ML20235B749

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Rev 3 to TVA Employee Concerns Special Program Subcategory Rept 10800, Structural, Consisting of Vol 1, Const Category
ML20235B749
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 05/20/1987
From: Brown R
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML082340470 List: ... further results
References
10800, 10800-V01-R03, 10800-V1-R3, NUDOCS 8902140412
Download: ML20235B749 (45)


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TVA EMPLOYEE CONCERNS REPORT NimBER: 10800 SPECIAL PROGRAM REPORT TYPE: Subcategory - Construction (Final) REVISION NUMBER: 3 TITLE: Structural PAGE 1 0F 21 REASON FOR REVISION: To incorporate SRP conunents, executive sumary and finalize report. Revision 1 To incorporate SRP coments, delete issue classification and Revision 2 l refinalize report. To incorporate SRP and TAS connnents and refinalize report. Ravision 3 PREPARATION FREPARE Y: f A4*/ _r ( ( I W GNATURE DATE PRE RED BY: f // M A b t ) O - MhL M E13-E7 ~ t SIGRATURE/) DATE PARED BY L/ O Pa swa s/is/e7 L l SIGNATURE I DATE i REVIEWS PEER: / AZL4%.Y [~/3*Y7 SIGNATURE DATE % TAS: OAL [//f/(( SIGNATURE / DATE CONCURRENCES CEG-H: s./ 5~)f"Al srb

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!k d'El 'Q j/ SIGNATU,RE7 DATE SIGNATURE DATE F APPROVED BY: t 6 6 V A/A O ' ECSP MATAGER ( LATE MANAGER bF' NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

  • SRP Secretary's signature indicates that SRP files contain documentation of full panel concurrence.

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Preface. Glossary, and. List of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR. CURRENT REVISION l 3' i To clarify that one or more attachments will help the reader find where a particular concern is evaluated I l 1 o l l L i l \\ l l l 1 l

TUA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT MATTER REV: 3 FAGE i 0F vili Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Tast Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before 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 fc inal, written description of a circumstance or circumstances that an eAployee 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 NEC, 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 directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2. An element consists of one or more closely related issues. An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns. For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself. Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element. Subcategory reports summarize the evaluation of a number of elements. However, the subcatescry report does more than collect element level evaluations. The subcategory level overview of element 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 apparent at the element level. To make the subcategory reports easier to understand, three items have been placed at the front of each report: a preface, a gicssary 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 numbors; identifies other subcategories 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.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE 11 0F vili The subcategories are themselves summarized in a series of eight category reports. Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas: management and personnel relations industrial safety construe' tion material control operations guality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General. l l Just as the subcategory reports integrate 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 causes of those problems that run across more than one subcategory. A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector General's report. For more detail on the methods by which ECTG employee concerns were evaluated.and reported, consult the Tennessee Valley Authority Employee Concerns Task 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. l l l l l

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE 111 0F viii ECSP GLOSSARY OF REPOP.T TERMS

  • classification of evaluated issues the evaluation of an issue leads to one of the following determinations:

Class A: Issue cannot be verified as factual Class B: 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 was undertnken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation l Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern. collective sir.nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective. l concern (see " employee concern") l l l I corrective action steps taken to fix specific deficiencies or discrepancies ) l revealed by a negative finding and, when necessary, to correct causes in l order to prevent recurrence, i l cri,terion (plural: criteria) a basis for defining a performance, behavior, or l quality which CNP imposes on itself (see also " requirement"). element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues. omployee concern a formal, written description of a circumstance or l circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the l K-form. H l l

4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM ] FRONT MATTER REY: 2 1 i PAGE iv 0F vili i 1 eyaluator(s) the individual (s) assigned the responsibility to assess a specific grouping of eraployee concerns. findings includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action. issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one 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. 1

  • Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).

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TVA EMPLOYES CONCERNS REPORT NUMBER: 10800 SPECIAL 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 Institute 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 i CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head i CFR Code of Federal Regulations CI Concerned Individual CNTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU. CON)

'l 4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vi 0F vill DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training l DOE Department.of Energy l l DP0 Division Personnel Officer l l DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualific'ation EMRT Emergency Medical Response Team EN DES Engineering Design l ERT Employee Response Team or Emergency Response Team .l FCR Fleid Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instr 9ction KVAC Heating, Ventilating. Air Conditioning II Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice I

4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vii 0F vill L/R Labor Relations Staff MLAI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch N5RS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC) NUKARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act) ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction 9

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM FRONT NATTER REV: 2 PAGE viii 0F viii QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction in Force RT Radiographic Testing SQN Sequoyah Nuclear Plant SI Surveillance Instruction SOP Standard Operating Procedure SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff 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 Nuclore Plant UR Work Regitnst or Work Rules WP Workplans l I I

a TVA EMPLOYEE, CONCERNS REPORT NUMBER: 30800 SPECIAL PROGRAM REVISION NUMBEPJ 3 j PAGE 2 0F 21 OUTLINE OF CONTENTS [X{.CUTIVE

SUMMARY

i 1.0 , CHARACTERIZATION OF ISSUES 2.1 Introduction 1.2 Description of Issues 1.2.1 - 1.2.6 Watts Bar Nuclear Plant (WBN) q 1.2.7 - 1.2.8 Ballefonte Nuclear Plant (BLN) 2.0

SUMMARY

2.1 Summary of Issues 2.2 Summary of Evaluation Process ) 2.3 Summary,.of Findings q l 2.4 Summ&ry of Collective Simrificance 2.5 kmmarr of Cauwes 2.6 Summary of Corrective Action ) 3.0 EVALUATION PROCEid 3.1 General MethodJ of Evaluation 3.2 Requirements or Criteria Established for Individual Issues 3.2.1 - 3.2.6 Watts Dar Nuclear Plant 3.2.7 - 3.2.8 Bellefonte Nuclear P] ant x 4.0 FINDINGg 4.1 Concrete / Masonry Blocks (WBjQ,

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGEAH l REVISION NUMBER: 3 PAGE 3 0F 21 4.2 Concrete (WBN) 4.2 GateHouse (WBN) 4.4 Structural Seals (RBN) 4.5 Door Installation (WBN) 4.6 Door Testing (WBN) 4.7 Concrete Pours (BLN) 4.8 Survey Control Points (BLN) 5.0 COLLECTIVE SIGNIFICANCE Watts Bar Nuclear Plant t Bellefonte Nuclear Plant 6.0 CAUSES 6.1 Watts Bar Nuclear Plant Issues q 1 6.2 Bellefonte' Nuclear Plant Issues 7.0 CORRECTIVE ACTIONS 7.1 Corrective Action Already Taken or Planned

  • /. 2 Corrective Action From CATD's 8.0 ATTACHMENTS 8.1 Attachment A. Subcategory Summary Table 8.2 Attachment L. List of Concerns by Issue 8.3 Attachment C. NFRS Investigation Report I-85-534-WBN on Groundwater Qa.t{Lg 8.4 Attachment D. List of Etaluators

m n STRUCTURAL Report Number: 10800 Revision Number: 2 Executive Summary Sunnary of Issues Eight issues are covered in this subcategory, five are deemed nuclear safety-related, e.g.. " Concrete," " Structural Seals," " Door Installation," " Door Testing," and " Concrete Pours." The remainder, " Concrete / Masonry Blocks," "Gatehouse," and "Su~rvey Control Points" are deemed non-nuclear safety-related. Two issues, " Survey Control Points" and " Concrete Pours" are specific to Bellefonte Nuclear Plant (BLN) _and the remaining six specific to Watts Bar Nuclear Flant (WBN). i yajor XLridh The evaluations concluded that five of the eight issues, " Concrete / Masonry Blocks.." ' Gatehouse,' Structural Seals," " Door Installation," and " Concrete Po9rs" were installed, documented (where required), and designed properly for their intended purposes. It is well to note, however, that "in process" changes and modifications occurred in a couple of issues which could have led a " concerned erplcyee" to misunderstand the entire process, The remaf51ng three icpues eere unique to themselves, therefore, they are addressed individually, a.C., " Door Testing" - The doors installed would not seal sufficiently to validate the Auxilary Building Secondary Containment Envelope (ABSCE) Test and had to be repaired. This "in-process" technique of dise';verinc areas in need of repeir created in appearanca of a tett violation. " Survey Contrcl Points" - bisecepM.cles were found in several tranfers of control points, but the documentation and resciutions were controlled by the approved programs. " Concrete" - The investigation / evaluation of this issue could not substantiate a substat;dard opening through the ceiling of the contaminated laundry room. Collective Significance of Findings There were items of significance, but evaluated collectively they were found I to be a small group of construction details commonl'y expected in a lar6e IF3 construction program. All were correctable and none were safety-re16ted or I could negatively impact operational safety. l Note: See Executive Summary Table #1 for Issue Evaluation. 3712T Page 1 of 1

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-- s, TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 3PECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 21 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The subcategory of structural contains eight concerns. Due to the specificity of the concerns, each concern will be addressed as a separate isspe. 1.2 Description of Issues 1.2.1 Concrete / Masonry Blocks i I A 6-inch wall of the hot shop in unit or.s at elevation 713' was made of concrete blocks. Cavities are present at the mortar joints. Finishers did not fill these cevities because of a tight schedulo. Concerned individual (CI) was told this was a radiation wall. 1.2.2 Concrete 4 hole was made in the floor over the contaminated laundry i room in an improper manner. 1.2.3 Getehouse Changes were made to the gatehouse without documentation. I Construction ensnges were verbally approved by telephone, j Actual work performed per Engineering Change Notice ] (ECN) 4039 is indeterminate. Ihts may involve a safeguard ) area. i 1.2.4 Structural Seals Expansion joint seal between Reactor Building and Auxiliary Building in unit 1 and 2 at elevation 692'O leaks and permits seepage of groundwater into these buildings. This situation could allow a radioactive spill inside these buildings tu leak into the groundwater system, thus i contaminating this water system. 1.2.5 Door Installation Craft personnel were instructed by their management to install five doors that were not shown on design drawings. These doors were not inspected.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVIS10N NUMBER: 3 PACE 5 0F 21 } 1.2.6 Dgor Testinr. Auxtliery Building Secondary Containment Envelope (ABSCE) test (vacuum test on internal doors) would not moet acceptance criteria. Personnel sealed doors with rags until acceptance criteria could be met. 1.2.7 ,cornrete Pours Rebar and/or insulation may have been omitted during the concrete pours of the Essential Raw Cooling Water (ERCW) pipe tunnels. 1.2.8 Survey Control. Points, Inadequate methods used to implement survey control points. Note: This issue is also addressed in QA/QC sub stegory 80212. 2.0 SUKMARY 1.1 Summary of Issues Eight issues involving structural features of the plant are contained in this report.' These issues are concrete / masonry block, concrete, gatehouse, structural seals, door installation, door testing, concrete pours and survey control point.s. 2.2 $unnary of Evaluation Procass The issues in this subcategory were evaluated by reviewing drawings, specifications, workplans, ECNS, Fleid Change Requests (FCRs), existing Nuclear Safety Review Staff (NSRS), Employee Response Team (ERT), Watts Bar Nuclear Plant (VBN) Project Managers Office (PMO) and WBN Construction Investigation Reports / Responses, Bellefonte Nuclear Plant (BLN) Employee Concern 2 investigation Reports. TVA General Construction Specifications, conducting it.terviews with knowledgeable personnel and plant walkdoiens. 2.3 Summary of Findint.s The issues of structural seals and survey control points were found to be valid and have been or are currently being corrected. The remaining six issues were found not to be valid. 2.4 Summary of Collective Significance As e result of this evaluation, it is evident that certain facts expressed are true with respect to the subje t concerns. However,

TVA EMPLOVEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 6 CF 21 so condition adverse to quality nor any condition that would cause s quality to be compromised was, identified. Furthermore, nc lR3 I ccadition was identified that would affec6 the aafety cf employees i c: impede theta in the performance of their duties. 2.5 Sunraary of Causes For issue 1.2.4, structural Jeais, the design of the facility never intended to inate the Auxiliary Buildinr, leak proof. -l l For issue 1.2.8, some of tb6 original temporary survey control points were installe# ine'orrectly due to human error and l inattention to precision. The r6toainins six issuez were not valid so there are no causer-4 2.6 {gmmary of Corrective J_ctlon, j e 1 For issue 2.2.4, structyral sesis Nonconformance Report (NCR) l W-233-P wks written and workplan 4976 it, sued to repair the Ica4ges. This work has been completed. A monitoring system is in j place te n.onitor for futura.Seel leakages. The Nuclear Services Branch (NSB) will raor.itor for future seal leakages. For issue 1.2.8, :;urvey control po'ats, NCR 2133 was written tr check 2 tereporary control poir.ts for accuracy and cort'ect any discrephntiec, then install,rermanent control point pistes. Other engineering units were notified to reverify location of their l festures. Any future discrepancies will oe nonconformed and { j corrected. Also, per disposition of the NCR, other engineering ( units will be nutified of the discrepancies. 3.0 EVALUATION PROCESS 1 8 3.1 General Methods of Evaluation i This evaluation was performed by reviewing applicable drawings, l specifications, workplans ECNs, FCks, existing NSRS, ERT, j Watts Bar Nuclear Plant (WBN) Plant Mauger's Office iPMO) and WBN Construction Investigation Reports / Responses, TVA General Construction Specifications and other relevant criteris. Employee l' interviews and plant walkdowns were also utilized. 3.2 Reautrements or Criteria Established for Individual Issue,,s_ 3.2.1 Issue 1.2.1 - Cone _rpte/ Mas,ogry Blocks r A. The expurgated v.% 1oyee concern file was reviewed for additional information. .J

e TVA EMPLO'IEE COFCERNS REPORT NUMBER: 10800 l SPECI,AL FF0 GRAM l REVISION NUMBER: 3 PAGE 7 0F 21 l B. Civil drawings ooW421-3 315 (architectural floor plan, elevation 715.0), 46W423-8 R10 (architectural wall sections) and 46W425-7 R7 (architectural miscellaneous details-hot shop facilities) were reviewed for specific inforettiva >n subject wall. l C. Reviedad the Cs7 crete Tracking System Master Report to determine applicable concrete pour cards. Reviewed pour j cards GS OC 16, 101, 111, 121, 125A, 126, 129, 130, 135, 142, 145, 147, and GSBG 144. Also3 workplans 2814 and 2835, which provided instruction required to perform work, were reviewed for any additional quality control requirements. I I l D. Interviewed cognizant design, architectural, and nuclear engineers. Interviews wees also conducted with the i Construction Supetint66 dent, knowledgeable Civil I Engineering Unit (CEU) personnel and the site ALARA l Engineer. ALARA (As Low As Reasonably Achievable) I identifies a program whose purpose is to hold radiation exposure to a minimum. E. Performed field walkdown with cochizant CEU personta1 to J visually inspect subject wall. 1 3.2.2 Issue 1.2.2 - Concrete l l l A. An attempt was made to coordinate with Quality l Technology Company (QTC) to obtain further detailed information. B. Interviewed cognizant CEU personnel. C. Performed field walkdowns with cognizant CEU personnel of affected areas. 3.2.3 Issue 1.2.3 - Gatehouse A. Reviewed existing WBN - PMO response to the subject I concern. B. Interviewed cognizar,t CEU personnel. C. ECN 4039, FCR F2602 and FCR 2603 R1 were reviewed to determine a complete description of the changes. A i review was also performed of memorandum SDP 830617 002 frote Special Design Project to Watts Bar Design Project dated June 17, 1983 and memorandum OQA 830527 002 from I l J. W. Anderson to M. N. Sprouse dated May 27, 1983. i 2 l l l l l

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 i SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 8 0F 21 l 3.2.4 Issue 1.2.4 - Structural Seals l l A. Reviewed existing NSRS investigation report I IN-85-534-WBN. l B. Interviewed cognizant Nuclear Services Branch (NSB) I personnel. i 3.2.5 Issue 1.2.5 - Door Installation A. Reviewed existing WBN - Construction response to the subject concern. B. Civil drawings 46W452-8 R2 (architectural secondary lab plans), 46W454-16 d4, RS, R6 (architectural door and l hardwater schedule) and 46W454-9 R21 (architectural door and hardware schedule - door details) were reviewed for locations and specifications. C. Interviour were conducted with cognizant CEU personnel. Also interviewed was a cognizant design architectural l engineer. 3.2.6 Issue 1.2.6 - Door Testing A. Reviewed existing ERT investigation report IN 85-088-001. 1 1 B. Interviewed knowledgeable NSB and nuclear power l personnel. 3.2.7 Issue 1.2.7 - Concrete Pours A. The Employee Concern Investigation Report was reviewed. B. Mechanical drawing series 7YWO401-KE was reviewed. Concrete progress chart drawing SYNO318-01 RO was also reviewed to determine applicable concrete pour cards. A review of concrete pour cards P-1-1G and 2G, P-1-30 and 4G, P-1-5-F, P-1-H and 2H, P-1-3H and 4H, P-1-5H P-1-1F and 2F, P-1-3F and 4F and P-1-5G wss performed. C. Bellefonte Nuclear Plant (BLN) construction progress photos 88P-419, 91620N, 91618D, 88P-428, 88P-437, 91618E and 91620M were reviewed to establish construction progress as of April 19, 1978. D. Interviews were conducted with cognizant CEU personnel involved in construction during this time.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 9 0F 21 3.2.8 Issue 1.2.8 - Survey Control Points A. Reviewed expurgated employee concern file for additional information. B. Reviewed existing Quality Control Investigation Report (QCIR) #15,966. Reviewed existing NCRS 2133, 2628, 2768, 2769, 2770, 2771, 2781, 2799, 2821, 2822, 2858, 2894, 2895, 2978, 2979, 2980, 3022, 3023, 3997, 4050, 4055, 4092, 4550, 4566, and 4842. Memos attached to these NCRS from involved quality control disciplines were also reviewed. An informal memorandum from J. Olyneic, CEU Supervisor, to R. Norris, CEU Group Leader, dated January 15, 1982 on the routing of QCIRs written against control points was also reviewed. Reviewed memos from R. Norris to other units which located permanent control plates. 4.0 FINDINGS 4.1 Issue 1.2.1 - Concrete / Masonry Blocks 4.1.1 Generic This issue was site specific to WBN and was determined not to be generic to other sites. 4.1.2 Site Specific A. A review of the expurgated employee concern file proviaed no additional information. B. A review of civil drawings 46W421-3, 46W423-8 and 46W425-7 supplied details of the subject wall. The wall was found to be a 12" block wall ((2)6" hollow block walls, concrete filled, with a 3/8" steel plate sandwiched between) that separates the health physics lab, hot instrument shop and the snubber shop from l nonprotected, clean areas on elevation 713.0. It should also be noted that these areas are located in the Service Building, a non-seismic, non-QA structure, i

+, TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 10 0F 21 C. The Concrete Tracking System Master Report was reviewed to determine applicable concrete pour cards. A total of thirteen cards were identified as applicable, all of which were found and reviewed. No obvious discrepancies or inconsistencies were noted. All documentation was complete and legible. The pour cards and workplans 2814 and 2835 contain the quality control requirements for the subject. wall. Furthermore, the Service Building is not a category one structure and the subject wall is considered to be non-QA. D. Interviews with cognizant Division of Nuclear Engineering (DNE) personnel revealed that the design intent of the subject wall was for purposes other than radiological shielding and that the information communicated to the CI that "this was a radiation wall" was in error. To support this information, civil drawing 46W425-7 showed the 6" block wall detail and i included the note" no shielding is required." The Construction Superintendent was interviewed and indicated that, although the applicable drawings called for the use of a masonry contractor for block laying, TVA forces were utilized to accomplish the work. He j indicated that he did not remember being required to j apply a " full mortar bed" where blocks joined at the vertical joint and that because of this, there could be j small cavities in the vertical joints where mortar was 1 applied along vertical block edges rather than on the entire vertical face of the block. He also indicated that the applicable construction schedule was not met but that the total manhour estimates were adhered to. He emphasized that the construction schedule had no impact whatsoever on the overall quality of work performed by the masonry personnel. Note: Based on this information, applicable drawings and workplans were again reviewed to determine if a " full mortar bed" requirement existed for subject wall. No such requirement was found. Cognizant civil engineering personnel were interviewed with respect to the " full mortar bed" requirement. They concurred that this requirement is not applicable to the subject wall. 4

~ TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 REVISION NUMBER: 3 PAGE 11 0F 21 The site ALARA Engineer was inter *11ewed to determine health physics requirements and intent with regard to the subject wall. Health physics was aware that, by definition, the subject wall was not a shield wall, but because of its proximity to the hot instrument shop and snubber chop, it would provide a certain degree of shielding to adjacent clean areas. To control potential exposure of personnel in these adjacent clean areas, two area radiation monitors were installed and routine radiation surveys will be performed on the clean side of j the subject wall. ] E. A walkdown was performed of the subject wall. This i walkdown encompassed all accessible areas on both sides { of the wall and revealed no obvious exterior cavities. Vhile the north side of the wall had protective coating applied and the south side had received a standard coat of paint, any existing exterior cavities would have been readily visible. 1 The statement made by the CI that " cavities exist where two blocks join" may, in f act, be a true statement. However, since the investigation revealed that the design intent was not directed toward radiation shielding, the' fact that cavities may exist has no de,trimental effect toward the subject wall. Therefore, no condition adverse to quality could be identified. 1 This concern was factually accurate, but what it describes was not a problem (i.e., not a condition requiring corrective action by ONP). 4.2 Issue 1.2.2 - Concrete 4.2.1 Generic This issue was site specific to WBN and determined not to be generic to other sites. 4.2.2 Site Specific A. An unsuccessful attempt was made to obtain further detailed information from QTC.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10000 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 12 0F 21 B. Interviews conducted with cognizant CEU personnel revealed that, to the extent of their knowledge, no holes had been drilled or chipped in an improper manner. They furtt.or replied that they were unaware of any NCRs or other documentation initiated to document any deficient work or work method used in the area addressed by the concern. C. A walkdown was performed of the contaminated laundry room ceiling and the concrete floor above the room. The ceiling proved to be ribbed metal decking throughout the entire laundry area. Several HVAC ducts and some small diameter piping penetrate from the floor above but because of the metal decking and congestion that exists in the ceiling area, no effective inspection could be performed.to identify potential deficiencies. Further walkdowns were performed in both the waste baller shipping room and barrel preparation room, located directly over the contaminated laundry room. No obvious discrepancies were noted nor were any questionable areas or holes found. Although specific, detailed information was not available..this evaluation could not perify or document any improperly installed holes in stated areas. Therefore, the concern can not be verified as factual. 1 4.3 Issue 1.2.3 - Gatehouse 4.3.1 Generic This issue was site specific to WBN and determined not to be generic to other sites. 4.3.2 Site Specific A. Review of the WBN-PMO response to this concern revealed that this concern did not involve a safeguard area. When TVA changed its original security concept to the. power block concept, the function of the gatehouse changed from that of a primary security control point to that of an access control point.of a noncritical nature. Due to this change, the gatehouse is not safety related in any way nor is it subject to safeguards control. ___________m__

TVA EMPLOYEE CONCERNS REPORT NUMBER:.10800 SPECIAL PROGRAM { REVISION NUMBER: 3 PAGE 13 0F 21 3. Interviews conducted with cognizant CEU personnel revealed that FCRs F2602 and F2603 R1 were written to document changes to the gatehouse. ECN 4039 was initiated as a result of these FCRs. C. A review of FCRs F2602 and F2603 R1 and ECN 4039 showed that changes were documented. FCR F2602 initiated gatehouse modifications according to DNE sketches 52083-1, 2 and general notes while FCR F2603 R1 initiated modifications by requiring all interior glass, tubular partitions, and millwork to be removed according to Nuclear Power's request. As a result of these FCRs, memorandum SDP 830617 002 was initiated by the Special Design Project to Watts Bar Design Project on June 17, 1983. This memo directed the Design Project to initiate ECN 4039 and addressed the fact that the aforementioned FCRs documented the work to be done and that the issuing of the ECN should be expedited since work had already begun. Additionally, the memo stated that the original intent was to handle the work entirely by FCR but the Special Design Project was unable to issue the drawings using the FCR process for reasons stated in memorandum OQA 830527 002 from J. W. Anderson _to M. N. Sprouse dated May 25, 1983. The findings of this evaluation show that changes to the gatehouse were, in fact. documented. Since a large portion of the correspondence concerning the gatehouse was transmitted between the Special Design Project and the Watts Bar Design Project, it is conceivable that the CI was not aware of the paperwork generated to document the subject modifications. Furthermore, because the gatehouse is a non-QA support facility and no safeguards are involved, no condition exists that has caused quality to be compromised. This concern cannot be verified as factual. 4.4 Issue 1.2.4 - Structural Sosis 4.4.1 Generic This issue is rite specific to WBN and was determined not to be generic to other sites.

m TVA EMPLOYEE CONCERNS REPORT NUMBER: 30800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 14 0F 21 4.4.2 Site Specific A. NSRS Investigation Report IN-85-534-WBN (Section III. Subsection B, C, D and E) addressed the issue of expansion joint seal leakage in two different areas. l The first encompassed the actual, the significance, and the resolution of the inleakage problem. However, conversation with WBN-Design Project personnel revealed the Auxiliary Building was never intended to be leak proof. Additionally, NCR W-233-D was initiated to document the leakage and workplan 4976 was issued to repair the unit I and 2 leakages. This repair was l performed for both economical and housekeeping I considerations, i.e., it was more cost effective to IR3 repair the leakages than to clean-up, patch /fix leakages 1 on a day-to-day basis. This repair was accomplished by l replacement of the fiberglass material in the expansion l joints with a pressure-injected chemical grout material. After determination of the leak's elimination, a foam backer rod and elastomeric sealant were applied to the joint. The second area addressed was the potential contamination of the groundwater system. In this area, research was performed and a review conducted of the WBN site geology to determine the parameters of radiological monitoring of the groundwater system. This revealed an ettensive monitoring program that includes a routine sampling of the local groundwater system as well as local drinking water, river sediment and agricultural and livestock products. B. Interviews with cognizant Nuclear Services Branch (NSB) l personnel revealed that wcrhplan 4976 was closed, the repair of the subject expansion joint having been completed. Additionally, NSB was continually monitoring other areas of the plant where inleahage had seen recorded. This evaluation shows that the concern is factual with respect to subject seal leakage. This leakage may occur in areas where concrete was not thoroughly consolidated adjacent to the waterstop. Additionally, the waterstops may be locally distorted or may have relaxed so that they are not tightly wedged into the concrete. I i

m TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800-SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 15 0F 21 This problem has been documented and corrective action taken. It should be noted that the corrective action l was not required by a specific design requirement. lR3 Rather, repairs were initiated for economic reasons and I housekeeping considerations. Furthermore, due to the l physical location at.d site geology of WBN, the potential for operational activities to adversely affect the region's groundwater users is very low. However, to assure the protection of those users WBN has established and implemented a program to routinely monitor the local groundwater system for radioactive l materials. This evaluation does not identify a condition adverse to quality. l This concern is factual and identifies a problem, but corrective action for tha probles was initiated before the employee concerns evaluation of the issue was undertaken. 4.5 _I_ssue 1.2.5 - Door _ Installation l 4.5.1 Generi2 This issue was site specific to WBN and determined not to be gene.eic to other sites. ~ 4.5.2 Site Specific A. Due to the vagueness cf the WBN-Construction response to the subject concern, the realew of this response did not reveal any relevant infermaticti. S. A review of civil drawings 40W452-6, 46W454-16 and 46W454-9 revealen specific door locations, specifications and f? ire rati0s criteria. Per drawing 46W462-8, the subject doors are Numbered T100. T101. T102. T103 and T104. Door T101 was the only interior door, all others being exterior / exit doors. Drawint 46W454-16 required that doors T100, 7102, 7103 and T104, all of which are exterior doors, have h "B" fire rbting while door T101 carried no firo rating. Additionally, doors T100 and T104 were type "G" which according *.o drawiht 46W454-9 reflected doors with glass window, doors T102 and T103 were type "L" which were eslid toors with bottom lousers and door T101 wru a type "F" door which was solid with no glaem window or Inv;ers. 1 J

4 ~ TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM l i REVISION NUMBER: 3 PAGE 16 0F 21 C. Interviews with cognizant CEU personnel revealed thet the secondary cinemical lab is located in the Turbine Building and is considered a non-QA structure. Also revealed was the fact that the door frames were available from WBN and installed prior to procurement of the subject doors from Hartryllie and Phipps Bond. Further conversation revealed that Construction Change Notification (CCN) C-54 was initiated to correct a drawing discrepancy c.oncerning doors T100 and T104 The drawing ref3ected type "G" doors which did not meet the required fire rating J criteria. Therefore, the CCN changed the drawing to reflect a type "V" door. Finally, this interview revealed that doors and door frames receive fire rating certification from Underwriters Laboratories (UL) Independently and rach should have a separate UL tag attached. Interview with cognizant design architectural engineer provided information agreeing that doors and doorframes "l are tested / certified individually with respect to UL fire rating. l D. Field walkdowns revealed that doors T100, 7102. T103 and 7104 all had UL certification tags attached to both doors and doorframes. These doors had "B" fire rating as specified on the applicable drawing. Door T101, a type "F" door, had no UL tag attached to the door or doorframe because it carries no UL fire rating. Each of the subject doors were of the type,and configuration required l by the applicable drawing. 1 I The findings of this evaluatien show the concern can not 1 be verified as factual and ooes not identify a quality 'l problem or procedure violation. 4.6 Issue 1.2.6 - Door Testina 1 4.6.1 Generic This issue was site spacific to WBN and datormined not to be generic to other sites. 4.6.2 Site Speelfic l A. Review of ERT investigation report IN 85-088-001 revealed. that during preparation uf various doors and penetrations .for ABSCE testing, construction determined that test l acceptance criteria could not be met with boundary doors =me

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 17 0F 21 in their present condition. Thus, workplan 3526 was written and issued to rework doors as needed. In implementing this workplan, construction personnel placed plastic, duct tape and possibly rags over doors to enable pin-pointing of air leaks. These temporary articles, with the exception of door A126 which was temporarily sealed with plywood and duct tape, were removed before actual ABSCE testing was started. Test exception EN-4 was taken to allow ABSCE testing to proceed with door A126 temporarily sealed. Door A126 was later installed upon receipt under workplan 4229. 1 Interviews with cognizant NSB and Nuclear Power engineers revealed that additional testing will be required prior to Mode 4 (hot shutdownf and retesting is required as part of the surveillance requirement in the FSAR and SI 7.9. This evaluation shows that the concerned individual may have construed construction activities and preliminary testing to be actual performance of ABSCE testing. This evaluation shows that fully adequate documentation exists to certify proper test performance and completion. Therefore, the concern cannot be verified as factual. Future tests are also required to further verify door acceptability. This evaluation concludes that quality was in no way compromised. 4.7 Issue 1.2.7 - Concrete Pours 4.7.1 Generic This issue was site specific to BLN and determined not to be generic to other sites. 4.7.2 Site Specifig A. A review of the employee concern investigation report revealed that the CI was referring te the concrete poured around the Essential Raw Cooling Water (ERCW) piping. The CI also stated that when he left at the end of his snift, there was no insulation or rebar installed. When he returned the next day, the concrete peur had been made. He was concerned that sixteen hours was not enough time to install rebar, insulation and make the concrete i pour. i

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 18 0F 21 B. A review of drawing series 7YV0401-KE identified two 36" diameter ERCW pipes at the location specified in the concern. Further review of these drawings revealed that these pipes were not encased in concrete. Instead, they were to be buried in limestone sand or type A backfill up to a foot above the pipe with a compacted or cast-in-place concrete slab on top of this. These pipes were encased in concrete up to the unit two rotaining wall which is approximately seventy feet west of the location given in the concern. Also reviewed was progress chart drawing 8YNO318-01 which revealed fifteen concrete pour cards used to encase the subject ERCW piping. These pour cards contain the necessary signatures by civil and mechanical personnel signifying that the hardware was acceptable prior to concrete piacement.. C. A review of the BLN construction progress photos produced several photos that contained the subject ERCW pipes. The latest picture was dated April 12, 1978, which was seven days prior to the first concrete pour. All of these photos show the subject pipes to be insulated. D. Interviews conducted with cognizant CEU personnel involved in construction during this timi revealed that with manpower levels present at that time, it would not be a problem to install any required rebar and insulation and pour the concrete in sixteen hours. This evaluation shows that this concern can not be verified as factual and there is no evidence that any procedural requirements have been violated. 4.8 Issue 1.2.8 - Survey Control Points 4.8.1 Generic This issue is site specific to BLN and determined not to be generic to other sites. 4.8.2 Site Specific A. A review of the expurgated employee concern revealed that the CI was not only concerned with the survey control points being incorrect, but also the notification of other units of the discrepancies so that the location of features or components could be reverified.

e a TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM' REVISION NUMBER: 3 PAGE 19 0F 21 B. A review of QCIRs revealed that QCIR 15966 was the first of several QCIRs initiated for this problem, dated January 18. 1982. Further evaluation revealed that on January 15, 1982, an informal memo was written from J. Olyneic to R. Norris stating that a QCIR written for inaccurate control points would be dispositioned to send a copy of the QCIR to other units so they could investigate their features in the affected area and reverify the location. The QCIR procedure was canceled on November 18, 1982. At this time, due to the large number of QCIRs written on control points. NCR 2133 was written on December 14, 1982. The disposition of this NCR was to notify other engineering units (this action had already been taken) to perform investigations and inspections of their features and for CEU to initiate a program to install permanent survey control points. This work has been completed and the NCR closed. Since the closure of NCR 2133, 82 additional discrepancies have been found and nonconformed. These NCRs are dispositioned with's " blanket" disposition: " Correct the control line (already corrected). By copy of this NCR. notify other engineering units to perform investigations of their features installed in this area and write NCRs to correct their features, if necessary. Other engineering units will inform CEU in writing of the findings of their investigations so that this NCR can be closed. Reference NCR 2133." A review of these twenty-four NCRs showed that all twenty-four had memos attached informing CEU of their findings. Also reviewed were memos from CEU Supervisor to other engineering units specifying locations of permanent control point pistes. These memos reveal a conservative approximation of 5400 permanent plates. This number includes the number of plates given in the memos plus ten percent for additional plates installed after these memos were written. I

+ l ( ZTA EMPLOYEE CONCERNS REPORT NUMBER: 10800 l SPECIAL PROGRAM REVISION NUMBER: 3 1 1 PAGE 20 0F 21 This ecaluetion shows that identified incorrect survey control points have been corrected by QCIR or NCR. Any future discrepancies will be corrected by NCR. Futhermore, it is apparent that other engineering units have been notified of the discrepancies, as their-concurrence is required for closure of the NCR. The issue is factual and identifies a problem, but corrective action for the problem was initiated before the employee concerns evaluation of the issue was j undertaken. No condition adverse to quality can be identified. 5.0 COLLECTIVE SIGNIFICANCE Each of the issues addressed in this subcategory report are diverse-and unique to the point that no collective significance is required. ) It is evident that in the areas addressed by this evaluation. TVA is fully implementing and abiding by all up'er tier documents and. p requirements. No condition adverse to quality ner.Any condition that j would cause quality to be compromised was identified, i 6.0 CAUSE I Of the eight issues in this subcategory, only two were found to be valid. l 6.1 Issue 1.2.4 - Structural Feals The cause of the leakage of structural f.eals as addressed in the employee concern can be attributed to the 1s ' of consolidation of the concrete adjacent to the waterstop. Acasticaally, the j waterstops may be locally dist'orted or may have relaxed so that' q they are not tightly wedged into the concrete. Furthermore, these 'I areas were not designed with the intent to be leak proof. J 6.2 Issue 1.'2.8 - Survey Control Points The cause of inaccurate survey control points was mainly due to human error. This could be misreeding a tape / rod, disfiguring of calculations, or some other mistake such as not verifying previously established temporary or permanent control points. Additionally, several personnel turnovers could have attributed to the cause.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 10800 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 21 0F 21 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken Or Planned Corrective action required for the two valid issues has already been taken. For structural seals at WBN, NCR W-233-P and workplan 4976 was written to document and repair the leaky waterstops. There is also a monicoring system to identify any additional leakages. For survey control points at BLN, several QCIRs were written initially to correct this problem. Due to the large number of QCIRs, NCR 2133 was written. Per this NCR, all temporary control points were verified and permanent control poicts were installed. This work has been completed. If future discrepancies are identified, a NCR will be written and the control pohit will bt rorrected. Per disposition of the NCR, other engineering units will be notified and will be lequired to report in writing to CEU. 7.2 Corrective Actibq_ffom CATD's None required. 8.0 ATTACHMENTS B.1 Attachment A, Subcategory Summary Table l 8.2 Attachment B List of Concerns by Issue 8.3 Attachment C. NSRS Investigation Report I-85-534-WBN on Groundwater s Leakage 8.4 Attachment D. List of Evaluators l l 1 l n.__-_--_________-__.__________

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i Page 1 of'1 l ATTACHMENT B ' l ) i Issue 1.2.1 - Concrete / Masonry Block.s-Concern No. IN-85-231-001 i Issue 1.2.2 - Concrete-Concern No.. IN-85-793-002 Issue 1.2.3 - Gatehouse-Concert No. IN-85-035-001 1 Issue 1.2.4 - Structural SealG-Concern No. IN-85-630-002 Issue 1.2.5 - Door Installation Concern No. IN-85-544-005 Issue 1.2.6 - Door Testing-Concern No. IN-85-086-001 Issue 1.2.7 - Concrete Pours-Concern No. BNP QCP 10.35-8-2 l Issue 1.2.8 - Survey Control Points-Concern No. BNP QCP 10.35-B i 4 E

4 4 a 4 ATTACHMENT C TENNESSEE VALLEY AUTHORITY i NUCLEAR SAFETY REVIEW STAFE NSRS INVL'STIGATIUP.1 REPORT No. I-85-536-WEN _ EMPLOYEE CONCER'N IN-85-630-002 MTLESTONE 6

SUBJECT:

GROUNDWATER INLEAKAGE DATES OF INVESTIGATION: December 11, 1985-January 7, 1986 INVESTIGATOR: 1-15-86 T. O. FrizzeAl Date j REVIEWED BY: 1-15-86 __ W. D. Stevens Date i i APPROVED BY: 1-15-86 M. A. Harrison Date l I l 4

I. BACKGROUND HSRS has investigated Employee Concern IN-85-630-002 which was communicated to the Quality Technology Company (QTC) in response to the Watts Bar Employee Concern Program. The specific concern reviewed and discussed in this report was presented by QTC to NSRS as follows. Expansion joint seal between the reactor building and auxiliary building (Units 1 and 2), 692' elevation, leaks and permits seepage j of ground water into building. Concern expressed is that this situation c.culd also permit contamination of ground water system (Aquifer) if a radioactive liquid spill occurred in these buildings. 1 II. SCOPE A. The scope of this NSRS investigation was defined by the concern of record which entails verification of expansion joint groundwater leaks in the soecified areas and determination of the status of corrective action in the event the inleakage was substantiated. Also, monitoring and safeguard of the site's groundwater system were examined. B. As a basis for investigation conclusions, reviews were made of the correspondence and other documentation associates with groundwater inleakage at WBN. Discussions were held with cognizant Office of Engineering (OE) and site Office of Construction (OC) personnel to assess the adequacy of plans and actions taken to resolve noted leakage areas. Interviews were also held with site dealth Physics and Mechanical Maintenance personnel concerning the significance and resolution of groundwater inleakage. Finally, reviews were conducted of the WBN Radiological Environmental Monitoring Pecgram as it relates to the site's groundwater system. During the monitoring program review, interviews were conducted with personnel of the TVA Radiological Health Organization to obtain information regarding the program's structure and implementation. ITI.

SUMMARY

OF FINDINGS 4 A. A review of correspondence between the WBN Construction Project Manager and the managers of the VBN design and engineering organizations revealed that groundwater leakage into the auxiliary building has been an identified problem since 1979. One area in particular that has been previously noted as an inleakage site is that which was discussed in the submitted employee concern. Specifically, groundwater soepage has been repeatedly observed and reported at the vertical expansion joints between th* reactor and ausiliary buildings at elevati-on 692.

q l i l = B. In discussions conductsd with civil enginssring personnel of the WBN Design project, it was related that the design of the facility never l intended to make the auxiliary building leakproof. However, it was a stated that waterstops.ere instePM in the noted' expansion joints I to prohiblt or slow inleakage of groundwater. VBM engineering l project personns) hav9 documented that the identified leaks occur in a few areas where concrete was not thoroughly consolidated adjacent to the watorstop. Another documented possible cause of thc inleakage is that the waterstops may be locally distorted or they I may have relaxed se that they are not tightly wedged into the concrete. C. In decumented analyses of the swall groundwater leaks identified, civil engineering personnel of OE had assessed ' chat the soepage problem was not a condition adverse to quality. However, it was j concluded that the areas leaking should be repaired to eliminate the leaks to the fullest extent practical. To support this effort, j cognir. ant OE personnel have in the p6st conducted a stA$y on materials and methods for grouting of active water leaks in concrete structures and have proviced specific repair recommendations to the WBN Certtfaction Pecject Manager. The Unit 1 and 2 leakage areas noted in the submitted concern are currently being repaired by the Construction Nuclese S,ervices Branch (NSB) under Workplan 4976. The latest repair activity was f.nitiated as a result of the issuance of Nonconformance Report NCR W-233-F by WBN NUC PR Mechanical 5 Maintenance personnel. D. Discusejons held with the cognizant NSB civil engineer responsible for the laakage repair work verified that the OE-coordinated and recommended plan was being implemented. Basically, the actual repair process involves replacement of the fiberglass material in the expansion joints with a pressure-injected chemical grout material. After determination of the laak's elimination, a foam backer rod and elastomeric sealant are applied to the joint. The NSB representative also related that Workplan 4976 would be held open until assurance of the adequacy of the repair work and that NSB would continue to monitor for new groundwater inleakage sites, j 1 E. Regardless of the corrective actions being taken to resolve the { identified groundwater inleakage areas the basis for the submitted i concern appears to be related to the plant's potential adverse h affect on the local groundwater system (aquifer). As such, this NSRS concern investigations also included a review of the WBN site geology and the implementation of activities associated with radiological monitoring of the groundwater system. The results of that review tro as follows. I i i f

{ = j 3. Geologic formations of this region consist of dolomite, limestone, shale, and sandutone. Regionally, few of tho shale 3 formatiens and nene of the sandstone tormations have significant I geoundweter potential. The most significant water--bearing ) formation in this region is the " Knox Dolomite " in which water j occurs in solutionally enlarged openings formed along bedding planes and fractures. This formation is the principal source of base flow to streams of the region and is the only significant I aquifer. The formation underlies a 1-to 2-rile-wide belt 2-1/2 l miles west of the WBN site at its nearest point; a ncrrow slice, the tip of which is aoout 1 mile north of the sito, and a 1-to 2-mile-wide belt 1 mile east of the site and accross chicamauga l Lake. Within a 2-mile radius of the plant, there is no use of the " Knox Dolomite" aquifer as a source of water to wells for other than small supplies. l 2. The plant site itself is underlain by terrace deposits of l gravel, sand, and clay, having an average thickness of 40 feet. l Essentially, all of the groundwater under the site is in this deposit. Bedrock of the "Conasauga Shale" formation underlies i the terrace deposit. WBN foundation exploration drilling and foundation excavation revealed that very little wate.r occurs in a the bedrock. Water occurs in the terrace deposit material in pore spaces between particles. The deposit is composed mostly j of poorly sorted clay to gravel-sized particles and is poorly water bearing. All recharge to this groundwater system is from l local precipitation. There is no regional subsurface transport i of water to rechargc the system, and all groundwater flow in the area of WBN has been shown to be toward Chicamauga Reservoir. l There are no sources tapped for drinking or irrigation purposes between the plant and the reservoir. Since the lake and Yellow Croak form hydraulic boundaries on three sides to the site groundwater system and the ridge is a boundary to the north, it is not believed possible that any nearby offsite groundwater withdrawals could result in drawdown at the plant site. 3. Although the potential for the plant to affect groundwater users is very low because of it physical location, a network of observation wells has been established and will be maintained throughout plant life. One of the wells, which is in the near vicinity of the plant, is equipped with an automatic water sampler. Water from the automatic sampler is being analyzed monthly for racloactivity as reqvited by plant procedures. In the remote event of the accidental release of rindioactivity to the groundwater system, nearby groundwater users will be advised not to use th61r wells for drinking water until sn investigation can be made of the extent, rate, and direction of movement of the radioactive material. These requirements are established in the WBN Final Safety Analysis Report (FSAR), and detailed information on the plant's radiological environmental monitoring program is contained in the WBN Offsite Dose Calculation Manual (CDCM).

t XV. CONCLUSIONS AND RECOMMENDATIONS Conclusj ons A. The submitted concern that points of groundwater inleakage exist in the expansion joints between the auxiliary and reactor buildings at the 692-foot elevation was substantiated. However, as detailed in this report, an NCR and workplan have previously been issued to address the leakage problem; and actual repair work-is in process. Additionally, the Construction Nuclear Services Branch and the NUC PR Mechanical Maintenance Section will continue to monitor for the adequacy of repair activities and the identification of additional or future inleakage points. B. Due to the physical location and site geology of the WBN plant, it has been analyzed that the potential for operational activities to adversely affect the region's scoundwater users is very low. i However, to assure the protection of those users. WBN has established and implemented a progran to routinely monitor the local groundwater system for radioactive naterials. It should be noted that the plant's radiological environment}. monitoring program is not restricted just to groundwater but includes the atmosphere, surface water such as the Chicamauga Reservoir, local drinking water, river sediment, allt from regional milking animals, fish, and food products grown in the area. It should also be noted that requirements are established and implemented to report the results of the monitoring program to the Nuclear Regulatory Commission, and TVA's Division of Quality Assurance conducts annual audits of the program to assure adequacy and verify compliance with program criteria. Recommendations None 1 1 l 1 l 1 1 l 3 1 ? ?

e Ar.tachment D Lead Evaluator - Gary L. Portwood Other Evaluators - Michael B. Shirey James A. Chesney 1 t _ _ _ _ _ _ _.. _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _}}