ML18052A322
| ML18052A322 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/04/1986 |
| From: | Wambach T Office of Nuclear Reactor Regulation |
| To: | Dotson J BECHTEL GROUP, INC. |
| References | |
| NUDOCS 8603110143 | |
| Download: ML18052A322 (23) | |
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March 4, 1986 Docket No. 50-255 Mr-...:-.J.;~l:.~D.o~ts.on~ -- ~.~
Bechtel Power Corp6ration P.
- 0.. Box 1000
- Ann Arbor, *MI 48106~1000.
Dear Mr. Dotson:
Distribution:
Docket File NRC & L PDRs
- Branch Files PKreutzer TWambach
. ;;.:...- _ :---.:_BGri mes_*..
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- . EJordan
- ACRS 10 CHehl,R. I Ir ESwanson
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SUBJECT:
PALISADES PLANt~CABLE TRAY SUPPORTS In June 1985.you expressed a concern regarding the adequacy of some cable tray
.f* supports *at the Pali sades Pl ant to the NRC-resident inspector.
This concern
'. was raised because "of apparent overloading or cab.le trays by added cables for. : >*;
-pl ant niodifi cat io'ns; *attachments made to cable trays such as conduit, sma l_ l piping',-or;instrument rac~s as part of plant modifications; and possibly overloading o_f cable tr~ys during initial construction.
The NRC and the licensee met witD.* *
.. you and* oth_er representatives. of Bechtel Power Corporation at the pl ant site, ~_,.!. *
- **-.f on J~ly 15\\ 1985.
As a result of that meeting,* Consumers Power Company committed to* certain* follow-on activities to *address your areas of concern.
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1 Enc i°.psed. is a copy of the Consumers Power Company _; nterna l correspondence that reports* on the results of their* on-going efforts in this matter (Memo_randum from K~ A. Toner to*J. L. Kuemin*dated September 19, 1985).
On page<5, Jhe additional actions planned* by the l iCensee are listed.
Upon
.. I.
cpmp)etfor of ttem.2, the licensee's.analyses from Item 1 and the evaluations of' Ite,m 2 wfl l be.treated by the NRC *.as evaluations pursuant to 10 CFR 50. 59,..
. that.is, an eva*luation* to determine whether an_uhreviewed safety question is involved for 11 changes in the facility. as destribeq in the safety analysis report.
11
. We intend to revfew the results of the litensee 1s evaluation and may select certai~ of the.analyses for worst case loading to *review in detail.
As you can see from the enclosed report; the 30 p~rcent fill criterion in the FSAR. was" not adhered* to and the as"'.bui l t drawings and. raceway schedl.Jl es were
- not ~p-to-date.
- Thankjou for bringi~g this. to our attention.* Based on the results of the SEP Owners Group Testing Program.*and the fndustrial experience of cable tray systems. from previous earthquakes, '{le do not be U eve that the conditions found present an immediate safety concern.
However,.we intend to follow up on this.to determine that the licens~e effects an acceptable resolution.
If you have any f~rther'comments or concerns, please feel fiee to contact us.
cc:
- See next page PBD#8 P~litzer
- { ~/,, /86 PBD#at) 1/ /fY TWambach
..2 /.<6/86 Sincerely,*
Is/
Thomas V. Wambach, Project Manager PWR Project Directorate #8 Division of PWR Licensing
...~
Docket No. 50-255 Mr. J. I. Dotson Bechtel Power Corporation P. 0. Box 1000 Ann Arbor, MI 48106-1000
Dear Mr. Dotson:
March 4, 1986 Distribution: *.Docket F.ile
-i
. NRC & L PDRs
-Br-anch-Files- -
PKreutzer
- TWambach BGrimes OELD EJordan ACRS 10 CHehl,R. III ESwanson RBrady CGrimes AThadani C.wcii.J R. Ill
SUBJECT:
PALISADES PLANT-CABLE TRAY SUPPORTS In June 1985 you expressed a concern regarding the adequacy of' some cable tray supports at the Palisades Plant to the NRC resident inspector.* This concern was raised because of apparent overloading of cable trays by added cables for plant modifications; attachments made to cable trays such as conduit, small piping, or instrument racks as part of plant modifications; and possibly overloading of cable trays during initial construction.
The NRC and the licensee met with you and other representatives of Bechtel Power Corporation at the plant site on July 15, 1985.
As a result of that meeting, Consumers Power Company committed to certain follow-on activities to address your areas of concern.
Enclosed is a copy of the Consumers Power Company internal correspondence that reports on the results of their on-going efforts in this matter (Memorandum from K. A. Toner to J. L. Kuemin dated September 19, 1985).
On page 5, the additional actions planned by the licensee are listed.
Upon completion of Item 2, the licensee's analyses from Item 1 and the evaluations of Item 2 will be treated by the NRC as evaluations pursuant to 10 CFR 50.59, that is, an evaluation to determine whether an unreviewed safety question is involved for "changes in the facility as described in the safety analysis report.
11 We intend to review the results of the licensee's evaluation and may select certain of the analyses for worst case loading to review in detail.
As you can see from the enclosed report, the 30 percent fill criterion in the FSAR was not adhered to and the as-built drawings and raceway schedules were not up-to-date.
Thank you for bringing this to our attention.
Based on the results of the SEP Owners Group Testing Program and the industrial experience of cable tray systems from previous earthquakes, we do not believe that the conditions found present an immediate safety concern.
However, we intend to follow up on this to determine that the licensee effects an acceptable resolution.
If you have any further comments or concerns, please feel free to contact us.
cc:
See next page PBD#8 PK~l.(j:.zer
- X "6_( /86 PBD#Bt/ 1/IJ'Y TWambach
..i /26/86.
Sincerely, Is/
Thomas V. Wambach, Project Manager PWR Project Directorate #8 Division of PWR Licensing
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CGrimes AThadani
~/ J/86
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- To JLKuemin, P~03 Fr'om Date Subject cc KAToner, Palisades ~~(v"JH '-.J September 19, 1985 PALISADES PLANT - CABLE TRAY SUPPORTS TJPalmisano, Palisades RAFenech, Palisades KKChao, Pl3-226 DDC 950*05000*37400/5 CONSUMERS POWER COMPANY
- I11.terrial Correspondence KAT85*034 As part of a recent Auxiliary Feedwater Project, Bechtel Corporation was charged with the responsibility of investigating the structural.capability of cable tray supports in the southeast corner of the IC Switchgear Room to carry additional fireproofing loads (Attachment 1). Bechtel's structural analysis concluded that the existing supports were not adequately designed for seismic loads.
The analysis also concluded that supports west of the trays to be fireproofed were not adequately designed (Reference I).
The. purpose of this letter is to describe the actions that Consumers Power Company has taken
!~-~esolve the Bechtel concern, to respond to subsequent NRC questions related
.to this issue, and to resolve the issue of cable tray support adequacy at Palisades.
In response to the conclusions reached in Bechtel's analysis, Consumers Power Company authorized Bechtel to strengthen the supports for only those trays designated to be fireproofed.
The additional tray support was installed by Bechtel prior to fireproofing the trays; a project which was closed out on June 18, 1984 (Attachment 1).
Regarding the trays running east to west from the fireproofed tray section (eg, trays XU012, XU014, XU016, etc), Consumers Power Company elected to rely on a continuing Systematic Evaluation Progra~ Owners Group (SEPOG) effort for resolution of the tray supports issue.
Plant representative cable tray sup-port systems, selected from detailed plant walkdowns, were evaluated and tested for the SEPOG by URS/Blume & Associates.
Based on the results of these evaluations and tests, reports of which were submitted to the NRC (Refer-ences 2 and 3), the SEPOG concluded that the existing raceway systems in SEP plants possess substantial seismic resistance, and the seismic qualification of raceway systems is net a significant safety issue. This conclusion was submitted to the NRC on October 15, 1984 (Reference 4).
We are presently
~await1n& a final Safety Evaluation Report by the NRC ~n the SEPOG submittal
. JRef erence 22. *
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C 1
- 1,.,..
Not satisfied with the timeliness of the SEP treatment of this issue, Bechtel Sf ";LL informed CPCo of its intent to inform the NRC of a potential 10CFR21 condition r: \\'
l* (Referenc;es 6 and 7).
Upon notification of Bechtel's concern, the NRC Resident If P,~ ~Inspector on June 20, 1985, questioned the plant staff as to the effectiveness
~**,v* of design control procedures to ensure that structural evaluations are per-J",.';.~.
- formed prior to adding weight to cable trays during plant modifications.
In
~l
- addition to the one-time application of a significant load to a tray such as fireproofing, the NRC Resident Inspector was concerned about the addition of individual cables and the accumulation of a significant load on the trays over time.
IC0985-0666A-TC01
- 4 2
In response to the in~pec~or's que~tions, the plant staff_ provided the follow-ing information:
- 1.
Existing design input documents have been and are effective in prompting an engineer to perform evaluations and make modifications, if necessary, of support systems prior to a substantial load being added to racew_ay.
Attachments 2 and 3 are portions of major and minor modifications and design procedures, respectively.
These documents show that design structural loads are required to be evaluated prior to modification implementation.
- 2.
Specification change design procedures are less clear in describing the requirement to evaluate structural loads prior to performing work.
As evidenced in Attachment 4, the specification change checklist does, however, require that prior to modification implementation the engineer identify and docul!lent any analyses which support the modification design.
Nevertheless, the specification change procedures are being revised to
---*provide desi~n structural loading evaluation requirements to a degree of detail consistent with the major and minor modifications' design proce-dures.
- 3. A review of recent design changes which added substantial weight to cable trays confirms our belief in that design procedures have been effective in prompting the engineer to perform required structural evaluations. Attach-ments 5 and 6 provide design documentation for two recent specification changes in which fireproofing was added to cable trays.
In each case, the engineer assured that structural evaluations were completed in advance of installing the fireproofing material.
- 4.
Existing design procedures do not specifically require that structural loading evaluations be performed prior to installing an individual cable
. within a given tray.
(It is our opinion that design procedures should not be so prescriptive as to inadvertently narrow the engineer's design con-siderations to~set of "rules" outlined in cookbook fashion.)
Therefore, structural evaluations would not be expected to have been performed for such installations.
In the absence ~f this information, a review of current fill levels of cable in a limited sample of trays in the lC Switchgear Room was performed to address the Resident Inspector's con-cern.
The current raceway schedule shows trays adjacent to the fire-proofed tray section to be filled to a roximatel *30 cros -section*
er fill limit rovided in t e ori inal FSAR for tra s carr in S..The 30% fill requirement is considered conservative National Electric Code allows a fill of 501. for tra conductor control and s gnal cables only, as do the IC0985-0666A-TC01
- 6.
A visual inspection of the raceway running east to west from the fire-proofed tray section was conducted on June 19, 1985.
Accessible raceway support were specifically inspected for evidence of raceway o'V'lf!rloading (eg, broken concrete around the point where the raceway vertical support strut is affixed to the ceiling, or misaligned struts). Our inspection, which consisted of engineers climbing up into the tray systems, failed to reveal any signs of tray overload.
3 Only July 15, 1985 members of the NRC's SEP and Operating Reactors Branches visited the plant site to be briefed on the Bechtel concern.
During the meet-ing Consumers Power Company provided the NRC with a review of the information previously given to the Resident Inspector (Items 01 through #5 above).
In addition, the NRC was provided with our preliminary structural evaluations which indicated that the trays running east to west from the fireproofed tray section are adequately supported.
In response to an NRC request made during the meeting, Consumers co11DDitted to pe-rforming a review of recent design changes to identify the modification "which resulted in the attachment of specific conduit to trays located within the section to be fireproofed as part of the Auxiliary Feedwater Project.
According to Bechtel, this conduit was not part of the original design of the plant and resulted in additional loading on the tray supports~ The NRC staff requested that Consumers attempt to identify whether or not design controls were effective in ensuring that a structural analysis was completed for the conduit installation. In addition, Consumers co11DDitted to conducting final structural evaluations for the trays running east to west from the fireproofed
~ection.
In response to the NRC requests, Consumers performed the following:
- 1.
Bechtel was contacted to identify the specific conduit that had been reported as supported by the trays within. the fireproofed section.
Given the conduit designations, the conduit was identified on the applicable layout drawing and the revision record block was then reviewed in an attempt to identify a facility change which may have resulted in conduit installation. Unfortunately.. the drawin& depicted no such change.
Consumers is of the opinion, however, that Attachments 5 and 6 provide ample evidence of design control effectiveness for significant load addi-tions.
- 2.
Final structural (seismic and static) evaluations of the trays running east to west from the fireproofed section were completed (Reference 8) with. the results confirming the preliminary evaluations - that the tray supports are not overloaded.
As part of these evaluations, the raceway schedules were reviewed to identify the fill level for all of the trays in the IC Switchgear Room.
During this review of a sample of trays much larger than previously surveyed, approximately 13 trays were identified_
-!S being in excess of the original FSAR's 30r. limit; with the greatest fill level documented at 41% by cross-section.
IC0985-0666A-TC01
Prompted by this new tray fill information, a review of all trays within thP.
plant was conducted by referring to the raceway schedules.
The schedules reveal that__ap_proximately 8% of all plant trays are filled greate* than 30%.
and_?% of all plant trays are filled greater than 40% by cross-section.
- The, reatest individual tra fil den In an eftort to extract 4
a su set of the total plant tray population which represents trays carrying safety-related cable, the unique identifiers for the partitioned trays (ie, trays with a metal barrier separating one side of the tray from the other so as to separate individual channels of a particular safety train) serving the Reactor Protection System (RPS) cables were used.
Raceway schedules for these trays show that 12% of the RPS tra s are filled reater than 30% and 5% are filled greater t an with the greatest overall tray fill (ie, the fill considering both partitioned sides together) being 54% by cross-section.
Since the raceway schedules were observed to indicate that a number of trays are filled above 30% and the review also identified specific sides of c*ertain RPS trays being filled in excess of 100%, a walkdown was performed to visually
..i_nspect the trays and their supports.
Trays selected for inspection were those
- shown by the schedules to be those filled the most. Trays showing the greatest fills in the plant are RPS trays located in the Cable Spreading Room.
Inspec-tions conducted on two occasions (August 1 and August 19, 1985) of approximately five partitioned trays, having fills for a specific tray section ranging from 83% to 111%, revealed the following:
- 1. Although filled Rreater than 85% in a given section (per raceway schedule),
the trays showed no signs of their supports being overloaded.
There was no indication of the support struts breaking away from contact points on the ceiling nor evidence of support strut or tray deformation.
- 2.
There was no indication of cables overheating. All cables were comfort-able to the touch and temperature measurements with a probe inserted into the cable bundle showed a maximum temperature of 89°F (cables are typi-cally rated at 90°C).
- 3.
The as-built condition, with differs rom t e informat on contained in schedules.
The schedules for t e.trays inspected show one side of the partitioned tray to be filled in excess of 85% and the other side filled less than 5%.
Field inspection, however, reveals that in the case of several trays, both sides of the artition hav si ifica flpesifically, partitioned tray XR301 3XR301 is filled sides of the artition to levels above the
__ ra side-rails. The schedules show the tray sections to be filled to 106% and 1%, respectively.
IC0985-0666A-TC01
In response to the aforementioned observations, Consumers plans on taking the following actions:
- 1.
By November to have reviewed and analyzed those trays selected as "outliers" in terms of percent fill.
For these trays, analysP.s will be conducted to confirm that the trAy supports are capable of carrying the structural loads.
In addition, cables in the trays will be monitored to determine if overheating is occurring due to self-generated and ambient temperatures.
Finally, a review will be conducted to determine if the cables at the bottom of the tray can support the long-term dead weight.
It is expected that this work will be instrumental in reconfirl!ling that the plant trays and supports are capable of supporting cable for all expected or postulated plant conditions.
5
- 2.
On a schedule yet to be determined, which takes into account both avail-able resources and the importance of this issue, develop an administrative.
limit for cable tray fill and include the limit in appropriate design
---*control procedures. It is expected that the limit will be determined by performing a walkdown of representative tray systems and performing struc-tural evaluations of such syst~ms in order to correlate existing tray fills to reserve load-carrying capability of the tray supports.
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Upon completion of 1tem 2, either revise the ra~eway schedules such that identified fill reflects accurately as-built conditions or delete such information from the schedules.
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3.1,,1 IC0985-0666A-TC01
.v Reference List_
- 1. Letter from JIDotson (Bechtel) to TCCooke (CPCo), 7/16/84
- 2. Letter from RMKacich (Northeast Utilities) to WTRussell (NRC), 4/29/83
- 3. Letter from RMKacich (Northeast Utilities) to WTRussell (NRC), 8/31/83
- 4. Letter from RMKacich (Northeast Utilities) to CIGrimes (NRC), 10/15/84
- 5. Letter from DJVandeWalle (CPCo) to JIDotson (Bechtel), 6/24/85
- 6. Letter from JIDotson (Bechtel) to JSchneider (CPCo), 4/5/85
- 7.
Record of Telecon:
JIDotson to JCorley (CPCo), 6/10/85
- 8. Engineering Analysis EA-DR-ES-1, "Evaluation of Cable Tray Supports in Switchgear Room lC ***," 7/31/85 IC0985-0666A-TC01 6
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TRAY a CONDUIT LAYOUT 1001
.14 2
PROJECTS. ENOINEEFUNO ANO CONSTRUCTION PL.ANT MODIFICATJONS ANO MISCEL.L.ANEOUS PROJECTS ENOINEERING DEPARTMENT
- PROCEDURES Supplement S3-2.0 A'ITACHMENT B Page 5 of 8 Revision 2 Consumers Power FORMAT GUIDE DESIGN PLAN Date 4/19/85 *~.
4.1 DESIGN PLAN Provide a brief description of the scope to allow the Design Plan to be a atand alone document.
4.1.l Design Reference Documents Identify tbe docwnents by title and revision (and section where applicable) wbicb provide design criteria/constraints.
4.1.1.1 NI OSHA 4.1.1.2 Plant Technical Specifications 4.1.l.3 Codes 4.1.l.4 Standards 4.1.l.S Regulatory Requirements and Licensing Commitments 4.1.l.6 Re<Julatory Guides 4.1.l.7 Existing Plant Engineering Specifications 4.1.l.8 PSAR/PHSA 4.1.l.9 Bxisting Plant Functional Description 4.1.1.10 Existing Plant Q-List 4.1.1.11 Existing Plant Drawings 4.1.1.12 Environmental Control Standards 4.1.1.13.
Miscellaneous Correspondence 4.1.2 Design External Environmental Conditions Identify the external conditions which will affect items, systems, structures or component* in this design, such as ambient temperature, pressure, humidity, corrosion attack, radiation exposure, and flooding.
Discuss the effect and design considerations for auch conditions.
Also identify Environmental Qualification Teat requirements and evaluate the capability of the Trail Street Lab to perform the testing.
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PALISADES NUCLEAR PLAN.
Design Input Checklist
- 1. DESIGN REFERENCE DOCUMENTS Identify the documents or sections from which applicable design criteria/constrainu are given. Either reference or include such in the design package.
Applicable Reference A. MIOSHA B.
Technical Specifications
- c. Codes D. Standards E.
Regulatory Requirements F.
Regulatory Guides G. Plant Engineering Specifications H. FSAR I.
System Lesson Notes J.
0-List K. Plant Drawings L
Pipe and Weld Specs M.
- 2. DESIGN EXTERNAL-ENVIRONMENTAL CONDITIONS Identify-the external conditions which will effect Items, systems, structures or components in this design. Discuss the affect 1nd* design considerations for such conditions. Documented environmental qualification of harsh environment safety-related
-electrical equipment is required by Tech Spec Section 8.
Applicable Reference A. Pressure B *. Temperature
- c. Chemical/Corrosion/Protective Coatings D. Humidity E.
Radiation/Effect on Material/Personnel Exposure/Location or Rad Zone F.
Flooding G. Harsh Environment 10CFR50.49; IEEE 323-1974 H. Pipe Whip Inside Containment R!Sj Guide 1.46 I.
- 3. DESIGN STRUCTURAL LOADS Identify the structurel forces expected to be satisfied by this design. Discu11 considerations.
Applicable Reference A. Seismic FSAR A~e!ndix A B. Wind
- c. Thermal D. Dynamic E. Static F. Anchorage IE Bulletin 80-21 G.
- -'Ar BS-it. c~~
Form 3125 8-83 A Tl~CH P'> IL....,...,...3
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.*~company
- 1. Request for Modification (A FM)
- 2. Safety Evaluation
- 3. Design Reference Documents
- 4. Engineering Analyses (EA)
- 5. Interfaces Considered
- 6. ClA Requirements
- 7. Codes/Standards..
- 8. Procedural Requirements A.
Fabrication B.
Installation
- c. Test
- a. Acceptance b *..suMillance
- c. Preservice
- d. lnservice
- 9. Copies of Procurement Documents
- 10. Design Document Olectdist A. Admin Procedure Revisions B.
Working Procedure Revisions
- c.
Drawing Revisions D. Equipment Data Base
£.
Spare Parts List f'.
FSAR/FHSR
- 11. Implementation Phase A. Maintenance Order(s) * *
- B.
NOC Forms
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'\\00CL'E:Alf mw.aTJa~§ DEPARTMENT Specification Change Checklist Applicable YI!<
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- Specification changes shall not be closed out prior to closeout of all applicable maintenance orders.
'19rformed by Date Closeout Date Technal SuPt Technical Review Date Administrative Review Date K~r Bs*o.34 Technic:al Supt
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circuits and how separation is to be effected.
Scheme numbers and relay numbers are coded with odd numbers indicating Channel 1 and even numbers for Channel 2. The allocation for the power source is shown for each scheme.
The cables are routed by an er.gi-neer and printed by computer with the computer output being carefully reviewed.
The computer also prints a cable routing card and connection cards for each interconnecting cable installed in the plant. The cards are sent to the field as the offici~l in-stallation documents.
The routing cards are signed and ret11rned to the design engineer for record and to verify that cable was installed in accordance with the design.
In the field, the Bechtel Electrical Field Inspector checks that all cables have been pulled in as required on the routing card.
'!'he Bechtel Quality Assurance Engineer and Consumers Power Company Quality Assurance Engineer spot-check the routing of all reactor pro-tective and engineered safeguards cables.
The cable and wire connected to devices and instrumentation which are required to operate during a DBA has been proof-tested.to assure satisfactory operation through and following the accident.
Tray fill will generally be llm1ted to 3~ by cross section.
Tray fill greater.than 3~ by cross section is carefully re-.
viewed to assure that cable damage, either mechanical or thermal will not take place. In the case of large diameter cables,.
fill may exceed 30~ but will be limited to a single cable layer.
Conduit fill will be llm1ted to values as stated in Chapter 9 of the NEC.
Cables are installed in ventilated trays and are thermally sized, in accordance With IPCEA ampe.city values of three con-ductor concentric stranded rubber insulated cable in 40° C air tor the conductor operating temperature of the insulation.
It ambient temperatures above 40° C are encountered,* or mul-tiple power cables are in a tray, the cables are further de-rated as outlined by IPCF.A.
Cables installed in conduit are thermally sized in accordance with IPCF.A ampe.city values of three identical single-conductor cables in isolated conduit in 40° C air or three-conductor cable in isolated conduit in 4o° C air, depending on the cables used.
Cables are further derated if the ambient exceeds 40° C or when multiple power cables are pulled into a conduit.
8-26a
'*1lTJ'S'fr3.{
ArrAc11rn£1JJ 1 Rev 4/10/69