
NDE Nondestructive Examination I
NPP Nuclear Performance Plan MPS Non-plant Specific or Nuclear Procedures System 9'QAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commiscion l
NSB Nuclear Services Branch NSRS Nuclear Safety Review Staff l
NU CON Division of Nuclear Construction (obsolete abbrivittion, see DNC) l NUMARC Nuclear Utility Management and Resources Committee l
OSHA Occupational Safety and Health Administration (or.Act)
ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Persor.a1 History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality control QCI Quality Control Instruction
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i TVA EMPLOYEE CONCERNS REPORT FUMBER: 10100 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE viii 0F vii)
QCP Quality Control Procedure QTC Quality Technolegy Company RIF Reduction in Force RT Radi,ographic Testing SON Sequoyah Nuclear Plant SI Surveillance Instruction i
SOP Standard Operating Procedure j
SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation j
TAS Technical Assistance Staff j
T&L Trades and Labor TVA
- Tennessee Valley Authority TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant i
WR Work Request or Work Rules WP Workplans
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PR00 RAM REVISION NUMBER:
2 PAGE 2 0F 66 OUTLINE OF CONTENTS PAGE l
SUBCATEGORY EXECUTIVE SU W RY 1.'0 Characterization of Issues 5
1.1 Introduction 5
Watts Bar Nuclear Plant Sequoyah Nuclear Finnt 1.7 Description of Issues 6
1.2.1 Barrier Trenches - (WBN) 1.2.2 Sint Hole - (VBN) 1.2.3 Blowdown Lines Backfill - (WBN) 1.2.4 ERCW Pipelines Backfill - iWBN) 1.2.5 North Valve Room Backfill - (WsN) 1.2.6 Low Volurne Waste Holding Pond Dike - (WBN) 1.2.7 General Concerns - (WBN) 1.2.8 Dry Active Waste (DAW) Building - (SQN) 2.0 Sumrnan 8
2.1 Sununary of Issues 2.2 Sununary of Evaluation Process 2.3 Sunenary of Findings 2.4 Sununary of Collective Significance 2.5 Sunrnary of Causes 2.6 Sununary of Corrective Action
TVA EMPL0f(E CONCERNS REPORT NUMBER: 10100 SPECIAL fROGRAM REVISION DUMBER:
2 PAGE 3 0F 66 PAGE 3.0 Evaluation Process 10 3.1 General Method Evaluation l
Barrier Trenchet - (WBN) 10 Sihk Wole - (WBN) 11 Slowdown Lines Backfill - (WBN) 12 ERCW Pipelines Backfill - (WBN) 12 North Valve Room Cackfill - (WBN) 13 Low Volume Waste Holding Pond Dike - (WBh) 14 General Cencerns - (WBE) 14 l
Dry Activ) Waste (Dist) Building
-(EQN) 14 Re_guigerents or Criteria Established fcr Individual Issues 3.2 u
3.2.1 Barrfer Trenches 15 3.2.2 Cink Hole 21 3.2.3 Blowdewn Line Backfill 22 3.0.4 ERCW Pipeline Backfill 23 3.2.5 North VLive Room Backfill 24 3.2.6 Low Volume Waste Holding Pond Dike 25
4.0 Findings
4.1 Barrier Trenches 28 4.2 Eink Holo 46
_,m TVA EMPLOYEE CONCERNS REPORT NUMBEE: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 4 0F 66 PAGE 1
4.3 Blowdown Lines Backfill 48 f
4.4 ERCW Pipelines Backfill 50 4.5 North Valve Room Backfill 53 4.6 how volume Waste Holding Pond Dike 54 q
4.7 General Concerns-(kBNL 58 4.8 Lry Active Waste (DAW) Building - (SON) 59 q
5.0 Collective Significance 60 5.1 Significance of Each Issue 4.0 Cause 63 l
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l 7.0 Corrective Action 64 7.1 Corrective Action Already Taken or Planned 8.0 Attachments l
l Attachment A - Listing of Employee Concerns l
Attachment B - List of Evaluators Attachment C - List of Conceprs by Issue i
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EXECUTIVE
SUMMARY
S.91LS.
SUBCATEGORY 10100
SUMMARY
OF ISSUES This report presents the findings of the eight issues that were derived from l
twenty employee concerns. The issues involve two major questions:
(1) Had l
improper backfill material and/or backfill placement methods resulted in the 1
structural integrity of the structures being compromised? (2) Had backfill IR2 for some plant features been placed on foundations that were questionable and l
had not been properly justified?
l Seven of the issues were site-specific to Watts Bar Nuclear Plant (WBN) and one issue was site-specific to Sequoyah Nuclear Plant (SQN).- The four issues deemed " safety-related" were at WBN and consisted of (1) barrier trenches.
(2) ERCW pipeline backfill, (3) north valve room backfill, and (4) general.
The issues deemed "non-safety-related" were made up of three WBN issues.
(1) sink hole, (2) blowdown lines backfill, and (3) low volume waste holding pond dike-and one SQN issue.. Dry Active Waste Building.
MAJOR FINDINGS The evaluations concluded that there was no evidence of significant programmatic problems. The backfill materials were correctly used, placed, inspected. and documented in accordance with drawings, specifications, and procedures in both " safety-related" and "non-safety-related" areas, except in two specific non-QA areas that have been analyzed as being acceptable. The Dry Active Waste Building (non-QA) required an evaluation of the soll structure of the foundation area prior to the start of construction activities on the building. The foundation was excavated, backfilled and compacted as a result of the evaluation.
COLLECTIVE SIGNIFICANCE OF FINDINGS The soils issues produced no programmatic problems, and only two site specific non-QA problems. The materials were correctly used, placed, inspected, and documented in accordance with drawings, specifications, and procedures to satisfy the structures designed function in all cases, both QA and non-QA.
The plant's ability to perform their designed function safely has not been compromised by any of the soils issues.
Engineering and Construction I
practices pertaining to soils were satisfactory.
IR2 Note: See Executive Summary Table Number 1 for Review Page 1 of 1
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IVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 66 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction Subcategory Report 10100 - Soils of the Construction Category of the Watts Bar Nuclear Plant (WBN) Employee Concerns Tast Group (ECTG) details the evaluation of the backfill operations during construction and the foundation integrity of verlous features of the Watts Bar and Sequoyah Nuclear Plants. The 20 concerns were broken down and evaluated in eight major issuos.
Three of the concerns were general comments about WBN with no specific information and were evaluated from the results of the other aizteen concerns, investigated at WBN. One concern (JAN-86-002) involved the integrity of the Dry Active Waste Building (DAW) foundation at the Sequoyal. Nuclear Plant (CQN). This concern at SQN was evaluated as a separate issue. All concerns are site specific.
An independent engineering review of the barrier trench issue was performed, after the ECTG evaluation, by Robert L. Cloud Associates (RLCA). Inc. and reviewed by Professor H. Bolton Seed at the University of California at Berkeley (report RLCA/P154/91-86-001).
The RLCA. Inc. report addresses the concerns of the barrier trencbos at the WBN plant. The results of the RLCA. Inc. report have been incorporated into this evaluation report.
Watts Bar Nuclear Plant Employee Concern No.
Issue IN-85-066-001 Barrier Trenches IN-85-442-X13 Barrier Trenches IN-85-472-007 Barrier Trenches IN-85-446-001 Barrier Trenches IN-85-529-003 Barrier Trenches IN-CS-978-002 Br.rrier Trenches IN-85-978-003 Barrier Trenches IN-85-978-011 Barrier Trenches VI-85-040-004 Barrier Trenches WI-85-040-005 Barrier Trenches IN-85-442-I11 Sint Hole IN-85-196-001 Blowdown Lines Backfill IN-85-472-003 Blowdown Lines Backfill IN-85-529-004 Blowdown Lines Backfill
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
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PAGE 6 0F 66 i
IN-86-205-001 ERCW Pipelines Backfill i
IN-85-978-003 North Valve Room Backfill IN-85-978-011 North Valve Room Backfill IN-85-088-002 Low Volume Waste Holding Pond Dike IN-85-302-001 General IN-85-978-013 General IN-85-472-006 General l
.Seouoyah Nuclear Plant i
JAN-86-002 Backfill DAW Building l
These perceived concerns may be the result of lack of communication:
I organizational cooperation; inadequate design information; lack of management / supervision control; and inadequate procedures, standards, site requirements, or work practices.
1.2 Description of Issues, 1.2.1 Barrier Trenches The barrier trenches had ten concerns that questioned the reason for the barrier trenches and/or whether the designed function had possibly been compromised by the type material used, the methods used in placing and testing fill material, the existing surface conditions of the trench area before backfill placement, a water source that had opened a hole in j
the slope face, and the stability of the slopes from erosion. Another area that needed resolution was whether Division of Nuclear Construction (DNC) or Division of Nuclear Engineering (DNE) had any breakdowns in specifications or I
procedures used in the design and/or construction of the f
trenches.
l 1.2.2 Sink Hole The issue was that a large sink hole had been formed in the earthfill on the east side of the Turbine Building (TB), that the necessary corrective action had not identified the cause, and adequate corrective action had not been performed by the construction forces.
l l
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x, TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 66 1.2.3 Blowdown Lines Backfill The issue was that the cocling tower blowdown piping was leaking so badly, due to improper installation (improper.
backfill), that erosion below the piping would cause collapse j
of the pipe and the seismic barrier could be eroded. The concern stated that the pipeline was reworked because of improper backfill and a construction change notice (CCN) had to be issued because Quality Control (QC) inspectors would not take verbal directions from site engineering on the type of osektill material to be used.
1.2.4 Essential Raw Cooling Water (ERCW) Pipeline Backfill The issue was that improper backfill methods (uncontrolled dumping) were used during original installation of the ERCW piping, resulting in the 30-inch diameter pipe having excessive stress placed on them.
1.2.5 North Valve Room Backfill The issue was that personnel used improper and uncertified material, and placed the material in two or three foot lifts, resulting in material not meeting compaction levels.
1.2.6 Low Volume Waste Holding Pond (LVWHP) Dike The issue was that'the construction ersft personnel ignored QC inspectors instructions for backfilling operations and worked with site engineers to obtain approval to deviate from drawings and specifications. They were concerned that this would jeopardize the structural integrity of the dite and 1
also establish bad policy.
1.2.7 General Concerns:
Three concerns were very general which stated that there were procedure violations and intentional bypassing of Quality Assurance (QA) hold points.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 8 0F 66 1.2.8 Dry Active Waste (DAW) Building - (SQN)
The issue was that soil condition under the DAW Building was l
inadequate, potentially causing uneven settlement of the,
building.
l 2.0 SUKKARY 2.1 Summary of Issues I
There were two major areas of concerns:
I Improper backfill material and/or backfill placement methods had resulted in the structural integrity of the barrier trenches.
{
l pipelines, or dikes being compromised.
]
l Backfill for some plant features had been placed on foundations that j
were questionable and had not been properly justified.
j 2.2 Sunnary of Evaluation Process The evaluation of these concerns consisted of a review of applicable documents; interviews of cognizant personnel; physical walkdowns of site areas involved to observe actual conditions; a review of l
pertinent inspection records and drawing. and a review of
)
investigation reports generated by the Nuclear Safety Review Staff (NSRS). Employee Response Team (ERT). DNE, and/or DNC organizations as a result of their evaluation of similar concerns. RLCA. Inc. Was retained after ECTG had performed it's evaluation to provide an independent engineering report on existing soil conditions of the barrier trenches to ensure that safety had not been compromised l
(RLCA/P154/01-86/001). The RLCA Inc. report was incorporated into l
this report as additional basis for the conclusions.
The evaluation approached the concerns with regard to three questions:
Were the ecncerns factualf If the concerns were factual, did the situation compromise the structural integrity of the plant and/or had the problem been corrected?
l If a problem existed, was it programmatic or an isolated incident?
l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 9 0F 66 2.3 Summary of Findinas The Issue Findings for the soil subcategory were evaluated, and there was no evidence of significant programmatic problems. These concerns were addressed only within the construction category.
The concerns varied with respect to their accuracy of site conditions and/or actions of DNC and DNE personnel. However, any problems concerning the backfill material, backfill methods used, and foundations of the identified structures had been documented and analyzed, and have not compromised the structural integrity of the WBN.
2.4 Summary of Collective Slanificance The soils issues introduced no programmatic problems. There were I
only two site specific non-QA problems. The materials were l
correctly used, placed, inspected, and documented in accordance IR2 with drawings, specifications, and procedures to satisfy the I
structures designed function in all cases. The plants' ability to i
perform their design function safely have not been compromised by l
any of the soils issues. Engineering and Construction practices l
were satisfactory in these soils applications.
I 2.5 Summary of Causes The 20 concerns resulted in no generalized cause. The problem areas were isolated drawing and specification interpretations in the non-QA area.
2.6 Summary of Corrective Action No significant corrective actions were necessary with regard to general soil conditions at WBN and SQN. However, three areca will require minor corrective actions.
Barrier Trench:
1.
DNE-CEB to issue ECN to excavate the seepage point area and cosmetically repair slope damage on southwest side of intake pumping station, after a monitoring program.
2.
WBN FSAR Section 2.5: Incorporation of underground barrier "as-built" information was incorporated into the WBN FSAR.
Low Volume Weste Holdina Pond Dike 1.
WBN DNE Civil Engineers to initiate an ECN to put note on drawing 10W228-1 clarifying use of dike.
4
1 e
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100
)
SPECIAL PROGRAM REVISION NUMBER:
2 l
PAGE 10 0F 66 3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation Barrier Trenches i
Reviewed the design drawings, specifications and procedures related to the underground barrier trench to become familiar with the designed aspects and requirements for constructing the trenches.
Reviewed Engineering Change Notice (ECN) 3960 and WBN Final Safety Analysis Report (FSAR) Section 2.5.4.2.1.2, 2.5.4.2.1.3, 2.5.4.8, 2.5.5.1.2 to determine the basis and function for the Barrier Trenches.
Reviewed NSRS Investigation Report IN-85-442-X13 and DNE/DNC's response for previous investigative work and conclusions drawn to determine if further investigation was required.
j Interviewed responsible DNE design engineers to establish the designed function, checked for documentation and backup to changes from original design to the actual condition, and any documentation on field inspections that were made to approve site conditions by verbal approval.
Interviewed the responsible DNC WBN engineers to determine the construction methods used, and discussed the as built conditions of 1
the Barrier Trenches as construction progressed.
Interviewed Civil-Quality Control (CQC) inspectors to determine j
their views and inspection methods of the Barrier Trench areas.
Reviewed Nonconformance Reports (NCRs) 5257, 5131, 6323, 6338, and 5804 for determining if areas of specification and/or procedural failure had been documented.
Reviewed Nuclear Regulatory Commission (NRC) Inspection Reports 50-390/83-41, 50-390/84-16, and 50-390/8*-64 for determining NRC inspection findings on the trenchen A and B backfill placement and inspection practices.
Reviewed backfill daily reports for 1983 and 1984 for barrier trenches to verify material and required inspection test records.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 11 0F 66 Reviewed WBN-Quality Control Procedure (QCP) 2.06, WBN-QCP 2.01, and General Construction Specifications G-9 and T-1 to determine the material placement, inspection, and documentation criteria for the backfilling operations.
Reviewed as-built cress-sections of Trenches A and B to determine the type backfill material used, location and inspection test results.
Compared as-built cross-section information to documentation that was supplied to the NRC with regard to engineering analysis and NCRs.
Interviewed cognizant Engineering Assurance engineers to determine documentation breakdowns in using " verbal instructions" to direct phases of work.
Inspected trench area 'to observe slope conditions attributed to artesian well and yard drainage concerns.
Reviewed WBN FSAR, amendment 55, dated April 15, 1985 for areas questioned by NSRS Investigation Report IN-85-442-113 to determine if changes had been made or were actually required.
Reviewed RLCA Inc., independent engineering report (RLCA/P154/01-86/001) August 4,1986, and September 15, 1986.
Sint Hole Interviewed cognizant WBN civil engineers to detarmine what, in their view, was done to evaluate and correct the sink hole problem on the east side of the TB.
Inspected the east side of the TB area to determine the existing site conditions and get familiar with actual site area.
Interviewed cognizant WEN QC inspectors to determine type of material used to backfill the area, the condition of the hole before backfilling, and the inspection criteria used.
Reviewed Backfill Daily Reports from April 29, 1985 to May 9, 1985, to verify material and required inspection test records.
l 1
TVA EMPLOYEE CONCERNS-REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 12 0F 66 Reviewed drawing (10N210, Revision 28) to verify the as-built site conditions in that area.
Reviewed DNC response to Employee Concern IN-85-442-X11.
Reviewed WBN-QCP 2.06 and General Construction Specifications T-l'to determine if all backfill was installed according to specifications and procedures.
Blowdown Lines Backfill Interviewed cognizant WBN civil engineers to deterhtine the reason for the pipeline leakage, the corrective action taken, and the backfill methods used.
Interviewed costizant WBN QC inspectors to determine inspection methods and whether problems existed with verbal instructions being used.
l Reviewed DNC responses to Employee Concerns IN-85-529-004, IN-85-196-001, and IN-BS-472-003 for information cad concurrence.
Inspected the Cooling Tower Blowdown Pipeline location for any physical evidence of continued water leakage.
Reviewed random samples of Backfill Daily Reports for original backfill operation between February 16, 1976 and October 11, 1978, for determining the adequacy of inspection records and type material used.
Reviewed drawings CCN-C47, Revision 0 through Revision 3 and memorandums to confirm construction requirements.
ERCW Pipelines Backfill Reviewed the design dr# wings 17A302-1 through -7, 17W302-2 through -7 and specifications relating to the backfill operations around the ERCW pipelines to become f amiliar with the design aspects and requirements for burying pipes.
Reviewed compaction test records of inplace material test to verify that potential " soft" areas in trench subgrade were inspected and verified acceptable.
-v IVA EMPLOYEE CONCERNS REPORI NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 13 0F 66 Interviewed cognizant WBN mechanical engineers to determine the condition of ERCW pipes when they were cut during concrete lining 1
installation.
Interylewed cognizant WBN CQC inspectors, that were' involved with concrete lining inspection. to determine the condition of pipe as they were cut during concrete lining installation.
Reviewed WBN Tracking and Reporting of Open Items (TROI) list for any NCRs generated against backfill of ERCW piping.
l Reviewed WBN FSAR sections 2.5.4.8 and 3.7.3.12 to determine the analysis that have been performed on existing soil conditions.
Reviewed NERS Investigation Report No. I-85-598-WBN for information l
and concurrence.
l Interviewed cognizant WBN civil engineers to determine their involvement and construction history of the pipeline placement.
Interviewed cognizant WBN CQC inspectors to determine inspection methods and whether problems existed with original backfill.
Reviewed Random Backfill Daily Repcrts and fill compaction test data for type A earthfill and limestone sand material to verify adequacy of inspection records, t.ype material used, and that all material placed was within specifications.
North Valve Room Backfill Interviewed cognizant WBN civil engineer to determine the construction history of the north valve room foundation.
Reviewed drawing (41N397-1, RI) to determine the design requirements of backfill material.
Interviewed cognizant CQC inspectors inrolved with backfill operations and inspections at the time of placement to determine if they knew of any discrepancies at the time.
Reviewed backfill daily reports to verify exactly what material was placed in area.
l f
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM l
REVISION NUMBER:
2 PAGE 14 0F 66 Low Volume Waste Holdina Pond Dike Reviewed drawings 10N225 Revision 10 and 10N228-1, Revision.1 to become familiar with design requirements.
Reviewed NSRS investigation report IN-85-088-002 and the series of l
DNC and DNE responses for information and concurrence.
Interviewed cognizant WBN civil engineers to determine the construction history and their views on the decisions made as dike construction progressed.
Interviewed cogr.izant DNE engineer to determine the design requirements and his directicns as dike construction progressed.
Interviewed cognizant CQC inspectors and supervisors tn determine inspection methods and any problems with the dike construction.
Reviewed various memorandums documenting the actions taken by DNC
[
personnel since dike construction was finished to clarify the construction practices on non-QA areas.
Reviewed General Construction Specification G-9 to determine construction specification requirements, i
l General Concerns - WBN i
The concerns (3) were general comments and were evaluated from the results of the other sixteen concerns investigated at WBN.
Dry Active Weste (DAW) Buildina - SON Reviewed Employee Concerns flies and other files, including QTC expurgated files, for additional information and reports related to this concern.
Interviewed Cognizant engineers of the SQN Modifications Unit to determine the construction details of the DAW Building foundation, i
inspection methods used, and documentation available of backfill operation.
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j TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 15 0F 66 Reviewed TVA memorandum to Impell about DAW Building contract, dated February 21, 1986.
Reviewed DAW General Arrangment Drawing Impell Number M-01, January 15, 1981.
Reviewed Impell Design of DAW Building fer SQN propscal, dated October, 1985.
ReFiewed memorandum - Project Manager, Segeoyah Engineering Project to Design Services Manager, Sequoyah Nuclear Plant, p
i dated February 3,1986,
Subject:
SQN-Dry Active Waste (DAW) i Building - Inspection of Foundation Excavation (B25 860203 020) to determine probisms and cutlincd course of action by site.
Reviewed drawing IMPELL CORP. C-01 to determine foundation requirements.
Reviewed SQN onsite employee concern impact evaluation report, JAN-86-020, dated February 5,1986.
3.2 Requirements Or Criteria Established For Individual Issues 3.2.1 Barrier Irenches i
i l
1 1
i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM i
REVISION NUMBER:
2 PAGE 16 0F 66 Information Source Comments (Applicable Procedures.
- The elements and attributes OE Document 9, Previous
- Applicable
- covered by the source documents Reports, NSRS/QTC/ERT
- Section
- are:
Investigation Reports i
Including revision or date) :
NSRS Invest. No.
- Barrier Trenches - A31 IN-85-442-X13
- Att:ributes WBNP FSAR. AMEND. 54
__2.5.4
- Barrier Trenches - Backfill l
Material 1
1 2.5.5 Barrier Trenches - Slope D0terioration i
l
- Fig. 2.5-225
- Barrier Tr6nches - Backfill l
Material
- Fig. 2.5-226
- Barrier Trenches - Backfill Material l
l
- Fig. 2.5-226a
- Barrier Trenches - Backfill l
l Material' J
1 Fig. 2.5-580
- Barrier Trenches - Designed Function
- F i t '. 2.5-581
- Barrier Trenches - Designed Function
~
Fig. 2.5-582
- Barrier Trenches - Designed Function
- Fig. 2.5-583
- Barrier Trenches - Desimped Function Gen. Construction. Specs
- Barrier Trenches - Backfill G-9. R5 Material l
I
- Barrier Trenches - Fill l -
Placement Gen. Construg lon. Specs T-1. E1: Sect. 1032 Barrier Trenches - Backfill
- Sect. 1075 Material l
l
m TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 66
.1 Information Source Comments (Applicable Procedures,
- The elements and attribut6s OE Doctrants, Previous
- Applicable covered by the source documents Reports, NSRS/QTC/ERT
- Section are:
Investigation Reports Including revision or date) :
t Drawirt 10N210 R28 Barrier Trenches I
Drawing 10N213-1. R1
- Barrier Trenches j
Drawing 10N213-2. R6 Barrier Trenches t
Drawing 10N215. R10 Barrier Trenches Drawing 10N225. R10 Barrier Trenches - Yard Drainate
~
Drawing,10N234 R14
- Barrier Trenches - Yard j
Drainate Drawing 10W235. R10
- Barrier Trenches - Yard Drainate Barrier Trenches - Slope Deterioration Drawing 10V245-1 R1
- Sheet 8 Barrier Trenches - Slope Deterioration j
1 Drawing 31N224-1. RIO Barrier Trenches - Incorr.
l Construction Drawing 41N200-1. R4 Barrier Trenches - Incorr.
Construction ECN No. 3960, dated 6/9/83 :
- Barrier Trenches - Backfill Material ECN.No. 4557, dated 1/24/84 :
Betrier Trenches - Backfill Material FCR No. F-3747 dateo 4/30/84:
- Barrier Trenches - Fill Placement WBNP-OCP-2.01 R6
- Barrier Trenches - Backfill dated 6/20/84 Material Barrier Trenches - Fill Placement
TVA EMPLOYEE CONCERNS REPORI NUMBER: 10100 SPECIAL PROGRAM RTVISION NUMBER: 2 PAGE 18 0F 66 Information Source
- Comments, (Applicable Procedures.
- The elomento and 6ttributes OE Documents, Previous
- Applicable cevered by the cource documents Reports, NSRS/QTC/ERT
- Section are:
Investigation keports l
Including revision or date) :
I I
WBNP-0CP-2.06 R4
- Carrier Trenches - Bactrill dated 7/0/82 Material I
Barrier Trenches'- Fill Placement j
3_.
j Barrier Trenches - Fill WBNP-0CP-1.02. R15 l
dated 11'/1/85 Placement
)
i I
NCR 5257 dated 12/1/83 Barrier Trenches - Fill l
Placement NCR 5131. dated 10/14/83 Barrier Trenches - Fill Placement l
l NCR 5804, dated 8/28/84 Barrier Trenches - Backfill Material l
Barrier Trenches - Fil_1 I
Placement l
l l
NCR 6330. dated Barrier Trenches - Fill (R1 i
September 24, 1985 Placement 1
'~
Backfill Dailey Reports for
- Barrier Trenches - Fill 1983. & 1984 Placement i
Barrier Trenches - Backfill Granular Compaction Test-Material Sand Cone Method Reports
~~~
for 1983 and 1984
- Barrier Trenches - Fill
]
Placement
^
~
I
- Barrier Trenches - Bactrill Material Memorandum. SONP & WBNP Barrier Trenches - Bactfill Design Projects Manator to:
Material WBNP Project Manager.
Barrier Trenches _ Backfill dated June 22,1976. "WBNF:
Material 1
-Yard Conduits and Pinint-:
Backfilling durint Construction" l
l l
1 I
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 l
SPECIAL PROGRAM l
REVISION NUMBER:
2
)
PAGE 19 0F 66 Information Source Comments (hpplicable Procedures.
- The elements and attributes j
OE Documents, Previous
- Applicablo covered by the source documents-
)
l Reports NSRS/QTC/ERT
- Section are:
Investigation Reports 1
Including revision or date) :
~
Memorandum. Manager of
- Barrier Trenthes - Backfill Construction to Material Construction dated January:
t Barrier Trenches - Fill 30 _}980. "Earthtill Placement t
_ Operstions and Quality Control" I
Memorandum. OE/CEB to CEB Barrier TrencheP Files. Dated August 1. 1983.:
l "WBNP-Licuifaction Potential Underground Barrier Remedial Treatment:
l
~~
--Status and Observations :
Based JniField Inspection"*
Letter. TVA to US NRC dated:
' ~
Earrier Trenches January 16, 176S. "Tu for-:
I mation Concernint the As
___, t j
l
__ Built Configuration of the:
]
Under-Ground Barrier at j
WBNP"__
I j
"As-Built" Cross-Sections
_ Barrier Trenches - Backfill l
for Barr!er Trenches Material Barrier Trenches - Fill I
Placement NRC Inspection Reports Barrier Trenches No. 50-390/83-41 (A02-
' - ~
831021 019) No. 50-390/84-:
i 16 (A02-84316 001) No. 50-:
390/84-64 (A02-840917 029)t Memorandum OE/OC WBNP Barrier Trenches "B" 3
Project Managers to W. R.
OC Response to NSRS Brown Project Manager.
Investigation Report WBNP Date March 18, 1986.
"NSRS Investigation Report:
IN-85-442-113 -Seismic Trenches l
l i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 20 0F 66 Information Source Commerts (Applicable Procedures.
- The elementi and attributes OE Documents Previous
- Applicable covered by the source documents Reports, NSRS/QTC/ERT
.: Section are:
l Investigation Reports Including revision or date) :
l Memorandum," Chief Civil.
- Barrier Trench - FSAR Engineer (R. O. Barnett to:
Cort'ections Chief Nuclear Engineer j
(J. A. Raulston). Dated March 27 1986. "WBNP-FSAR:
1
~
Section 2.5 -INeorouration:
of Underground Barrier "As:
-Built" Inf_ormation (841 :
_,860327 018) q Letter 7VA to NRC Dated.
Barrier Trenches December 6. 1983. "WPMP-Inspections
)
NRC OIE Rer, ion II Inspec- :
t'lon Report 50-390/83-41.
50-391/83-30,, Response to:
Violation" (A27 831206018):
l Memorandttm Director of Berrier Trgg;sts
" Verbal j
Nucleer Engineering To Instruction ^
l Those Listed. Dated April :
4 1986 " Policy Membrandum:
l Formal Apprnt al Recuired :
for Field ChanRe R&ouests":
)
(B05 860404 003)
Memorandum-J.C. Standifer.
- Barrier Trenches
{
Project Engineer. WBN
- FSAR Revision in j
Engineer Project to R. D.
Response to NSRS Investigation Tooley. Acting Site Design:
j Services Manager. WBN.
j Dated April 25. 1986. "WBN:
]
-FSAR Revision Pactazo Number 463" Suelear Dissatch. Dated
- Barrier Trenches May 5. 1984 "TV4 Admiral Unite-Response Evaluation Substantiates to NSRS Integrity of Underground Barrier."
Robert L. Cloud Associates :
- Barrier Trenches Report RLCA/ PISA /01-86/001 :
Independent Evaluation August 4 1986 and follow-up insDection Final: September 15. 1986 :
i
TVA EMPLOYEE CONCERNS' REPORT NUMBER: 10100 SPECIAL PROGRAM j
REVISION NUMBER: 2 PAGE 21 0F 66 j
l 3.7.2 Sink Hole l
{
Information Source Comments
]
(Applicablo Procedures.
OE Documents. Previous
- Applicable 4
Reports NSRS/QTC/ERT Section Ihvastigation Reports Including revision or date) :
j i
WBNP-0CP 2.06. R4
- Grandular - Fill Dated July 9. 1982 Material General Construction Specs Section 1032 : Grandular - Fill T-1 OC Response' Employee Concern:
- Sink Hole IN-85-442-X11 Corrective Action Backf-ill Dolly Reports c
- Sink Hole j
April 29, 1985-through Fill Inspection j
May 9. 1985 Drawint 10N210. R?8
- Sink Hole Location I
t
-+
m TVA EMPLOYEE CONCERNS REPORT NVMBER: 10100 SPECIAL PRJGRAM l
REVISION NUMBER:
2 PAGE 22 0F 66 3.2.3 Blowdown Line Backfill information Source Comments (Applicable Procedures.
OE Documents. Previous
- Applicable Reports, NSRS/QTC/ERT Section Investigation Reports Including revision or date) :
OC Response to Employee
- Blowdown Lines Concern IN-85-529-004 Backfill OC Response to Employes Blowdown Lines Concern IN-85-196-001 Backfill OC Response to Employee Blowdown Lines; Concern IN-85-196-001 Backfill CCN Number C-47 RO. RI. R2.
- Blowdown Lines - Backfill Memorandum to Files from a
Blowdown Lines - Backfill i
C. Freeman CEU. WBNP. dated:
September 4 1985. "WBNP-Soil Cnspection Requirements:
Memorkndum to Files from Blowdown Lines - Backfill S. T. Wrir.t. CEU. "WBNP OC.:
Dr3,nd February 27 1985.
"WBNP-Bactfill Operatton of:
ol T
rs Blowdown Pipe t
Drawings 17V303-1.-2.-3.-4 Blowdown Lines - Backfill
~
Drawint 10N213-1. R1
- Blowdown Lines - Backfill l
Drawing 10N213-2. R6
- Blowdown Lines - Backfill WBNP-0CP-7.01. R4 Dated BlIwdown Lines - Backfill June 20, 2984 WBNP-0CP-2.06. R4 Dated
- Blowdown Lines - Backfill July 9. 1982 Drawint 27WO2-2. R6
- Blowdown Lines - Backt ill
TVA EMPLOYEE CONCERNT REPORT NUMBEP.: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 23 0F 66 i
3.2.4 ERCW Dipeline Backfill Information Source Comments (Applicable Procedures.
OE Documents. Previous
- Applicable Reports. NSRS/QTC/ERT
- Section
, Investigation Reports j
Including revision or date) :
Drawings 11A302-1 Through -7:
ERCW Pipeline Backfill i
RO R6auirements WBNP-FSAR, Amendment. 54 3.7.3.12 ERCW Pipeline Backfill Dated April 15, 1965 Fig. 2.5-273 Analysig Criteria NSRS Report Number I-85-598-:
ERCW Pipeline Investigation WBN Random Dackfill Daily ERCW Pipeline Bc:Kfill j
Reports on ERCH fill _from :
Records May 10, 1982 to October 26.
1982
~
Drawings 17W302 - 1 and 7 ERCW Pipeline Backfill Design 2.5.4
$"RCW Pipeline BacEfill WBNP-FSAR. Amendment $4 Analysis of FDM Figure 2.5.549:
- Through - 553 :
Inplace MatSrial Compaction :
ERCW Pipeline Subtrade
.I Test Records from March 25.*
Test 1977 to November 3. 1977 l
mem
1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 24 OF 66 3.2.5 North Valve Room Backfill Information Source Comments (Applicable Procedures.
l OE Documents. Previous
- Applicable Reports, NSRS/QTC/ERT Section Investigation Reports Including revision or date) :
l EBNP - OCP 2.06. R4 1032 - Crushed Stone Dkted July 9. 1982 Fill Material General Construction 1032 - Crushed Stone I
Specifications T-1. R1 Fill Material Drawing 41N397-1. El
- North Valve Room Outline
{
i And Backfill Requirements
)
)
.I
v TVA EMPLOYEE CONCERNS REPORT NUMBER:
101C 0 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 25 0F 66 3.2.6 Low Volume Waste Holding Pond Dike Information Source Comments (Applicable Procedures.
OE Documents. Previous
- Applicable Reports. NSRS/QTC/ERT Section Investigation Reports Including revision or date) :
NSRS Investigation Report
- LVWHP Dike Construction Number In-85-088-002 Response to NSRS Investment :
LVWHP Dike Con,struction l
Number In-85-088-002 l
Dated July 23, 1985 Memorandum - NSPS to General:
- LVWHP Dite Construction Manater. " Response to Board:
]
Comment-WBNP-Request for Investment / Evaluation - QTC :
Concern Number In-85-088-00 :
(001 85-0806 050)
)
Memorandum R. J. Hent to LVWHP Dike - As - Constructed P. D. Herald. Dated Analysis Findings
)
September 12, 1985. "WBNP-LVW!!P Dike - Stability Memorandum - t,cting Site LVWHP Dike Investment D! rector to Project Manager:
Response Request
)
Dated November 19, 1985.
i
_ BNP - Employee Concerns l
W Number IN-85-088-002 Memorandum - WBNP Project LVWHP Dike Investment
_Manater to all M-Scheduled :
Employees WBNP OC. Dated
_pecember 13. 1985. "WBNP-1 DRG Inter.rity on BOP l
Features" (C2a 851213 012) :
l Memorandum - WBNP Site LVWHP Dike - Construction Director To Director of NSRS. Dated December 18.
1985. "WBNP-Response to Erployee Concern Investment :
Report I-85-088002" l
l l
l l
i I
R TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM
{
REVISION NUMBER:
2 PAGE 26 0F 66 Information Source Comments (Applicable Procedures.
j OE Documents, Previous
- Applicable Reports, NSRS/QTC/ERT Section Investigation Reports Including revision or date) :
Memorandum CEU WBNP to WBNP :
LVWHP Dike - Construction Files. Dated January 18.
1985. "WBNP-Non-0A Permanent:
Backfill /Earthfill Operations" Memorandum - WB Engineering :
LVWHP Dike - Construction Project. Project Manager to :
to WBNP Project Manager. OC.:
Date December 19.1985. "WBNP:
LVWHP Dike Stability" Memorandum - Director of LVWHP Dike - Evaluation NSRS to Acting Site Director:
Dated January 10, 1986.
" Corrective Action Response :
Evaluation"
_ Memorandum - Site Director LVWHP Dike - Investigation WBNP ONP to Project Manager *
Response
WBNP OC Dated February 11. :
1986. "WBNP-Employee Concerns IN-85-088-002" Memorandum - Project Manager:
LVWHP Dike - Analysis Watts Bar Engineering Project to Project Manager. :
WBNP Project. WB OC Dated :
February 25. 2986. "WBNP - :
LVWHP Dike-EmploJee Concerns Memorandum - G. Wadewitz, t
LVWHP Dike - Response Project Manager. WBN-OC. to :
to Investigation NSRS W. T. Cottle. Site Director.:
WBN-ONP Dated February 27 1986. "WBN-Recuest for Investment / Evaluation" Drawing 10N255. RIO LVVHP Dike Construction Drawing 10W228-1. R1 LVWHP Dike Construction 10W228-2. R0
g.
TVA RMPLOYEE CONCERNS REPORT NUMBER: 10100
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SPECIAL PROGRAM
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REVISION NUMBER:
2 i
PAGE 27 0F 66 Information Source Comments (Applicable Procedures.
OE Documents, Previous
- Applicable Reports, NSRS/QTC/ERT Section Investigation Reports Including revision or date) :
Construction Work
- LVWHP Dike Construction Package C-199022 General Construction
- LVWHP Dike Construction Specifications G-9 R5 1
Memorandum - (Informal) C0C.:
Inspection in General I
WBNP to CEU WBNP. Dated Problems in Non-0A l
June 20.1985. "WBNP-Civil i
)
Ouality Control Inspection :
Non-0A Areas
)
Memorandum - (Informal) CEU.:
Response to COC WBNP to C0C. WBNP, Dated Ouestions j
July 24, 1985. "WBNP - Civil:
Quality control Inspection j
Non-0A Areas" i
Memorandum - (Informal) CEU.:
Revised Response to C0C WBNP to C0C. WBNP Dated Questions October 8. 1985. "WBNP -
Civil Quality Control I
Inspection-Non-0A Areas"
(
Drawing 15W810-11. RIO
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 28 0F 66
4.0 Findings
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I 4.1 Barrier Trenches 4.1.1 Site Specific Discussion Design Function The designed purpose of the Underground Barriers is to prevent the lateral flow of soils should an earthquake occur that could liquefy some of the soils below the ERCW piping and 1E conduits. The Underground Barriers do not keep the soil from liquefying, but are intended to contain the liquefiable soil. The Underground Barriers are located between the safety-related piping and conduits, and the area towards which the soil would attempt to flow should the soils liquefy. The Unocr&round Barrier resulted from an extensive and conservative analysis of soil liquefaction that is presented in the WBN FSAR, Section 2.5.4.8.
The Barrier Trench was then incorporated on ECN 3960 and constructed according to drawings 10N213-1 and 10N213-2, " Underground
. Barriers for Potential Soil Liquefaction."
Concern:
Backfill Material Backfill Material: The areas of concern were that (1) 1075-crushed stone granular material was used instead of compactible clay because of schedule and weather conditions, and the material was unacceptable for structural fill; (2) unauthorized or uncertified material was used; and (3) material was used before necessary tests and approvals obtained.
Response
DNE/DNC response to NSRS to Investigation Report IN-85-442-X13, dated March 13, 1986, addressed the issue of 1075-crushed stone granular material use. The results of this ECTG evaluation concurs with the DNE/DNC response, and statements from that report are repeated here to give a consolidated finding.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 29 0F 66 i
1 1
1075-crushed stone fill material was used extensively in l
Barrier Trench B.
Its use was based on the three valid I
reasons listed below, and arranged in order of priority as to the importance of reasons:
l The Trench B was excavated to a greater depth at the south 1
end, than the exploratory borings had indicated prior to start of work. Stability analysis performed at the time the excavation was open, by DNE engineers, indicated a need for a higher shear strongth for the backfill material or to make the trench wider. The option of using 1075-crushed stone with higher shear strength properties in lieu of Al-earthfill j
was selected. The use of the 1075-crushed stone met the l
bisher shear strength requirements and provided the-additional stability needed for actual field conditions.
The site engineers were concerned with the available quantity of A1/earthfill, since the trenches were so large. Locating l
a new borrow area would have required more testing and delays.
l The Barrier Trench B had to be completed prior to fuel load.
l This required the placing of backfill through the winter i
season. The use of 1075-and 1032-crushed stone definitely solved that problem. However, if the material had not met the requirements some other option would have been explored.
l j
The use of 1075-crushed stone (equivalent to ASTM D448, size i
- 56) was an option available to construction as proscribed in the design documents and construction drawings.
It's use was analyzed and documented in the TVA design report on the l
"as-built configuration of the underground barrier at WBN" submitted to the NRC dated January 16, 1985. The analysis documented that 1075-crushed stone was used extensively and that all potential failure planes were evaluated on all cross-sections. The cross-sections submitted in the TVA design report were those sections that had the lewest factor-of-safety, as a result of the analysis of potential failure planes, and also, representative of the backfill materials used in both trenches.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 30 0F 66 The drawing (10N213-2) 6efined the materials and placement requirements that applied to the use of 1075-crushed stone.
Earthfill Note-1 specified the placement and acceptance critaria for the 1075-crushed stone.
Earthfill Note-4C specified that 1075-crushed stone could be us6d.
Unauthorized or uncertified material was never used in the Barrier Trenches.
Inspectors were present at all times during backfill placement. The earthfill used came from designated borrow areas as specified in Note-2 and -6B on Drawing 10N213-2.
Granular material, both 1032-and 1075-crushed stone, came from a qualified offsite source.
Records are on file documenting that all materials used were certified, and backfill placement materials were constantly monitored according to VBN QCP 2.01, WBN QCP 2.06, and General Construction Specification G-9 and 7-1.
Material was'never used befora necessary tests and approvals were obtained. The reasons cited above is documented proof that backfill was controlled properly. The Trench A and B excavation was started prior to completion of the laboratory i
soil strength test of the backfill soils. However, these tests were completed prior to fill placement having started I
in Trench A.
Memorandum, Office of Engineering (OE)/ Civil Engineering Branch (CEB) to CEB files, dated August 1, 1983, "VBN-Liquefaction Potential-Underground Barrier remedial treatment--status and observations based on field inspection"
)
(CEB 830801 020) discusses these strength test as being complete and the fill placement just getting started. The "as-built cross-sections" show all fill in Trench A parsed all required test, except those documented on NCR 5131.
The Robert L. Cloud Associates, Inc. Technical Evaluation and Response addressed this issue by answering TVA's first and second question presented to them as independent engineers.
The first question presented by TVA was as follows:
"Was the use of 1075-crushed stone for earthfill technically acceptable?"
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,b TVA EMPLOYEE CONCERNS
. REPORT NUMBER: 10100 SPECIAL PROGRAN REVISION NUMBER:
2 t
PAGE 31 0F 66 i
To evaluate.this question, it was necessary to determine the l
function of the barrier trench in which the crushed stone was placed.~ Additionally, it was necessary to determine the properties of the crushed stone,.the properties of the compacted earthfill which it replaced, and whether any other problems might have.resulted from differences between the 1075-crushed stone and a'coppacted earthfill. For example, one such difference is the porous nature of the crushed stonefill as compared to the relatively impervious compacted earthfill.
There are two underground barrier trenches designated Trench A and Trench B.
The purpose of these trenches is to provide' a stable structure which will~ confine the potentially 11guefiable material. lying in the generally northerly direction from Trench A and in the generally easterly direction from Trench B.
Confinement of this potentially liquefiable meterial is deemed necessary to assure the piping supported by the earth and running from the intake pump structure to the plant does not lose its support. More specifically, to assure that it is not dragged toward the river if the potentially liquefiable material should undergo a dynamic occurrence of sufficient magnitude to esuse liquefaction.
The specific area of concern with regard to the 1075-crushed stone is in the southerly end of Trench B.
An example of the use of 1075-crushed stone in this nres is shown on FSAR Figur'e 2.5-602, which is'a cross-section through Trench 8 at station 1 + 00.
The concern was derived from the fact that the original drawings for the' construction of the underground barrier trenches showed a bottom layer of 1075-crushed stone approximately 12" thick. However, the depth to bedrock for Trench B was greater than originally thought. There was also a potential problem with moisture control of earthfill, resulting from the increased precipitation during the fall and winter months, at which time this part of Trench B was being placed. Due to these conditions it was decided to use larger amounts of the 1075-crushed stone in the backfill of Trench B than had originally been intended.
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TVA EMPLOTEE CONCERNS REPORT NUMBER:
10100 SPEC 7AL PROGRAM REVISION NUMBER: 2 PAGE 32 0F 66 FSAR Figure 2.5-583 provided the information used in, and the results of, the calculations made to determine that the barrier trenches have sufficient strength to resist the potential liquefaction loads that.might occur under the specified seismic event. Therefore, the primary consideration in assessing the adequacy of the 1075-crushed
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stone in this structure must be ascertained by determining the capability of that crushed stone to develop the strength necessary to resist the loads imposed on it by the seismic occurrence. It was also useful to ascertain the strength of the 1075 material relative to the compacted earthfill 1
originally intended at the elevations above the originally designed 12-inch thickness of 1G75-crushed stone.
No testing had been performed on the 1075-crushed stone to determine its internal angle of friction. Hewever, as shown
)
in TVA's specification 7-1 Section 1075, the material shall be of crushed stone free of a variety of deleterious substances, shall have a maximum size of 1.5 inches, and shall have a minimum of fine material. Review of TVAfs specification T-1. Section 1032, shows the 1032-crushed stone has a very similar maximum size but includes approximately 50 percent of the material passinc through a number 4 sieve.as compared to five percent maximum for the 1075-crushed stone, i
Tectint was performed by the U.S. tirmy Corps of Engineers on three inch maximum size crushed limestone, similar to that used at the Watts Bar Nuclear. Station 'with a maximum of two percent pasting through a one inch square sieve.
Figures have been-prepared showing the shear stress capability of the materials mentioned'above with rerpect to the normal stress.
In keeping with the fact that generally larger aggregate of l
sharp contours, 6uch as.erushed stone generally have larger angles of internal friction, it appears consistent to use an internal friction angle (0) of 40 as is shown on FSAR-Figure 2.5-583.
Shear strength data for a wide ranSe of different rockfill d
materials with maximum particle sizes ranging from 3/4" to 8" are available. The lower bound foc the friction angle of the samples were approximately 40 degrees in the range of i
effective normal force of interest for WBN trenches. The majority of the friction angle values were between 45 and 50 1
degrees.
1
TVA EMPLOYEE CONCERNS RFPORT NUMBER: 10100 SPFCIAL PROGRAM REVISION NUMBER:
2 PAGE 33 0F 66 1
It was apparent the 1075-crushed stone is stronger than the l
compacted earthfill within the ranges.of effective normal l
force encountered at the depths of placement. Therefore, in terms of evaluating the strength of 1075-cruehed stone in replacing the compacted earthfill, the~use of this material I
was technically acceptable.
l The compacted earthfill originally intended near the bottom of Trench B is essentially impervious to water flow. To the contrary 1075-crushed stone is often used as a material j
where drainage is required. One element of concern resulting from the substitution of 1075-crushed stone could be whether l
the greatly increased permeability of the barrier trench l
compromised its ability to perform its confinement functica.
l For example, the question might be posed as to whether this type of material will preclude the transmission of liquefied sand should an occurrence happen to liquefy the sand layer adjacent to the coinpacted crushed stone. However, the cross-sections of Trench B show the design water level to be well above the sand layer and indeed, above the top of the crushed stone. This means the crushed stone layer is completely saturated and is not an oper. void which a liquefied material could flow into..Also, the downhill side of the 1075 is constrained by earthfill of little if any slope toward the river. Therefore, liquefaction of the material between the Barrier Trench B and the river would not result in a significant flow of material away from Trench B.
For this to happen it uculd be necessary for all of the liquefied materft1 on the uphill side of the barrier trench to displace the water from the barrier trench which in turn would have to displace material between the barrier trench and the river out of the way to permit flow. Such an i
occurrence does not Leem possible.
1 Therefore, it was concluded the use of 1075-crushed stone is acceptable from this aspect, also.
The above discussion was reviewed with Professor Seed of the University of California. He concurred with the general reasoning and the conclusion.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 34 0F 66 The second question posed by TVA was "Was TVA's use of a procedural specification for compaction control of the 1075-crushed stone technically acceptable?" RLCA interpreted this question to be "Is the compaction of the 1075-crushed stone through the use of a procedural specification, without subsequent confirming tests, technically acceptable?"
Therefore, no attempt has been made to evaluate the specific procedural specification.
In arriving at an answer to this question, it was necessary i
l to consider the types of tests that would be meaningful for i
the crushed stone earthfill and the significance, or lack l
thereof, on some of the testing that is performed on I
compacted earthfill. Compacted earthfill is tested for I
density and moisture content. The determination of moisture l
content is not meaningful for the 1075-crushed stonefill l
because of the absence of fines. That is, the moisture l
l content is critical for the earthfill above the 1075-crushed l
stone but not for the crushed stone itself.
1 Obtaining a sample for density measurements from compacted j
earthfill is relatively simple, it uses a small test sample 1
and disturbs a very minor portion of the earthfill.
l However, obtaining a density sample from a crushed stone such as the 1075 material, is much more difficult and requires a i
much larger sample. Consequently, it is likely that more of l
the consolidated crushed stonefill will be disturbed during obtaining the sample and it will be more difficult to replace the material that has been removed. Further, consolidation of crushed stonefill, which has been accomplished primarily by vibration, is less sensitive to the compaction procedure than is the case with a fine grain fill.
This lack of sensitivity to the compaction procedure for coarse filter material was illustrated by the compaction tests from Hartsville Nuclear Plant. These tests, which included the use of the same heavy vibrating roller used at Watts Bar, demonstrated that adequate relative densities are obtained after three passes over 12 inch loose lifts.
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TVA EMPLO7EE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 35 0F 66 The compaction procedure for the 1075 material at Watts Bar called for a minimum of six passes on maximum 10 inch lifts using heavy vibratory rollers. The inspection of the compaction was documented on a daily basis throughout the, duration of the backfill operation from September 1985 until July 1984. The daily inspection included information about lift heights, number of roller passes, amounts of backfill material and locations as well as weather conditions.
For reasons provided above, the use of a procedural specification for compaction control of the 1075-crushed stone was considered technically acceptable.
Concern: Fill Placement
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Fill Placement - The areas of concern were that improper backfill methods were used, resulting in lift limits being exceeded and compaction levels falling below requirements in
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Trenches A and B.
Response
4 The concern was not factual, except in a relatively few cases i
that were documented on NCRs as work progressed. The
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cognizant CQC inspettors stated that inspectors were always
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present during backfill operations, and lift thickness and compaction were rigorously controlled at all times in l
accordance with WBN QCP 2.01 and 2.06.
Daily Backfill I
Reports and fill compaction test data for earth and i
cohensionless materials are on file documenting that earthfill and 1032-crushed stone backfill was placed in i
specified lif t thicknesses and compacted, as required by Drawings 10N213-1 and -2.
The 1075-crushed stone was installed and inspected in accordance with Drawing 10N213-2, Note-1. This was a procedural compaction specification, which specified a particular type of compaction equipment, specified layer thickness, and number of passes of the compaction equipment. This was all that was required to place 1075-crushed stone and is a normal and accepted construction practice for placing coarse granular materials.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 36 0F 66 The NRC inspectors examined the records and observed the backfill operations in Trenches A and B on three different occasions, and on only one visit was a reportable condition identified. These inspections were documented on NRC Inspection Reports 50-390/83-14, 50-390/84-16, and 50-390/84-64. NCR 5131 was written and dispositioned to document the sites response to NRC finding of some test sampling deficiencies. NCR 6323, 6338, 5257, and 5804 were J
also written to document the few specification and/or procedural violations with regard to backfill operations in the Trenches. All these NCRs were dispositioned as nonsignificant and use-as-is. This was verification that the placement and inspection problems were documented.
Concern: Incorrect Construction Incorrect Construction The areas of concern were that (1) a
" gap" exists between the IPS and the Trench B backfill, where all the sand was not excavated resulting in a questionable structure and (2) CQC was told not to write an NCR on this condition. This concern is not acr te with regard to structural stability and the writin af the NCR. There was u
an area of fine sands left, but the area does not pose a threat to the structural integrity of the Barrier Trench-B.
Response
DNE/DNC response to NSRS Investigation Report IN-85-442-X13 dated March 13, 1986 addressed the issue of adequate cutoff.
1 The results of this ECTG evaluation concur with the DNE/DNC l
l response, and statements from that report are repeated to
)
l give a consolidated finding.
l i
The drawing (10N213-1 and -2), issued for construction, l
required an adequate cutoff. Based on a visual field inspection performed when the Barrier Trench was being excavated and other site conditions. DNE ruled the cutoff as adequate. The visual field inspection was performed by the l
DNE engineer responsible for the design of the Underground l
Barrier.
It is correct that for the Underground Barrier Trench B, some j
fine sands were intentionally left between the Barrier Trench 1
excavation nnd the formed the IPS excavation. In lieu of making a total cutoff and possibly undermining the I
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 37 0F 66 Category I sheet pile wall behind the IPS, the Barrier Trench excavation (cutoff) was extended to the extent evaluated and determined to be adequate. This adequacy was based on (a) l the geometrical relationship of the Trench-B excavation and backfill with the IPS. and intake channel excavation and backfill, and (b) on the f act that any loss of material from j
behind the Underground Barrier due to liquefaction must be J
preceded by movement of a massive amount of material on the flood plain into the river.
The geometrical relationship of the excavation and backfill limits of Trench-B, the IPS, and the intake channel are such that only a small zone of sand was left in place. The excavation limite for these three featcres overlap, ex' cept near the top of rock where the sand zone exists. The zone is estimated (based on construction 'hotographs and visual p
observation of the Trench excavation) to be approximately 3-to 4-feet high and 5-to 6-feet wide at the base or top of rock. This zone is probably from 100- to 125-feet in length in the area of concern. This zone also contains an indeterminate amount of nonliquetiable basal gravel. The 4
basal gravel is the material layer just above rock at the plant site and varies in thickness from 11 foot to 81 feet.
This material was not removed during the over excavation of the intake channel. In fact, the basal gravel provided the foundation for the earthfill that was placed to construct the intake channel slopes.
l The other site condition, that affected the engineer's
{
evaluation that the cutoff was adequate, was that a massive volume of material would have to be moved off the flood plain and into the river to create a void where the potentially liquefiable sands behind the Barrier could move.
The evaluation as to the adequacy of the cutoff was based on engineering judgment by licensed professional engineers, using the fact that an analysis had already been performed on i
the intake channel (FSAR Section 2.5.4.8 and 2.5.5.2.1) an1 l
corrective action accomplished, which formed a barrier between the river and the small aras in question of the cutoff trench. The CQC inspector involved at the time of the i
decision, whether to leave the material or not, stated that he felt at the time that the clay contact had really been reached, and that the amount of material estimated to have been left, according to DNE/DNC response, was greatly
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exaggerated and conservative to be on the safe side in their evaluation.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 38 0F 66 Both CQC inspectors interviewed, involved directly with the Trenches A and B. stated that they were never discouraged or told not to write an NCR on this aspect or any other aspect of the Trenches.
The Robert L. Cloud Associates. Inc. Technical Evaluation and Response addressed this issue by answering TVA's question to them as independent engineers.
The question asked of RLCA by TVA was:
"Are the judgments and justifications that serve as the basis for TVA's conclusion that an adequate cutoff exists between the IPS and Trench B reasonable?"
1 A small amount of in situ alluvial sand may have been left in l
place between the extreme southeast edge of trench B and the backfill for the IPS excavation. The possible presence of some remaining in-situ sand at this location was known and evaluated at the time of the excavation. The excavation was continued towards the IPS and intake channel slope as far as was considered safe without endangering the integrity of f
these structures.
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i The excavation limits for the IPS the intake channel and l
Trench B overlep such that only a small amount of sand could
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have been left in place. Based on the excavation limits, the
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sand wedge diminishes in size towards the southeastern tip of I
Trench E and is likely to end up in a total cut-off. The maximum width of the in situ sand at the critical section has been estimated to be approximately six feet, with a height of approximately four feet.
l Any in situ sand left in place at the critical junction l
between the excavations for the IPS the intake channel and I
for trench B has been subjected to drained consolidation from two sides during the construction of these three features.
The eastern side of the sand wedge was exposed during the excavation for the IPS and the intake channel. The sand then had the opportunity to consolidate and drain as a result of the existing overburden and the compaction of the backfill.
The western side of the sand wedge was exposed, drained and consolidated in the same way during the excavation for Trench B.
The western edge of the sand layer is in direct contact with the 1075-crushed stone backfill material, which would provide drainage paths to relieve any build-up of pore pressure in the sand during a seismic event. As a result, the remaining in situ sand is now highly unlikely to have the potential to liquefy.
s TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 39 0F 66 Under the most conservative scenario of assuming that the in situ sand layer could reach a state of liquefaction, there would be a narrow channel of liquefied sand providing a potential flow path between Trench B and the IPS for liquefied material located east of Trench B.
In order f or any flou to actually take place through this hypothetical
" channel," the Hyderstatic Pressure Differential, or " HEAD",
between points north and south of the cut-off would have to be sufficient to overcome the flow resistance provided by the residual strength of the liquefied sand. In the judgment of RLCA, the available pressure differential is clearly insufficient to sustain any flow material through this channel, even if the residual strength of the liquefied sand is conservatively assumed to be extremely low.
In summary, RLCA considers TVA's conclusion that an adequate cut-off exists between Trench B and the IPS to be reasonable and justifiable.
The above was reviewed with Professor Seed. He agreed with the generel reasoning and conclusion. Specifically, it was suggested that the effectiveness of the sand layer consolidation, as described, could be better understood by penetration testing.
I Conectn: Slope Deterioration Due to Erosion l
Slope Deterioration Due to Erosion - The area of concern was that there has been damage to the slope next to the IPS west side, Barrier Trench-B side, caused by either an artesian well or yard drainage pond seeping through slope.
Response: These concerns were factual with respect to a water source had opened a hole in the slope "sce, and caused l
some limited erosion. However, the flow of water from the I
seepage area had a negligible affect on the slope. There was l
an attempt to locate the source of the water flow originally. An investigator from TVA's Norris Lab dye tested the yard drainage holding pond, as well as other potential sources, but no definite source was identified.
The seepage site was examined in detail on the site visits made by Robert L. Cloud Associates both in June and July.
During the June visit, there was no seepage occurring; the l
site was slightly damp. On the July visit, a substantial l
seepage flow existed. There was no way to measure the flow at the time, but subsequently a flow of about 50 gpm was confirmed.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 40 0F 66 Robert L. Cloud Associates. Inc. Technical Evaluation and i
Response addressed this issue by answering TVA's question to them as independent engineers.
l The question asked of RLCA by TVA was:
- Was TVA's conclusion that the identified seepage had no 1
effect on the stability of the intake channel slope valid?"
+s The technical assessment of the reasons for the seepage are l
that it occurs whenever the water table in the permeable layers of the trench B fill rises higher than some threshold value. The water table is supplied and replenished by three i
potential sources:
l
- Natural ground water l
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_* The yard holding pond
- Leakage from a large drain pipe (Cooling Tower Blowdown) crossing trench B During the June visit, the drain pipe was not in use; the level of the holding pond was down; and drought conditions l
prevailed. Therefore, the water table was evidently below the threshold value for leakage. In the July visit the level of tha holding pond was much higher; the drainage line was in use for the preceding six weeks; and drought conditions still prevailed. Evidently the seepage threshold level of the water table in the trench was surpassed by replenishment from the last two sources, and the seepage re-initiated.
The general features, appearance, and overall arrangement of the seepage site appears to be little changed in the two year period since trench B was completed.
Evidently the seepage began shortly after the trench was completed in July of 1984 and has occurred intermittently since then. Photographs of the seepage flow taken in November 1984 show the site appearance is comparable to that of the present. Additional significant observations are that the seepage water runs clear as in a natural spring. The ditch the seepage water flows in is stable. In other words, the seepage is not washing or leaching any material, either sand or earth, out of trench B.
Neither is it causing further erosion of the earth surface, or if so, at least not at any significant nor even perceptible rate.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 l
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 41 0F 66
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An additional damp spot was observed on the south face of
,1 trench B in the July visit. The dampness was at about the same elevation as the soepage and approximately 20 feet distant. The seepage flow has eroded a small ditch on the south slope of the trench. This damage is essentially cosmetic. 'It has caused no shear failures nor otherwise affected the stability of the slope. Even if it were to cause such a failure it would of necessity be so limited in extent as to be inconsequential.
Erosion of the shallow surface covering on the south face of trench B will not affect the shear strength of the trench nor its ability to perform its design function of stabilizing the site against liquefaction.
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After the' initial site visit, the seepage issut, was discussed a
with Professor Seed and thereafter a recommendation was made I
to monitor the seepage. Following the July site visit, a
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l monitoring program was established and is in the procese of i
being implemented. Data is being collected on a daily basis, Monday through Friday, regarding the leni of the water j
table, level of the pond, flow in the large drain pipe crossing barrier trench B, seepage flow, and in general any t.hanges at the site. As sufficient data becomes available on the local hydrology of the barrier trench, it will be possible to determine the advisability of taking corrective l
action concerning the sewpage and to determine the appropriate action to take, if any. The monitoring program l
provides adeguate control of the situation for the present.
j DNE is going to initiate an ECN to repair the slope and control the seepage flow, after sufficient data has been collected for a viable solution to be forwalated.
i concern: Documentation and Miscellaneous
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NSRS Investigation Report IN-85-442-X13 Observations - The NSRS report presented several observations in Section VIII, page 51 through page 53 that were outside of the concern area that they felt were discrepancies in documentation and other miscellaneous items.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 42 0F 66
Response
The DNE/DNC rasponse, dated March 13, 1986, expressed their view on these observations. This ECTG evaluation concurs, with the DNE/DNC response, with the following additional l
information. The WBN FSAR changes and/or additions that were j
needed to resolve comments mede in the NSRS report have been submitted in memorandura, R. O. Barnett, Chief Civil engineer to J. A. Raulston, Chief Nuclear Engineer, dated March 27, 1986, "WBN FSAR Section 2.5 - Incorporation of Underground Barrier "as-built" Information" (B41 860327 018). The area of using " verbal instructions" to make changes, even though it was allowed according to notes on drawings, was researched through cognizant Engineering Assurance engineers to determine if there had been a condition contrary to the QA J
prograo requirement's. It was determined this practice was not a QA program breakdown. However DNE has recogrized that the practice of approving anything with" verbal approval" 1
without follow-up documentation needs to be discontinued.
I The process of establishing this policy has been initiated by l
memorandum, W. C. Drotleff, Director of Nuclear Engineering to Those listed, dated April 4, 1986, " Policy Memorandum:
Fonnal approval required for field change requests. (805 j
860404 003)
The observations of the NSRS Report and Respective ECTG/DNE/DNC Responsen are as follows:
Observation A.1 The L"BN Final Safety Analysis Report (FSAR) does not accurately describe the "as-built" condition of construction of the Category I Un6erground Barriers (Trenches A and B) for Potential Soil Liquefaction and the Class "A backfill around the Category I Intake Pumping Station (IPS) and associated sheet pile wall.
FSAR Figures 2.5-225 and 2.5-226a show " limits of class
'A' backfill" around the IPS and sheet pile wall. However, these
" limits" are not shown on design drawings issued for construction, and are not representative of the actual boundariec of installation of compacted backfill around the Category I structures.
I
m o.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 43 of 66 FSAR Sections 2.5.4 and 2.5.5, as applicable, describe features of the Underground Barriers for Potential Soil i
Liquefaction. HoNever, the FSAR does not identify the extent of use of granular material (such as 1075 and 1032 crushed stone) for backfill, does not identify the use of 1075 granular material in lieu of. class A or Al backfill, and does not cloerly identify 1075 material as being subject to or exempt from the construction controls described in FSAR Section 2.5.4.5.1.4.
Reeponse:
l The FSAR will be revised to include the "as-built" l
information and to clarify ot5at statements in the FSAR.
FSAR Figures 2.5-225 and 2.5-226a are drawings showing the excavation and backfill for Category I' features at the
]
plant. The drawings will be revised to show the actual excavation limits' for the IPS and sheet pile wall.
Observation A.2 General Construction Specifications G-9 and 7-1 do not I
specify and include appropriate quality standards and design requirements for installation, inspection, and testing of all i
- iaterir.19 used for Catetory I backfill at WBN.
General Construction Specifiestion G-9 is referei.ced in WBN project documantr. such as drawings, procedurer and instet.;. tion, for installation, inspr::tton and testing of granaler fill materials. However, Specification G-v does not j
taecify or include provisions for such materials. The Specification addresses rolled earthfill and.othea materials, principally for dam construction, and does not clearly L
j indicate tt.e applicability for power plant aarthwork.
J l
General Construction Specifications T-1 is also referenced in l
WBN project documents for granular materials, such as Section
)
1032 and Section 1075. However, Specification T-1 provides raaterial specifications only, and does not specify or include standards or requirements for the installation, inspection and testing of these materials for use as. power plant backfill.
J l
1
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 3
SPECIAL PROGRAN REVISION NUMBER:
2 4
PAGE 44 0F 66 No project construction specifications were found to have been i.ssued to specify and include appropriate quality standards and design requirements for granular backfill installation, inspection and testing at WBN.
Response
General Con 6truction Specifications G-9 and T-1 provide general instruction about earthfill or granular fill placement and control. Site specific requirements (dependent on the type of feature, design requirements, equipment available, etc.) are established by the engineer and placed on drawings or in specific construction specifications. For l
the WBN underground barrier these requirements were on drawing 10N213-1 and
-2.
l Observation A.3 Design Drawing 10N213-1 and 10N213-2, issued for construction of " Underground Barriers for Potential Soil Liquefaction,"
permit changes or deviations from design requirements and quality standards without identification, documentation, and control of such changes or deviations.
Drawing 10N213-1, " Note A1," and Drawing 10N?l3-2, "Earthfill Notes" 4(a) and 4(c) (3), permit the use of " verbal (oral) instructions" for activities within the scope of quality assurance. Personnel stated that such instructions were issued end implemented, and were not documented or otherwise identifiable or controlled.
Response
Verbal instructions were permitted by the drawings. Prior to excavation, a complete site investigation of subsurface conditions was not made. Construction excavation and backfill operations on this unique type of feature de not lend themselves to established acceptance criteria.
Engineering evaluation at the site was the most expedient method of getting the job done. The DNE engineer, respotisible for the feature design, made frequent site inspections to observe progress and to evaluate conditions as
]
they became visible. These types of engineering evaluations of in altu condition 3 do not lend themselves t'o predetermined notes on drawings or in construction specifications. Because
l TVA EMPLOYEE CONCERNS REPORT NUMBEP.: 10100 SPECIAL PROGRAM REVISION AUMBER: 2 l
PAGE
'.5 0F 66 l
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of the nature of these verbal instructions, and the additional information about site conditions, the stability analyses were frequently recalculated to confirm the stability of the underground barrier. At the completion of construction an analysis of the "as-built" conditions was made. This "as-built" analysis took into account the conditions that resulted from verbal instructions and unexpected site conditibns. The results of the analysis, taking into account these factors, showed the underground barrier was adeguate for its intended function. For the results of this analysis, refer to the analysis report (TVA l
l l
1etter to the NRC dated January 16, 1985 (L44 850116 809)).
The FSAR is also being revised to include the "as-built" analysis.
Observation A.4 The concrete gutter, located southwest of the Intake Pumping Station sheet pile wall, is not serving its intended I
function. The soil on the southwest side of the gutter has been eroded due to spillover of drainage from the discharge pipe at invert elevation 706. Refer to Drawings 10N234 and 10N215.
l l
Response
The eroded areas will be repaired when the ECN is issued to repair slope. Seeding after the repair should prevent l
recurrence.
l l
l Observation A.5 l
The upper slepes of the Intake Channel, above the riprap and southwest of Intake Pumping Station and concrete gutter, have l
l significant conditions of erosion. The erosion of soil is progressive and appears to be due to surface water runoff and lack of adequate slope protection. Refer the Drawing 10N215.
Response
See response to Observation A.4
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 46 0F 66 l
==
Conclusion:==
Barrier Trenches l
The concerns were not factual in all the areas with regard to the employee concerns about the quality of materials used.and I
the structural integrity of the Barrier Trenches. The I
material and methods used were performed according to drawir.gs and specifications, and inspected properly. There were no breakdowns.in QA, design,' and/or construction of the
'l Underground Barrier Trenches. There were some areas that needed clarification in the WBN FSAR, and these are in the process vf being corrected.
Robert L. Cloud Associates, Inc. made the following observation and' general conclusions.
The design and construction of the seismic barrier trenches near the Intake Pumping Station at WBN have been reviewed.
The results of our review are clear and unambiguous.
On an engineering basis, RLCA believes the underground barrier trenches.were undoubtedly improved by using crushed stone instead of the originally specified earthfill. The method of placing and compa'eting the crushed stone was appropriate to assure that the barrier performs the intended design function.
RLCA does not believe the seepage is a threat to the intake channel embankment stability, ner is it believed posstole that any unremoved sand at the foot of l
Trench b could compromise the function of the trench.
1 The above was reviewed with Professor H. Bolton Seed at the University of California at Berkeley. He concurred with the j
general conclusions.
)
I 4.2 Sink Hole l
4.2.1 Site Specific Discussion l
Concern: A large sink hole had been formed in the earthfill on the east side of the Turbine Building (TB), and the j
necessary corrective actions to identify the cause and a i
proper solution had not been performed by construction forces.
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T1fA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 47 0F 66
Response
Some construction trailers had been located on an area south of the existing south condensate storage tank on the east.
tide of Turbine Building at approximate elevation 727.
The l
1 trailers were removed, a large wet hole was discovered.
Site civil engineering investigated the sinkhole to determine the extent and source. A largs hole approximately 15-feet deep was excavated to naar the bottom of the abandoned unit-2 l
ringer crane foundation, where a cavity of approximately 24-inches in diameter was discovered running north back under i
l crane fcundation. The. cavity was filled with water that appeared to be oily an! foamy, which indicated a leak in an air line. Construction personnel opened and closed the valve to a nearby eight-inch diameter construction air line. The water in the cavity rose and fell when pressurized with operation of valve. The air line was plugged and abandoned.
The water was pumped out and no more drained back into the j
cavity. The cavity was excavated to a point at the bottom of i
l the foundation where it narrowed to eight-to-ten inches in I
diameter. It was evaluated in consultation with OE, and
)
decided that the expense and effort to dig further was not j
necessary. The cavity was backfilled with compacted l
1032-crushed stone knd filled to existing grade.
l The hole has been backfilled and there has been no visible reoccurrence of the bole or wet spot.
I The civil-QC personnel were involved in the decision to backfill the hole, and monitored the backfill operation.
l The Backfill Daily Reports, Sheets - 040 through 046 dated j
April 29, 1985 through May 9, 1985, are on file and document
]
I that the material was qualified, inspected for proper placement, and passed all compaction test.
Drawing (10N210 Revision 28) has the ringer crane foundation and the existence of the cavity noted.
The ECTG evaluation concurs with DNC response to Employee Concern IN-85-442-X11 that the hole was investigated, problem i
source identified and corrective action taken.
The work was performed to existing specifications and procedures.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 48 0F 66
==
Conclusion:==
Sink Hole The concern was factual in that a sink hole or wet area was formed. However, the sink hole was excavated to a reasonable reduction point, the source was identified and eliminated, j
the hole was backfilled using qualified material and j
documented on drawing.
l 4.3 Blowdown Lines Backfill l
l 4.3.1 Site Specific l
l l
Discussion l
l l
l Concern: That the cooling tower blowdown pipes are leaking l
so badly, due to improper installation (improper backfill),
i l
that erosion below pipe will cause collapse of the pipe and the seismic barrier may be eroded. Also that the pipeline was reworked because of improper backfill and a CCN had to be i
issued because inspectors would not take verbal directions l
from engineering on the type of fill to be used.
l
Response
(
l The cooling tower blowdown pipes were designed as a 66-inch
(
corrugated metal pipe (CMP) with a 48-inch fiberglass liner with grout between the outer CMP and liner. The 66-inch CMP was originally installed in 1976. The 48-inch fiberglass liner was installed within the 66-inch CMP in 1978. The backfill of the 66-inch CMP was inspected and documented in i
accordance with WBN QCP-2.01 and QCP-2.06.
Due to continuous l
wet areas in the field, south of the 35-acre holding pond, an l
inspection of the cooling tower blowdown line was conducted I
of the internal 48-inch fiberglass liner. The inspection revealed numerous problems with the liner that were responsible for the leaks, and none of the problems were l
caused by the bactfill operations of the original pipeline.
The fiberglass liner damage was guite extensive in the areas of the original inspection-opening patch joir.ts and support braces that had broken through the liner wall. The damage resulted from how the pipe had been installed, aligned, and I
grouted within the 66-inch CMP, not by the backfill placement of the original 66-inch CMP. The pipe between the cooling tower weir box at approximately elevation 701 to the pipe-tee was repaired by patching the existing fiber 61 ass pipe. This
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 49 0F 66 repair procedure did not stop che leaks totally, but reduced the leakage of water to an acceptable amount to satisfy DNE.
The pipeline was never designed to be completely watertight.
The leg of the pipe between the Tee and Holding Pond was not considered to be repairable due to extensive damage. The section of pipe between the existing access manhole (M. H.)
and tee of the holding pond leg was completely replaced using
'a 48-inch Class III concrete pipe in accordance with CCN-C47 in 1985. The backfill material below the blowdown line is granular material which will allow for any small amount of l
water leaking to drain to the south slope of the excavated area. Documentation raviewed demonstrated that the material i
l used, met or exceeded test requirement.
lR2 The original backfill material was placed, inspected, and documented in accordance to WBN QCP-2.01 and QCP-2.06.
The-backfill around the reworked section of the blowdown pipe was installed in accordance with CCN-C47. The CCN-C47. Revision 0 was originally written to change the routing of the pipe and to change the type of pipe. However, CCN-C47 Revision 1 and 3 was written to clarity backfill requirements ar9und the 48-inch concrete pipe due to CQC inspectors reluctance to work from verbal instructions.
The inspection of the blowdown pipe route did not produce any l
visual wet areas or indications of a return of the leakage j
problem in the repaired / replaced areas. There was evidence of a source of previous water seepage through the slope on the south side of Barrier Trench B.
However, there was no water seepage on the inspection tour and the engineers stated that i
there had not been any seepage since the blowdown lines had been repaired.
1 There was some water seepage on a later inspection visit to the Barrier Trench B in July, 1986 at the barrier trench and j
3ower river end of blowdown lines. This is addressed in this Subcategory Report - Barrier Trench Section 4.1 Slope Deterioration Due to Erosion.
The Sh,wdown Pipe Leakage issue is a.lso addressed in l
Construction Subcategory 17100-Mechanical, Sectioh 4.5 i
Pipe / Fittings. The area between the pipe-tte and the I
river is going to be replaced. The 66-inch fiberglass pipe l
downstreSN of the tee leading to the river, presently is being replaced with 72-inch concrete pipe,under ECN 6455 (delivery
.nf materials has started). The presently installed 48-inch i
fiberglass pipe from the cooling tower to the tee is under i
observation. This corrective action is being tracked for i
WBN-ECTG on CATD 17105-WBN-01.
l'.
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 50 0F 66 1
Conclusion q
The concerns were generally factual in that a bad leakage problem did exist prior to 1985; that a potential erosion-f problem did exist; and that a CCN was revised to eliminate verbal instructions to inspectors. However, the leakage problem was not caused by improper backfill material or
{
methods 'of backfill placement; the pipes have been repaired, l
eliminating the extrerte leakage and erosion potential; CQC L
was justified in regnesting documentation of backfill
]
requirements; and other tress of pipe is presently being replaced.
4.4 ERCW Pipelines Backfill 4.4.1 Site Specific Discussion 1
Concern:
Improper backfill methods (uncontrollert dumping) q were used during original installation of the ERCW pipicg, j
resulting it the 30-inch diameter pipes having excessive j
stfess placed on them.
l
Response
i The four 30-inch diameter ERCW pipes and two 12-inch diameter i
HPFP pipes were placed 8.0 feet on centers, in a une.inuoue trench, from the IPS to the Aurillary Building (AB), and buried with Type a earthfill or limestone rend (ASTM C 3l) beckfill. The buried pipes were bedded in e manner that l
provid&d a cortinuous and uniform bearing between the bottom cf trench and the bottom quadrant of the Pipe for its full length. The pipe generally was to have had a minimum c0ver of 2-feet 6-inches below finished grade, and a minimum depth of 6-inches beneath the bottom of the pipe. The backfill was to have been placed in 6-inch loose layers and compacted.
The backfill material on either side of the pipe, was to be equal to or less than a 6-inch maximum variation, compacted
]
by a Buff alo-Boisag BV60-S Vibrating Compactor. The material 1
was to have been compacted in this manner to at least i
8-inches of compacted fill above the pipe. The Type A or
)
limestone sand backfill was then to be placed in 6-inch loose layers, and each layer ecmpeted using a Raygo 4000-A Vibrating Compactor until at least 12-inches,of fill was abore thc top of the pipe. The Type A earthfill was to be k
TVA EMPLOYEE CONCERNS REPORT NUMBER: 101'00 SPECIAL PROGRAM REVISION NUMBER: 2 I
PAGE 51 0F 66 i
compacted te i t least 95 percent standard, mar dry density 1
with a moirts a.antent of 1 3 percent of optimum. The limestone sac was to be compacted to at least 70 percent l
relative density with an average relatfre dunsity of 75 percent.
These were the requirements existirg at the time of the original backfill of the ERCW pipelines installation. The work being done in accordance with these requirements would not have produced excessive stresses in the pipes.
WBN CQC inspectors were always present during backfill placement, since this was a Category-I seismic pipe, and all specifications, procedures, and documentation requirements were complied with. Three of the inspectors that actually performed the inspections were interviewed, and they could not identify any problems or deviations from specifications and/or drawings. These inspectors seemed very knowledgeable of the work that went on, nearly nine years ago. They knew the details of the work vers well.
Random Backfill Daily Reports for the Type A.earthfill between August 24, 1976 and August 22, 1978 verified the material used was from approved borrow areas, material was placed in specified lift thicknesses, compacted with i
specified equipment, and met the specified compaction criteria.
Random fill compaction test data reports between September 27, 1977 and July 6, 1974 verified that the liR9 stone sand used came from a qualified source, the sand was placed in specified lift thicknesses. compacted with equipment, and compaction criteria was met.
7he records are on file and document that material was qualified, inspected for proper placement, and passed all compaction test.
Inplace Material Compaction Test Reports 701, 702, 880, 025 and 926 verify that test were run on potential " soft" areas of the subgrade, and the areas met the compaction limit.
s TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 52 0F 66 WBN FSAR section 2.5.4.8 gave the analysis performed on the ERCW piping for potential settlement due to soil liquefaction. There were borings taken all along the pipeline and analyzed. This analysis confirmed the foundation of the pipeline was adequate.
The WBN FSAR section 3.7.3.12 gave the criteria used for analyzing the buried ERCW piping.
The analysis was based on the fact that the backfill material was placed te standards that insure suitable bearing conditions. Therefore, the transition from one material to another, i.e., in situ soil to backfill j
should not be a problem. The analysic confirmed that if the l
backfill was placed as specified, the stress levels of the l
piping would be below the ASME Code allowable for settlement j
itiduced loads.
)
l NSRS Investigation Report Number I-85-598-WBN revealed that personnel, which performed investigations of mortar lining, witnessed the misalignment that occurred when ERCW pipes were 1
cut. However, the NSRS could not determine that the original 1
backfill was the cause of the piping misalignment.
)
WBN civil engineers were responsible.for the lay-out of the trench excavation and pipe alignment. They were not involved in the installation, nor the actual backfilling operation.
The civil engineers involved did not observe any incorrect i
placement of backfill.
Two mechanical engineers responsible for the ERCW pipeline concrete lining installation, cutting pipes, and reinstalling the pipe sections had no knowledge of extreme distortion of the pipe after cuttint out sections. They stated there were 3
some fit-up problems, due to ovalit'y of rew pipe sections not matching with buried pipe sections, but nothing out of th6 ordinary for 30-inch diameter pipe. The fit-up did not l
require excessive force to correct problem.
Two WBN CQC inspectors, of the four responsible for inspection of concrete liner installation, stated they saw no evidence of extreme distortion. One inspector had heard rumors of the large fit-up problems, but had no first-hand knowledge. The other two inspectors no longer work for TVA and were not available.
The TROI list did not have any NCRs that were written againtt the ERCW pipeline backfill, and CQC unit had no records of any.
-~,,
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM l
REVISION NUMBER: 2 PAGE 53 0F 66
)
l Conclusion The concern was not factual with regard to improper backfill methods used, and thus causing excessive stresses or. the ERCW pipes. The backfill was installed, inspected, and documented in accordance with drawings, specifications and procedures. The correct method of backfill placement did not cause excessive stresses.
The analysis performed on the ERCW pipelines which showed i
stress levels below the ASME Code allowable for settlement i
induced loads, deduced backfill was placed to standards that ensured suitcble bearing conditions.
4.5 North Valve Room Backfill 4.5.1 Site Specific Discussion Concern: WBN personnel used improper and uncertified I
material, and placed the material in two or three foot Iffts.
resulting in material not meeting compaction levels.
Response
l The drawing (41N397-1. Revision 1) showed the concrete outline of north valve room foundation. Notes-6 and -7 on I
the drawing gave the backfill instructions and criteria for l
the foundation. Note-6 stated that "for backfilling around 4
the walls in the north-south direction, the difference in l
elevation of backfill on opposite sides of the walls shall
]
not be greater than 15 feet."
Note-7 stated that " backfill i
for the area enclosed by the shield building and the l
foundation walls shall be noncompacted crushed stone
{
l conformint. to sectibn 1032 of specification number T-1."
j This required that 1032-crushed stone from a qualified I
offsite source be placed with no lift restrictions, except the balancing of opposite sideo of walls, and no inspection test be performed since the designer did not want the material compacted.
The CQC inspectors confirmed that the 1032-crushed stone atterial was installed according to the drawing, and that it came from a qualified offsite materials source. They observed the material being placed, and performed no compsetion test.
l 1
l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 54 0F 66 The Backfill Daily Reports, January 24, 1975 through March 27, 1975, confirm:d that qualified 1032-crushed stone I
was placed and inspectors were present during werk.
Coriclu si on_1 North Valve Room Backfill The concerns were not factual.
The specified material was placed in 3ccordance with the drawings and specifications.
4.6 Low Volume Waste Holding Pond Dike 4.6.1 Site Specific Discussion Concern: The construction craft personnel ignored CQC i
inspectors inst! ructions for backfilling operations and worked with site and/or DNE engineers to obtain approval to deviate from drawings and specifications. They were concerned that this would jeopardize the structural integrity of the dike and also establish bad policy.
Response
The low volume waste holding pond dike was constructed on the I
west end of the 3L-acro yard drainage holding pond to
)
consolidate several individual waste discharges into a single 2
discharge point. The dike is approximately 201 feet high,
)
constructed of earth backfill material from sources j
established by the field in coordination with DNE-CEB. The I
dike construction work was to be done in accordance with Ceneral Construction Specification G-9, except as noted.
according to Note-A on Drawing 10W228-1, the initial fill l
material was to be placed underwater, then once a foundation l
had been established the remaining fill was to have been placed using 6-to 8-passes per 9-inch loore lifts.
Riprap was to have been placed on both slope faces. The dite was to be a non-QA permanent backfill structure.
The NSRS Investigation Report IN-85-088-002 substantiated the concern on several points which included:
- QC was overruled on G-9 specification implementation.
- QC was overruled on quality of backfill.
. O.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 55 0F 66
- QC was not contacted to begin inspection at proper time.
- Quality status of dike is indeterminate due to amount of organic materials possibly used in dike.
l
- Quality status of dite is indeterminate due to amount of bridging.
l How3ver, DNE has analyzed the dike from a very conservative, worse case, as-built condition on two separate occasions.
(September 12, 1985 and February 25, 1986), using different analysis parameters. The stability analysis of the dike showed an adequate factor of safety. The resultant factor of l
safety was 1.9 for the most critical section, as compared l
with the recommended minimum Safety Factor of 1.5, as given l
in Civil Design Guide C1.4.2.
These analysis are presented l
In memorandums - Project Manager Watts Bar Engineering I
Project to Project Manager, WBN Project, WBN OC, dated i
February 25, 1986, "WBN - LVWHP Dike - Employee Concerns" and Project Manager, WBN Engineering Project to Project Manager, j
WBN OC, dated December 19, 1985 "WBN - LVWHP Dike Stability."
l l
DNC has responded to the NSRS investigation on three different occasions. This evaluation concurs with the DNE's l
analysis of the as-built dike stability, and DNC's responses j
to the Employee Concern IN-85-088-002 with regard to other systems or structures. However, there will be corrective action with regard to a note on drawing concerning dike.
DNC stated on their response to the NSRS investigation that "during the investigation of this concern, several engineering and QC units were contacted to determine if there existed similar situations in disciplines other than civil.
From the evaluation, no potential for a similar problem exists in other Balance of Plant (BOP) systems cr structures. Iterefore, since no other issues were identified, no corrective action is required at this time.
If in the future a problem is identified, then thst problem will be evaluated and corrective actions will be t:aken."
The organizational and attitude issues are a result of partial inspections by QC personnel in a non-QA area. This happens on rare occasions, and better coordination will be done in the future to ensure that work is performed in strict adherence to drawings and specifications. A policy memorandum from Guenter Wadewitz to all WBN Construction
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE $6 0F 66 Supervisors was issued December 13, 1985, on the subject of drawiig integrity of BOP features.
This memorandum reaffirmed TVA's policy that DNE issued drawings will govern at all times. By following the policy as set forth, the.
potential for similar problems will be negated.
The cognizant civil engineers felt they had a little more latitude with regard to the dike construction, because they knew the intended purpose of the dike, the notes on the drawings, and the dike being non-QA. They did not feel at the time that CQC was being overruled. The inspection start point and inspection points were established in Work Package C199022 and in a prework meeting. There were several discussions held at various points during the construction of the dite between DNC, DNE, and CQC personnel and there was i
verbal agreement on steps to be taken to continue construction. The backfill below water level is indeterminate, since no one observed the actual dumping at all times. However, no engineers or CQC personnel saw any signs of large stumps or organic material going into dike.
The first time the material was dumped into the dike area, the CQC supervisor interpreted the fill as being above the point that they were designated to start inspecting, which l
was at the 1-foot above water level. However, it was i
explained that the material had to be spread out and compacted. He concurred and CQC started inspecting at 1-foot above water level as planned. A conduit trench was dug through the length of dike at a later date, and it was l
inspected for organic material by several engineering I
personnel and none were found. This trench was above water j
level though, and this was the material inspected by CQC.
I The cognizant DNE engineer felt that all the material should have been inspected and the general requirements of G-9 should have been adhered to, with the exceptions of material 4
compaction, type material and testing. The DNE engineer
]
visited the site and defined the term " deformation" as being 2-3 inches, and issued other guidelines with regard to the state of the dike backfill during the site visits by " verbal" instructions. These verbal instructions were usually issued to all parties in a group discussion. The DNE engineer felt the day to day directions for the dike construction was the
)
site engineer's responsibility. The DNE Engineer stated that neither construction superintendents nor craftsmen attempted to bypass site engineers by going thru DNE at any time.
1 l
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i TVA EMPLOYEE CONCERNS REPORT N0LdER:
10100 REVISION NUMBER: 2 PAGE 57 0F 66 I
l Cognizant CQC personnel felt the problems with construction
)
of the dike were the " verbal" instructions with no follow-up q
documentation. They never questioned the engineers authority I
or responsibility to make decisions about the dike construction. However, when conflicts or questionable areas came up involving the drawings or specifications, they were not supplied with the documentation that was necessary to answer the inspectors questions even though the dike was non-QA.
CQC personnel were never confident that they were always notified that backfill was being placed, as was required by TVA General Construction Specification G-9.
CQC supervision initiated discussions and memorandums to get the questionable areas clarified between them and site engineering. The clarifications were obtained after the construction of the dike was completed. However, as a result of the policies that came out of those discussions, the problems and/or misunderstandings will not happen again.
WBN DNC has established several policy clarifications since l
the low volume waste pond dite was constructed. This has improved the organizational and attitude issues with regard to non-QA related work. The memorandum - Project Manager.
WBN OC to All M-senedule Employees, WBN OC, dated December 13, 1985, "WBN - Draying Integrity on BOP Features" reaffirms and clarifies project policy, that no feature will be constructed in violation of irsued drawings and specifications and all deviations will be documented. The I
inforn21 memorandum to WBN files - Supervisor, CEU, WBN OC to WBN Files, dated September 4,1985 clarified the type of backfill to be used on WBN.
The issuance and implementation of Work Control Procedure QCP 1.60, Revision 0 will also aid in preventing a recurrence of any disputes between CQC and site engineering. The work and inspection criteria has to be documented by a work plan prior to any work being performed.
Conclusion The concern was generally factual with regard to craft personnel getting approval from site engineers to continue earthfill operations after CQC inspectors had put them on hold. However, the approvals by the site engineers were based on their interpretations of the drawings and/or specifications considering the purpose of the dike and the j
l i
i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 58 0F 66 non-QA type work that was being performed, which was the engineer's responsibility. Site engineers should have provided for better inspection initially, and drawing and/or specification interpretations should have been followed-up by documentation. The documentation was provided long after the dike was completed.
The two questions raised by this concern have been addressed by the following actions:
The dike has been analyzed and accepted for its designed purpose in the as-built condition by DNE. However, a note should be put on drawing 10W228-1 stating that "the LVWHP dike will not be used for any other purpose without prior approval from DNE due to indeterminate foundation material for the dike."
The WBN Project policy clarification with regard to non-QA work and organization changes that have taken place at WBN since dike construction will prevent a recurrence of similar problems on any other part of the project.
4.7 General Concerns 4.7.1 Site Specific Concern:
(1) Bad backfill practices were encouraged and were not fully or adequately documented.
Concern:
(2) Craft superintendents ordered craft personnel to intentionally bypars QA inspection holdpoints relating to backfill operation. This caused significant amounts of rework.
Concern:
(3) Craft personnel refuse to remove adequate backfill to permit a representative compaction test, when inspectors suspect improper backfill preparation.
==
Conclusion:==
In evaluating the other sixteen employee concerns, there was no evidence as to validity of these three concerns occurring as a general practice. Therefore, three concerns are not factual. The documentation and evaluations researched on the other issues covered such broad areas, both QA and non-QA, that sufficient evidence exists to substantiate that no programmatic problems existed within material placement areas.
=
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 59 0F 66 4.8 Dry Active Waste (DAW) Building - (SQN) 4.8.1 Site Specific Concern: The area of concern was that SQN DAW Building j
foundation was being constructed on unsuitable backfill material, that could result in uneven settlement of the building. This was a SQN site-specific concern.
Response
The area that the DAW Building was to be built on had been previously built up, using waste backfill material, during the early stages of the plant construction. The material was random backfill and not compacted. The area was originally intended as a storage yttd, and controlled fill was not considered necessary. The DAW Building was non-QA. The material was not inspected at the time of the original i
backfill placement, because there was no requirement or need.
The concern was evaluated at the site on January 21, 1986, by cognizant engineers from SQN Modifications Unit. DNC Nuclear Services Branch (NSB), and DNE Civil Engineering Branch (CEB). The decision was made that the existing material needed to be remore'd prior to constructing the foundation of the building, and backfilled with 1032-crushed stone material. The material was to be removed and areas excavated 1
to approximately 12 to 18 inches below in situ soil for all column footings, grade beams, and under the compactor area of I
the DAW Building. The work was performed by the DNC NSB Unit. The areas were actually over excavated beyond the original guidelines. The foundation area was backfilled with compacted 1032-crushed stone in 4-inch layers to the required elevation, before placing the concrete building foundation.
The material was inspected randomly by cognizant engineers froh. DNC NSB Unit, not QC-Inspectors, and no documentation was recorded, since the DAW Building was non-QA.
The concerned individual had been contacted by the SQN Modifications Unit supervisor in charge of the DAW Building construction, and he was satisfied with the corrective action taken. This fact was revealed by SQN Modifications Unit supervisor and was documented in his note to flie, on his inyestigstion.
1 I
1
=
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM-REVISION NUMBER: 2 PAGE 60 0F 66 The memorandum referenced in 3.2.8(B25 86020s 020),
summcrized the January 22, 1986 site meeting to discuss the DAW Duilding backfill material conc 6rn and appropriate course of action. The conclusions of the site inspection were that:
1.
The random fill was not an acceptable foundation for the footings.
2.
An overezcavation of approximately 3-feet would reach in situ soils.
l 1
The corrective action recommendations made as a result of findings were:
1.
Over excavate the footin6s to the buff-colored in situ soils. Rep, lace the excavated material with 1032-crushed stone in approximate 4-inch liftt and compact with approximately 10 passes of the Bomag roller or power l
tampers (in footings).
2.
Advise IMPELL (the building designer) of the problem w*th the random fill.
The IMPELL design drawings C-01 and M-01 for the DAW Building were reviewed.
It called for building to be non-QA and did not. call for anything special with regard to foundation materiel requirements.
Conclusion l
The concern was valid with regard to unsultable backfill material. However, the situation has been corrected to the concerned individual's satisfaction by removal of the material j
l beneath the DAW Building and backfilling with compacted 1032-crushed stone.
5.0 COLLECTIVE SIGNIFICANCE The soils issues introduced no programmatic problems, and only two site i
specific NON-QA Problems. The materials were correctly used, placed, and l
documented in accordance with drawings, specifications, and procedures to I
saticfy the structures design function in all cases. The plants ability I
l to perform their design function safely have not been compromised by any of the soils issues. Overall, management and employees did a creditable job within the soils issues areas. There were some minor non-QA ares l
breakdowns, but nothing significant.
i l
l
g-TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 61 0F 66 5.1 Significance of Each Issue 5.1.1 Barrier Trenches:
DNE/DNC responses to NSRS investigative report
- IN-85-442-X13 provided adequate assurance as to the reliability of the barrier trenches.
Robert L. Cloud Associates, Inc. was retained to do an independent engineering review of the barrier trenches installation. The Cloud report concurred with the DNE/DNC i
and ECTG responses.
l Profes.or H. Bolton Seed of the University of California l
reviewed the Cloud report and concurred with the report.
l WBN drawing 10N213-2 provided for 2075 crushed stone requirements as an alternate source selection.
I Trenches will not be compromised, structurally or l
functionally by documented seepage and erosion areas.
l l
The " Gap" that exists between Trench B and IPS was determined to provide an adequate cut-off that was reabonable and justifiable by both ECTG, DNE RCLA, INC, and Professor Seed.
l CEB 830801 020 addresses strength testing and that TVA had met required criteria with regard to the use of 1075 crushed stone.
l 5.1.2 Sink. Hole:
Site civil engineering evaluated the soils conditions and decided to excavate the area and backfill the area with compacted 1032-crush stone prior to the employees concerns.
Recurrence of the wet spot or cavity is non-existant.
5.1.3 Blowdown Lines Backfill:
Backfill operations were installed in accordance with procedural requirements.
CCN-C47. R1-R3. was written to clarify verbal direction to satisfy CQC reluctance to work from verbal instructions.
1
(
6
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 62 0F 66 I
q l
Leakage condition eristed but was not a result of backfill operations.
Piping was repaired and leakage subsided significantly.
5.1.4 ERCW Pipelines Backfill:
Soil borings taken satisfied the requirements of WBN FSAR Section 2.5.4.8 and 3.7.3.12.
l Records and documents on file verifies the proper i
material and soil placement was in accordance to drawings.
I specifications and procedures.
Analysis criteria in WBN FSAR Section 3.7.3.12 confirmed that backfill placed as specified produced stress levels on buried pipes below the ASME code allowable for settlement induced loads.
1 5.1.5 North Valve Room Backfill:
Documentation verifies proper material and soil placement.
5.1.6 Low Volume Waste Holding Pond Dike I
The LVWHP dike is not safety related and quality record-of the design and construction are not necessary.
QC was improperly utilized during dike backfill operations.
Engineers and supervisors were lax with rcgard to adherence to drawings and specifications on this non-QA dike.
l LVWHP Dike has indeterminate foundation matsrial.
Engineering (DNE) conducted two separate engineering evaluations of as-built worse case conditions with the results that the safety factor due to the oversize of the dike exceeds the 1.5 safety factor for the dikes purpose.
The calculations resulted in a 1.9 safety factor.
Management has issued directives to preclude the use of verbal instructions which are in conflict with engineering drawing and/or specifications.
5.1.7 General Concerns None l
e.
w TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 63 0F 66 5.1.8 Dry Active Waste (DAV) Buildittr. - (SON)
The decision was made that the material needed to be removed l
prior to building the foundation of the building, and backfilled with 1032-crush stone material.
6.0 CAUSE 6.1 Barrier Trenches:
Groundwater table fluctuations in the permeable layers of trench resulted' in slope seepage.
WBN FSAR not incorporating "as-built" conditions of trench expeditiously due lack of coordination between DNE and licensing group.
6.2 Sink Hole Leaking Air Line 6.3 Blowdown Lines Backfill None - Soil backfill placement had no impact to blowdown pipe problems, so no direct cause was assigned to this issue. The pipe repair / replacement resulted from pipe installation process, completely seperate from soil placement.
6.4 ERCW Pipelines Backfill None 6.5 North Valve P.oom Backfill None 6.6 Low Volume Waste Holding Pond Dike j
Site engineering was inconsistent in controlling backfill activity i
operations in regard to established procedures, for this specific l
non-QA Dike.
6.7 General None 6.8 Dry Active Waste (DAW) Building - (SQN) l The specifications and/cr drawir.gs failed to initially define the foundation requirements.
1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 64 0F 66 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken or Planned 7.1.1 Barrier Trenches DNE-CEB is to issue an ECN to excavate the seepage point area and cosmetically repair slope damage on southwest side of j
Intake Pumping Station.
(CATD 10100-WBN-01) j Line management response was:
A program has been established (WBEP-WP-5) to monitor the leakage. Besides the leakage flow, several other water levels and observations in that area of the plant are being made.
I The initial results show a direct relationship between the flow l
rate and the pool level in the yard pond.
Due to the above relationship, the repair of the leakage area will require an expanded leakage monitoring program to resolve any post construction monitoring program to resolve the leakage sources (s), facilitate repairs, and resolve any post i
construction monitoring and reporting requirements. The expanded program will include the following steps:
(1) Yard Pond Leakage Testing and Repair (2) CCW Blowdown Potential Leakage Testing (3) Repair of Leakage Area at IPS and Underground Barrier -
Trench B At the completion of the expanded leakage monitoring program, an ECN will be initiated to accomplish any needed repairs.
WBN FSAR Section 2.5-Incorporation of underground Barrier "As-Built" information is to be incorporated in WBN FSAR.
(CATD 10100-WBN-02)
Line management response was:
Theh ehar t
r
-1y14 onditions of the bar cl"h i{
edb FSAR in e
adarMa e tidh Section 2. 5 are rel ated to b
tr h
~,
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 65 0F 66
)
7.1.2 Sink hole The sink hole was excavated to a reasonable reduction point, the
]
source was identified and eliminated, and the hole was backfilled I
using qualified materials. Corrective Action completed prior to the employee concern.
7.1.3 Blowdown Lines Backfill j
The pipe between the cooling tower weir box at approximately elevation 702 to the pipe-tee was repaired by patching the l
existing fiberglass pipe. This repair procedure did not stop the leaks totally, but reduced the leakage of water to an acceptable amcunt to satisfy DNE. The pipeline was never designed to be completely watertight. The leg of the pipe between the tee and holding pond was not considered to be repairable due to so much i
damage. The section of pipe between the cristing access M. H.
i l
and tee of the holding pond leg was completely replaced using a l
i 48-inch Class III concrete pipe in accordance with CCN-C47 in 1984. The backfill material below the blowdown line is granular material which will allow for any small amount of water leaking I
to drain to the south slope of the excavated area. Corrective l
Action completed prior to the employee concern.
I 7.1.4 ERCW Pipelines Backfill' j
No corrective action required.
j l
l 7.1.5 Eoith Valve Room Backfill l
No corrective action required.
7.1.6 Low Volume Waste Nolding Pond Dike Ho major corrective actions need to be performed for this specific concern. However, WBN DNE civil engineers will initiate an ECN to put a note on the drawing 20W228-1 stating that "the LYWHP dike will not be used for any other purpose (except as noted below) without prior approval from DNE, because of the indeterminate foundation material for the dike.
i The construction of the electrical conduit bank to the Meteorological Station through the dike was approved based on the j
fact that loss of dike and conduit bank would not be critical to the safety of the plant." (CATD 10100-WBN-03)
=
a
'1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER:
2 GE 66 0F 66 The line management response was:
Note C or drawing 10W228-1 e revised a follows:
l "The low volume waste o:
e wi be used for
- tA any other purpose A
o e
elow) without cguq,e If indeterminate prior approva r
foundatio th k
Note con non-c electrical conduit bank for which j
r r
slo o
e dike. can be accommodated. Note D 4
e gs result of the change to Note C given l
ab v.
Revi on wi e accomplished via ECN Exception A chango controi I
(no E ber required).
7.1.7 General Concerns No corrective action required 7.1.8 Dry Active Waste (DAW) Building - (SON)
The material was removed and areas excavated to approximately 12 to 18 inches below in-situ soil for all column footings, grade beams, and under the compactor area of the DAW Building. The work was performed by the DNC NSB Unit.
The areas were overezcavated beyond the original guidelines. The fcundation I
area was backfilled with compacted 1032-crushed stone in 4-inch layers to the required elevation, before placing the concrete building foundation. The material was inspected randomly by l
cognizant engineers from DNC NSB Unit, not QC-Inspectors, and no documentation was recorded, since the DAW Building was non-QA.
Corrective action was taken and completed as a result of employe9 concern.
8.0 ATTACHMENT 3 Attachment A - Listing of Employee Concerns indicating safety relationships and generic applicability.
Attachment B - List of evaluators.
Attachment C - List of concerns by issue and classification of findings designations.
1 1
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5
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10100 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 1 0F 1
-r ATTACHMENT B LIST OF EfALUATORS WATTS BAR NUCLEAR PLANT (WBN) CONCERNS J. L. Howard: Lead D. E. Wizon
- 3. W. Joyce SEQUOYAH NUCLEAR PLANT (SON) CONCliRN k
J. L. Howard k
'9 5
- l TVAEMPLotgl$DNCERAS REPORT NUMBER:
10100 t
SPECIAL PROGRAM l
REVISIOW NUMBER: 2 1
PAGE 1 0F 1
- 2.,
ATTACHMENT C LIST OF CONCERNS BY ISSUE ISSUE CONCERNS l
Barrier Trenches IN-85-066-001 IN-85-442-X13 IN-85-472-007 IN-85-496-001 IN-85-529-003 IN-85-978-002 l
IN-ES-978-003 IN-85-978-011 WI-85-040-004 WI-85-040-005 l
l Sink Hole IN-85-442-X11 Blowdown Lines Backfill IN-85-196-001 IN-85-472-003 IN-85-529-004 ERCW Pipelines Backfill IN-8 6-205 -001
)
North Valve Room Dackfill IN-85-978-003 I
IW 65-978-011 i
Low 7olume Waste Holding Pond Dike IN-85-088-002 General IK 85-302-001 IN-85-978-013 IW-85-472-006 Backfill DAW Building (SQN)
JAN-S6-002 l
--