ML20116K678

Informs of Completion of Commitments for Items Associated W/Walsh/Doyle Allegations,Per Schedule Submitted W/ Nh Williams to Noonan,Including Punching Effects in Tube Steel Around Bolt Holes

ML20116K678
Person / Time
Site:	Comanche Peak
Issue date:	02/13/1985
From:	Williams N CYGNA ENERGY SERVICES
To:	Noonan V NRC
Shared Package
ML19283E951	List: ML20116K657 ML20116K678
References
NUDOCS 8505030354
Download: ML20116K678 (47)

Text

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101 CaWorfu Street. Sude 1000. San Francisco, CA 941115894 415 397 5600 i

February 13, 1985 84056.055 Mr. Vince Noonan US Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814

Subject:

Revision to Open Itmas Schedule Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program (all phases)

Job No. 84056

Reference:

M. H. Williams (Cygna) letter to V. Noonan (US NRC),

"Open Items Associated with Walsh/Doyle Allegations,"

84042.022 January 18, 1985

Dear Mr. Noonan:

A schedule for completing milestones associated with open review items was '.

attached to the above-referenced letter. To date, Cygna has completed the committments for the following items:

1. Punching effects in tube steel around bolt holes - Cygna letter _

84056.051 detailing open questions was submitted 1/29/85. i

- 2. Box frames with 0" gap -~ Cygna letter 84042.023 detailing open questions was submitted.1/28/85.

3. . Richmond Insert allowables and bending stress - Cygna letter 84042.025  :

detaill'gnopen questions was submitted 1/31/85.

4.,' Mass Participation / mass point spacing - Cygna letter 84042.021 ',

summarizing review results.and open questions was submitted 2/8/85. .

,. 5. Qualifications of welds in welded / bolted connections - Cygna letter 84042.024 detalling open questions was submitted 1/28/85. {'

850503035 850422 PDR ADOC 05000445 i A t PDR I

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Mr. Vince Noonan February 13, 1985 Page 2 We find it necessary to revise the completion dates for the following activities: ,

Original Completion Revised Completion 1  :

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Date Date Activity _

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Verification of as-built 2/11/85 2/19/85 cable tr y hardware against .

design drawing Verification of cable tray 2/19/85 construction drawings against . 2/11/85 design drawing 2/20/85 [.

Pipe support stability 2/4/85 Cinching of U-bolts 2/8/85 3/1/85 All other activities Tamain as shown in the original schedule except the issue of sizing of hardware for rotational restraints. TUGC0 has not provided a revised schedule for submitting their study to Cygna for review.

I We apologize for any inconvenience this schedule revision my cause; however.

the size of these issues has warranted more review than originally anticipated.

If you have any questions, please call at your convenience.

Very truly yours.

%4.1an N. H. W1111ans i

Project Manager .

l NHW/dri cc: 5. terwell I

• 5. Treby J..Ellis

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101 CeMorrua Street. Sude 1000. San Francisco CA M1115494 415 35#M600 February 19, 1985 84042.035 Mr. J. B. George Project General Manager Texas Utilities Generating Company Comanche Peak Steam Electric Station Highway FM 201 Glen Rose Texas 76043

Subject:

Stability of Pipe Supports Texas Utilities Generating Company j Comanche Peak Steam Electric Station Independent Assessment Program ',

Job No. 84042 3

References:

(1) N.H. Williams (Cygna) letter to V. Noonan (U.S. NRC),

"Open Items Associated with Walsh/Doyle Allegations," .

84042.22, dated January .18,1985. .

(2) N.H. Williams (Cygna) letter to V. Noonan (U.S. NRC),

" Revision to Open Items Schedule," 84056.055, February 14, 1985.

(3) Affidavit of John C. Finneran Jr. regarding Stability of Pipe Supports and Piping Systems, dated June 17, 1984.

(4) Cygna Phase 3 Final Report TR-84042-1, Rev.1 Novenber -

20, 1984

Dear Mr. George:

As comitted to in Reference 1 and subsequently revised in Reference 2. Cygna has completed an evaluation of the pipe support stability issue. This evalue-tion considered the support designs reviewed by Cygna as part of Phases.2, 3 and ,

4 as well as TUGCO's position described in Reference 3. Since stability is a very complex issue, we will sunmarize our position in six parts: (1) Definition of Stability (2) Dynamic Versus Static Stability. (3) System Stability, (4) i Commentary on TUSCO's Position.. (5) Classification of Cygna. Review Scope, and {

i (6) Conclusions. t i

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Mr. J. B. George February 19, 1985 Page 2 Definition of Stability Prior to performing an evaluation of this issue, criteria were developed to define what constitutes an unstable pipe support. Individual pipe supports can be classified into two broad categories: (1) supports which, in the total ,

absence of the pipe, are stable, and (2) supports which, in the total absence of the pipe, are unstable. Implicit in our definition for the second category is ,

the fact that the instability is a rigid body type which my be coupletely removed or acconenodated by proper attachment to the pipe. That is, by restrain-ing certain degrees of freedom at the attachment to the pipe, such as with a pipe clamp, the instability my be removed. Alternatively, by limiting the ,

motion following instability through the presence of the pipe and adjacent ,

I supports, the instability say also be eliminated. Since there is no stability issue with respect to supports of the first category, only supports of the second category need be discussed.

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'In order for a support of the second category to be stable, there are two requirements to be inet, one involving force transfer between the pipe ud support and the other involving the geometric relationship between the pipe and support. The force requirement is met if adequate forces, which develop instantaneously and can be relied upon by design, exist between the pipe and the i support hardware to resist the factored load. The following definitions are provided for clarity:

e develop instantaneously (imediately): Resisting forces are activated at the same instant that piping loads are applied. An -

example of forces which cannot develop insnediately are binding ,

forces which require a rigid body motion of the support (rotation, translation) to become effective.

• by design: The mechanism for and magnitude of the resisting forces are calculatable and known, or have been evaluated exten-sively by test or by use in the specific application.

. ne factored load: Applied load times a safety factor.

In addition to the above described force requirement, the geometric relationship between the support and the pipe must remain within set limits during the operational life of the plant. If sufficient clamping forces between the pipe and support are not present, small pipe movements my cause large changes in the position of the support relative to the pipe. Piping system vibration occurring ,

during start-up, normal operation or shut-down can cause the support to move (rotate, translate) relative to the pipe. This support movement is unfavorable if, for a support initially perpendicular to the pipe, the direction of pipe

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O M_E ss C Mr. J. B. George  :

February 19, 1985 page 3 movement in the absence of the support is such that the displaced centerline of '

the pipe intersects the arc mde by the rigid body motion of the pipe center

• within the support. The new position of the support on the pipe my be well outside the displacement (eccentricity) envelope for which it was designed and -

for which stability has been assured. Since the support did not restrain the i movement of the pipe during this process, adjacent supports must now resist an  !

additional load for which they my not be adequate. Therefore, a sufficient condition for individual pipe support stability of the second category is a t design in which, upon the application of the factored load from the pipe, adequate resisting forces can be developed imediately and the position of the

• support attachment on the pipe does not move relative to the pipe with time.

'Considering the definition presented above, we will now discuss some specialized situations in which the instantaneous development of resisting forces required ,

i for stability does not occur. For these designs momentary instability (of the rigid body type) could be tolerated, provided that it can be demonstrated that sufficient forces eventually develop to completely remove the For instability example, (i.e.,

stop the motion and allow-the support to function as designed).

when considering the instability of a support which requires the development of binding forces to ultimately naintain stability, one could assume the support does not act and then determine the resulting pipe deflection in the released direction. If that deflection is a sufficient multiple (say 4) of the deflec-tion required to develop the necessary binding forces, it then becomes ,

appropriate to further investigate the- ability of the support to resist both the binding force and the applied load. During such an investigation, it is essential to demonstrate that the binding force mechanism possesses both sufficient strength and stiffness. In other words, while certain designs my exhibit sufficient strength to develop and resist the necessary binding forces, they may not posssess sufficient stiffness to limit the rigid body displacement and thus resist' the applied load. The alternative to this approach is to limit .

the consequences of the instability. This could be accomplished by showing that i the piping and remaining supports are acceptable in the absence of the unstable support. In either approach, before the design can be considered satisfactory, pipe stresses and other support reactions must be checked for the new displace- '

ments occurring at the support and the pipe must be checked for the effects of

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the . binding . forces.

Dynamic Versus Static Stability _

The proceeding. discussion addresses only stability due to statically applied  ;

loading. The question arises as to whether a support could be unstable l statically under the application of eximum load, yet stable when the same load

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1s applied. dynamically. This is a very complex analytic problem to resolve i which is further complicated by the fact that the eximum loading on a pipe i

_ _ _ . . _ _ _ _ _ _ . _ . _ _ . _ . _ . ~ _ _ _ _ _ _ _ _ _ _ _ . _

E*E . n Mr. J. B. George February 19, 1985 ,

Page 4 support is generally some combination of static and dynamic loads. Cygna is unaware of any established precedent for the acceptance of statically unstable '

In some cases dynamic loading can contri-supports based on dynamic arguments. The time bute to pipe support instability rather than helping ~to preclude it.

phasing of static and applied seismic (random) forces to Therefore, can either exacerbate or demonstrate alleviate individual support instability. I analytically that a statically unstable support is dynamically stable would require an extensive evaluation using large nonlinear dynamic models and time- l history analyses. Add to this the variety of possible geometric configurations .

i and input motions ~that must be considered, as well .as the existence of static l system preload (dead load plus thermal), and the problem becomes extremely costly to evaluate. This is a particularly unfavorable approach in view of the potentially inconclusive nature of the results.

For anny of the same reasons stated above, any testing program developed to prove dynamic stability would also have to be very extensive. Tests which are severely displacement limited and sinusoidal (non-random) in nature can only prove that a support is ' stable under small amplitude displacement sinusoidal input.: Such tests would not necessarily demonstrate stability.under conditions which reflect the real nature of the random input motion.

System Stability i Generally, the term system stability is associated with the arrangement of a structure's restraint configuration such that it is not possible for the struc-ture to undergo rigid body motion. We will refer to-this as geometric stability. With respect to piping systems, geometric stability is assured when

.a pipe stress computer analysis is successfully executed. This computer analysis would have detected a system of supports which does not restrain each of the three translational and three rotational global degrees of freedom.

Encountering such a geometrically unstable system is an extremely rare situation since almost all piping systems contain some type of anchor (e.g., equipment nozzle, penetration, structural anchor, etc.). .

When discussing system stability as it relates to pipe support stability, the I najor concern is the ability of the piping. system to provide the appropriate i stabilizing restraint for each support. This type of global stability can only be assured if each support is individually stable in its own right, either j through its design (supports of the first tategory) or by adequate attachment to yI the pipe (supports of the second category). If individus1 support stability is .i*

i not assured, system stability is not guaranteed. The instability of one support can trigger the progressive instability of adjacent supports by causing the -

limits of the forces and tHsplacements to which the adjacent supports were  !

. originally . designed to.be exceeded. This may result in the-formation of plastic l

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Mr. J. B. George  !

February 19, 1985 Page 5 hinges in the pipe (due to overload) which in turn my develop into a collapse ,

mechanism. . This situation would not, however, prevent successful. execution of a linear, elastic pipe stress computer analysis.

Demonstration of system stability by removal of an unstable support from the system and subsequently showing that each remaining support can resist the new forces is not sufficient by itself. In addition, it should be shown that I removing the unstable support does not affect the stability of other supports. i That is, overall systam stability should be reevaluated in the absence of the removed support.

Commentary on TUGCO's Position Cygna has reviewed the Reference (3) Affidavit using the criteria described above. The Affidavit (pages 2-8) discusses system stability and its relation to individual support stability. In it. TUGC0 states:

"In addition, if the total support. scheme does not provide proper nultidirection support required by the piping configuration, the analyst will be unable to successfully run the piping analysis computer program (see Tr.12025 (Bjorknan testimony)). In summary, '

the piping analyst assures the stability of the piping system by limiting deflections, which negates any need to assess stability ,

separately."

Cygna agrees with the first statement, since this is our basic definition of geometric stability. The second statement, however, does not follow. A piping ,

analyst does not limit deflections to those required to assure system stability, since, in general, these deflections are not known. Rather, the analyst inprts i' asch support as a~ restrained node and reports the resulting deforations to the designer for consideration. Therefore, the issue is not piping system stability, but rather the stability of the individual support itself. The 4:ey point is whather the individual support can resist the applied load within the J

initial eccentricities and displacement limits imposed upon it.

The:. stability issue:is best illustrated in Figure 1(c) of the Affidavit (page  !

4). _The concern is not whether an adjacent support can provide a horizontal reaction component (since it is.already. known by analysis that it can and the j l -

.syst.em is geometrically stable), but rather whether the clamp (U-bolt) can I provide sufficient resisting forces to prevent rotation of the clamp (U-bolt)  !

.about the pipe or slippage along the pipe axis. If the clang (U-bolt) cannot Frovide sufficient resisting torque, the. individual support is unstable and  !

system stability as well as progressive support instability must be re-  :

evaluated.

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Mr. J. B. George '

February .19.1985 Page 6 1

Of the specific support configurations discussed in the Affidavit, the most unique is the box frame with zero-inch gap attached to a single strut-or snubber (Affidavit, page 9). This is unusual because it relies solely on the relative thermal expansion between the pipe and frame during normal operation to create claging forces. The resulting frictional forces which resist support rotation  :

around the pipe and translation along the axis of the pipe would stabilize the 1 support. The lower bound value of stabilizing frictional force which exists over the operational life of the plant was never determined either analytically ,

i or by test. Furthermore, since claging forces do not exist at ambient condi- l tions, it is possible for the support to move (rotate.and translate) relative to j

-the pipe. ~ This movement of the support could be caused by normal vibration during start-up, operation or shut-down, combined with pipe thermal translation compatible within the rigid body displacement envelope of the support. -

Subsequent to this movement the support may be in a position on the pipe which is outside of the displacement range for which it was designed and for which stability could be assured. Furthermore, due to the compatible rigid body motion of the pipe and support, the support would be unable to restrain the therm 1 movement (load) for which it was designed and adjacent supports would have to resist this load - a load for which they were not designed. This situation pay also develop at temperatures above ambient since the maintenance of zero gap over the life of the plant could be difficult to achieve. Fo- these reasons, Cygna classifies these supports, without modification, as unstable. ,

In Figure 4 of the Affidavit (page 13) three methods are shown which have been utilized to modify the box frame supports to improve their stability. Two of  :

these methods, " indexed lugs" and " additional struts" only provide rotati:ral stability. They do not prevent translation of the support along the axis of the pipe with time. Therefore both of these nodification schemes result in supports which must still be classified as unstable. The third modification scheme. .the addition of cinched U-bolts, can prevent both rotation and translation of the support provided it can develop sufficient lower bound clamping forces. Since the final evaluation on the use of cinched U-bolts tas not been completed, the acceptability of supports with this configuration remains an open issue at this  :

4 time.

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l . Cygna classifies .all single struts with'U-bolts and a thermal gap (Affidavit,

' page 15) as unstable since the stability of this type of support has never been analytically or experimentally demonstrated. Cygna understands.that all of j these-supports' have been modified in an effort to enhance stability (Affidavit,

.page 18). These modifications consist of either cinching the U-bolts or adding  :

supplementary steel that would prevent the rotation of the U-bolt crosspiece. .

Cygna believes we have adG t sad those supports for which supplementary steel

- was added to create "stabdt:y bumpers" in Reference (4) Observation PS-02.

- Cygna found these bumpers unacceptable since there were no calculations to I

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Mr. J. B. George

• February 19, 1985 '

Page 7 demonstrate that they possessed sufficient strength and stiffness to mintain stability. The stability of the supports which were modified by cinching the U-bolts reamins open as par.t of the.U-bolt analysis / testing program.

Double strutted frames (Affidavit, page 19) supporting two or more pipes were not encountered during any of the Cygna review phases. However, Cygna did find examples of double strutted frames supporting a single pipe and double strutted trapeze supports with U-bolts, which are configurations similar to those discussed in the Affidavit. As previously discussed for single strutted frames, both the double strutted frames and trapeze supports with uncinched U-bolts  ; i suffer from the problem of not having the demonstrated ability to maintain their '

relative position on the pipe over time. In addition, the double struts cannot be relied upon to resist compressive load until the frame (U-bolt) has rotated about an axis parallel to the struts and has bound itself in a cocked position against the pipe. 'Neither the stiffness requirements of the frama (U-bolt) necessary to maintain a stable position nor the binding forces and displacements required to restrict the unstability have.been. evaluated. Cygna .therefore classifies these supports as unstable.

In the case of double strutted trapeze supports with cinched U-bolts, the most likely mode of instability is that due to rotation of the support about an axis parallel to the. struts. If the frictional resistance between the pipe and the '

. trapeze crosspiece is not sufficient, the frictional bond will be broken and the entire destabilizing twisting moment must be resisted by the bending strength (and stiffness) of the U-bolt binding against the pipe. Since neither the frictional forces nor the U-bolt have been evaluated for their capability to resist this nonlinear destabilizing moment, Cygna classifies this configuration as unstable. '

. l The stability of a single strut or snubber with a cinched U-bolt (Affidavit, l page 27) is directly related to the resolution of the issue of U-bolts used as

' pipe clamps. Until the resolution of that issue, which includes the satisfac- l tory determination that lower bound preloads can provide the clamping force necessary to resist the factored piping loads, Cygna considers all.such. supports to the unstable.

Classification of Cygna Review Scope Cygna has examined the 226 pipe supports within the Phases 2, 3 and 4 review t scope. Thirty-seven supports were identified as supports which, in the total absence of the pipe, are stable. Of the remaining 189 supports which in the absence of the pipe would be unstable,124 possess sufficient positive attachment to the pipe to ensure stability. The 65 potentially unstable supports my be classified as follows:

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Mr. J. B. George February::19,1985 i Pa ge' 8 ,

• Single strut with box frame or cinched U-bolt (23)

• Double strut trapeze with cinched U-bolt (25)

• Multi-strut box frame (8)

• Single strut with uncinched U-bolt, stability bumpers (2)

• Double strut, double trunnion with cinched U-bolt (1)  !  !

• Double strut trapeze with box frame (2) , l

• Double strut trapeze with uncinched U-bolt'(3) '

• Triple ^ strut box frame (1)

There are two reasons for classifying these supports as unstable: 1) the  ;

unconventional methods used to develop the restraining forces between the pipe and the support, and 2) the lack of any demonstration that the restraining forces developed by these supports are sufficient to maintain the support s stability. Supports which are designed with cinched U-bolts to provide the necessary positive connection to the pipe may be reclassified as stable if the

~ U-bolt testing / analysis program and the application of the results to the individual supports in question is found to be. acceptable. Jt should be noted, ,

however, that.this program does not address the stability of supports which do not use U-bolts, nor does it evaluate the twisting strength of U-bolts used in trapeze supports.

Conclusions ,

Throughout this letter, Cygna has applied a very rigorous definition of rigid body instability. Cygna recognizes from a practical standpoint that many of -

these potentially unstable designs my actually perform their intended function. However, we also recognize that the inability to quantify the actual behavior. which nay help' stabilize the support in practice _ necessitates that stability be viewed under more idealized conditions. For that reason the individually unstable supports identified above, and any similar configurations throughout the plant, should be evaluated using.one of the following approaches:

e Modify togrovide adequate restraint at the pipe / support

. connection

.* Demonstrate system. stability in.the presence of the unstable

. supports

• Quantitatively show that_the individual supports are stable I

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Mr. J. 8. Gearge

• February 19, 1985 Page 9 .

Please call to discuss any questions or clarification necessary since this is a ,

complex subject.

I.

uly yours.-

M.H. W1 ams Project Manager s i

feui/ajb cc: . S. Treby (U.S. NRC)

.S. .Burwell (U.S. NRC)

V. Noonan (U.S. NRC)

D. Wade (TUICO)

J. van Amerongen (EBASC0/TUGCO) j R. Ballard (G8H)  ;

J. Ellis (CASE)

D. Pigott-(Orrick; A iington & Sutcliff)

J. Finneran (TUGCO)

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101 Cahtorru Street. Sune 1000. San Francrsco, CA 941115894 February 20, 1985 84056.056 Mr. J. B. Secrge -

Project General Manager ,

Texas Utilities Generating Company .

Comanche Peak Steam Electric Station  ;

Highway FM 201 Glen Rose, Texas 76043

Subject:

Cygna Attendance at NRC Meeting: 2/26-2/28.and 3/5-3/7 .

Comanche Peak Steam Electric Station Independent Assessment Program - all phases Job No. 84056

Dear Mr. George:

It is Cygna's understanding that the NRC has scheduled a series of meetings with TUGC0 in.the next two weeks. to discuss the results and status of the staff reviews. The NRC has indicated that many of the proposed topics overlap Cygna's earlier findings, open items. and/or on-going work activities.

To ensure that Cygna fully understands 1UGCO's position on certain subjects and  !

to eliminate any possible duplication of questionc. which may have been asked by the NRC, Cygna proposes'to attend these meetings is part of the Phase 4 work i; ,

unless instructed otherwise.

Please advise me if TUSCO does not w, i sh to have Cygna representatives attend.

Very truly yours, ,

j N. H. Willians ,

Project Manager cci D. Pigott (Orrick, Herrington &'Sutcliffe)

V. Noonan (U.S. NRC)

5. Burwell (U.S. NRC) 5.Treby(U.S.NRC)  !

D. Wade (1UGCO)  ;

J..vanAmerongen(TUGCO)

.J. Beck.(TUGCO) l L

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b1 CaMoma suest, Saite 1000. San Francisco CA 941115894 415 357 563:

March 12,1985 84056.058 J.

Mr. J.B.. George ,

. Project General Manager Texas Utilities Generating Company ,

Comanche Peak Steam Electric Station ,

Highway FM 201 Glen Rose, Texas ,76043 Phase 4 Open Items - Punching Shear

Subject:

Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 Job No. 84056 i

References:

1. N.H. Willimas (Cygna) . letter to J.B. George (TUGCO), " Phase Open Items - Punching' Shear;"~.84055.053

2. Teleton dated February 26, 1985 between J. Finneran (TUGCO) and J. Minichiello (Cygna)

Dear Mr.-George:

In the attachment to the referenced letter, Cygna 1 questioned the use of A punching shear methodology for tube steel with holes.betwee element analysis used by Cygna to eraluate.the application of the AWSAltho methodology. These calculations are enclosed. Also, these. calculations not included, it man be.provided upon request.Cygna did represent a study only. We not attempt to re do feel-the naximum stresses; since our interest was stresses orer a

..punchingahear. in tube steel. i l (

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W .'J.B. George W.t r:h 12, 1985 Pags 2.

If yo:; hwe'any questions or wish to discuss this data, please- do not hesitate I: call .

Very truly yours. -

'f4]idk &

N.H. Williams Profe:t Manager ,

NHW/ajb A-tachment ec: tir. J. Finneran, w/ attachment Nr. D. Wade, w/o attachment Mr. V. Noonan, w/o attachment Mr. S. Treby, w/o attachment Mr. S. Burwell,- w/o atta;.i.=4.i.

Mrs. J. Ellis, w/o attacnment 9

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Cygna Letter B4056.058 i

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. D GNA CALDE.ATI E FILE 84056-95 i

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1 sess 415 397-5600 101 Cahtornia street. Suite 1000. san Francisco. CA 941115894 i

March 25, 1985 84042.036 Mr. J.W. Beck Manager - Licensing Texas Utilities Generating Company Skyway Tower i

400 North Olive Street <

L.B. 81 Dallas, Texas 75201 i c

Subject:

Phase 3 Open Items - Cinching of U-Bolts i l

' Texas Utilities Generating Company  !

Comanche Peak Steam Electric Station  :

. Independent Assessment Program ,

Job No. 84042

References:

See Attachment 1 for a List of References  !

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Dear Mr. Beck:

As comitted to in References 1 and 2, Cygna has reviewed allThis theinformation information provided by TUGC0 on the U-bolt cinching evaluation program.3, 4, 5, 7, 8, 10 and 11 only. i consists of the documents listed in References Cygna has previously issued questions on the testing / analysis program in Refer-We have reviewed both our earlier questions and all data sup-ences 6 and 9. A summary of our remaining questions is . contained in this plied by TUGCO.

letter.

Throughout our review of this program, Cygna has asked questions which are interrelated.- For example, questions 6, 12, 18, and 19 from Reference 6 were discussed as a single issue during the TUGC0/EBASCO/Cygna meeting on September 13, 1984. Thus, it is not possible to address any individual question without Cygna's under- .

considering the implications of the response on other questions. ,

lying concerns, which must be addressed in any response, are: ,

l (1) Has the test considered.the worst orientation of the U-bolt / strut.when attempting to demonstrate stability? !l i

Does the test show that the U-bolt is capable of maintaining  :

(2) the support in a stable configuration at the minimum.preload l over the operating life of the plant?

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Has TUSCO established a torque.vs. preload relationship which '

(3) will ensure that the torque used in the plant will- guarantee I the minimum preload required for stability?

I i SanFrancisco Boston Ctucago Rchtand l

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u i Mr. J.W. Beck  :

l March 25,.1985 Page 2 Has TUGC0 shown that the stresses in the pipe due to the (4) maximum possible U-bolt load (for the torque chosen) are acceptable under.all conditions of temperature, pressure, and applied load?

Cygna's remaining questions and concerns related to each of these four areas ar detailed in Attachment 2 to this letter.

(References 10 and 11), Cygna reviewed the entire set of references once more' toi detemine if all our concerns had been addressed. In this attempt to trace the path from the testing through the analysis and finally to the actual in-plant data, Cygna has concluded that we are unable to close out the four basic con- l' cerns at this time. We suggest that while we are transmitting these questions via letter, a meeting may be the most expeditious way to discuss these questions and to provide any required clarification.

This letter completes Cygna's connitment listed under Item 1 of the OpenIfItems you List attached to Reference 1 and subsequently updated by Reference 2.

have any questions or wish to liiscuss the subject, .please. call.

Very truly yours, m,0.1& uduua N.H. Williams Project Manager ~

NHW/ajb Enclosures cc: Mrs. J. Ellis Mr. S. Treby Mr. S. Burwell j Mr. V. Noonan Mr..J. Redding l i i

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1 EM 84042.036 Nr. J.W. Beck Fa ge 1 ,

Marcn 25,1985 ATTACl9 TENT 1 Cygna Coments/ Questions Related to the TUGC0 U-Bolt Cinching Program

References:

1. N.H. Williams (Cygna) letter to V. Noonan (USNRC), "Open 1 l

Items Associated with Walsh/Doyle Allegations," 84042.022, dated January 18, 1985

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Revision to Open Items Schedule," 84056.055, . dated February 14, 1985

3. Affidavit of Robert C. Iotti and John C. Finneran, Jr.,

regarding Cinching Down of U-Bolts (received July 12,1984) 4.. Westinghouse Electric Corp. Report EQ&T-EQT-860, Revision 0,

" Comanche Peak Steam Electric Station U-Bolt Support / Pipe Test Program" (received ~ July 12,1984)

5. Westinghouse Electric Corp. Report entitled " Comanche Peak Steam Electric Station U-Bolt Finite Element Analysis", dated June 12,1984 (received July 112,1984)

6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "U-Bolt Cinching Test / Analysis Program - Phase 3 Open Items,"

B4042.015 dated August 23, 1984

7. Transcript of Meeting between Cygna Energy Services and Texas Utilities Generating Company and Ebasco Services Inc. dated September 13, 1984

8. R.C. Iotti (Ebasco) letter to N.H. Williams (Cygna),

" Additional Information as Follow-Up to Meeting of 9/13/84,"

3-Z-17 (6.2), ETCY-1, dated September 18, 1984

9. .. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Status of Cinched U-Bolt Testing and Analysis Program " 84042.018

. dated October 1,1984 l

'10. ~ ~J.B.- George (TUGCO) letter -to N.H. Williams (Cygna) dated November 1,1984, " Cinched U-Bolt-Testing and Analysis i

Program- Additional Information"

11. J.B. George (TUGCO) letter to N.H. Williams (Cygna) dated November 16 1984, " Cinched U-Bolt Testing and Analysis Program - Additional Information" l

t l

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ER V,-,,

.,m Mr. J.W. Beck. 84042.036 '

March 25,1985 Page 1 ATTACl9 TENT 2

- Cygna Coments/ Questions Related to the \

TUGC0 U-Bolt Cinching Program (1) Reference 4 (Page 7)

a. Was any special cleaning done to the U-bolt threads prior l to the test? It is Cygna's understanding that torque will be used in the field to achieve the desired preload, therefore, the condition of the threads is important.

b. What procedures will TUGC0 employ to ensure that the condition of the threads in the field is representative of the threads in the tests?

(2) Reference 4 (Figures 2 and 3; Appendix II)

a. A ten-inch U-bolt (#1) with the same backing plate was used for both the 10-inch Sch 80 and 10-inch Sch 40 torque tests. Cygna has noted a large (50%) difference in preload values between the two tests for the same torque. Please explain why these large differences were predicted for the same U-bolt. One of these tests may not properly represent field conditions.

t. The same 4-inch U-bolt (#1) was used for all 4-inch tests except the friction test. While this' m y be beneficial in that it provides data for one bolt under various con-

-ditions, it has a drawback in that- the possible yielding in the threaded-region at 60 foot-pounds in the first test may affect the results of later tests. If yielding did occur in the threaded region during the first test.

what impact does it have on the conclusions of later tests which used this same U-bolt?

c.' A conforming fit e s achieved at:35 foot-pounds in the first test (page 8 of Reference 4). As noted by TUGC0 in Reference 3, page 74, they pisn to use 25 foot-pounds of

-. torque in the field (which they note will ensure perfect ;_

contouring). Please discuss the discrepancy between the field planned conforming fit (20 - 25 foot-pounds) and-the controlled. test conforming fit (35 foot-pounds). ,

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$4ewstf8 84042.036 )

Mr. J.W. Beck Page 2 l

-March 25,.1985 t

ATTActMENT 2 t

Cygna' Coments/ Questions Related to 'the '

)

TUGC0 U-Bolt Cinching Program 1 (3) feference 4 (Figures 9 through 12)

Of more importance than slip force versus torque is slip force versus preload, since preload is what must be generated to resist slip. Cygna notes this as a coment and realizes this can be ,

derived by . combining these figures with the data from Reference 10.

(4) Reference 4 (Page 52)

There are a number of items concerning the 4-inch U-bolts which '

require clarification.

a. A comparison of the preload prict to a cycle (shown on page 52) to that at the end of the stae cycle (Figure 21) nay be sumarized as follows:

-Cycle 1 End = 7700 lb Change = 1800 lb Leg 1: Prior = 5903 lb Change = 1100 lb Leg 2: Prior = 6292 lb End = 7400 lb Cycle 10

~End = 6900 lb Change = 2600 lb Leg 1: Prior = 3271 lb Change = 1800 lb Leg 2: . Prior = 4529 lb End = 6300 lb This indicates that'.the system became stiffer as the  :

cycles progressed. Does this indicate the U-bolt in the '

threaded portion-has-been affected by strain-hardening 7 Please explain. I

b. . The 3271-Ibload in Leg 1 prior to Cycle 10 appears in-correct when compared to the 4871 lb load prior to the creep test (Reference 4, page 65) or the 4854 lb load after the creep test (page 66). Yet, it appears that  !

i 3271 lbs is used in arriving at the 641 noted~ on page 23 1

of: Reference 3,:as-follows: i 6292 Average load prior to Cycle 1 = 5%3 =16098 lb Average Load prior.to' Cycle 10=.3271 4529 = 3900 lb New Load

• 3.96.1 * *0 Old Load l

i 4

ces 84042.036 ,

Mr. J.W. Beck Pa ge' 3  ;

March 25, 1985 ATTACNtENT 2 .

Cygna Coments/ Questions Related to the I

'TUGC0 0-Bolt Cinching Program If the 3247 lbs load is a correct data point, please explain .why it is reasonable in light of the later creep l test data, for which there was no retorquing of the l U-bolts. .

(5) Reference 4 (Page 68 and Appendix II) l

a. TUGC0 has emphasized the fact that preloads which stress On the U-bolt above 1/2 yield will relax to 1/2 yield.  ;

page 12 of Reference 3, TUGC0 states:

"Hence the effective torque for all pipe sizes will be the lesser of the value cor-responding to a U-bolt stress of half-yield or. the value achieved by a nan -with a tor-que wrench or impact wrench."

However, in Reference 10, question 4, the first sentence reads:

"There is scant data available on strain relaxa' tion properties of SA-36 material."

Based on data from page 68 of Reference 4, the shank area of 4-inch U-bolt maintained a stress between 32 and 34 ksi for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with little indication that l the stress decreased. What is the basis for the statement that the U-bolt will relax to 1/2 yield, since l there is scant data available? Please explain the lack j of relaxation in the 4-inch U-bolt .during the creep test, when the U-bolt was at 445"F.-

b. The U-bolt used on the 4-inch pipe ,in the Therm 1 Cycling ,

and Creep Tests had already been used in the Torque ver-l sus preload Tests and the Friction Polishing Test. The  :

l- U-bolt used on the 10" Sch 40S pipe in the Theral Cy- 'l

( 't: ling and Creep Test had already been used in ~the Fric-

. tion Test. Please explain how the relaxation data ob-tained from tests on "used" U-bolts will be related to Separate the " unused" U-bolts installed in the field?

relaxation tests on-unused U-bolts would provide a more sound basis for evaluating the relaxation characteristics of U-bolts.

I

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$$n . 84042.036 Page4 g Mr. J.W. Beck March 25,1985 ATTACIMENT 2 Cygna Coments/ Questions Related to the TUGC0 U-Bolt Cinching Program (6) Reference 5_ (Page 25)

What was the basis for using a coefficient of friction equal to 0.167 The minimum coefficient of friction from Reference 4 wasBy using a v 0.12, which is also noted in Reference 3, page 18.

which is 331, higher than the minimum, the analytically determined be required for the worst case friction coefficien test.

(7) Reference 5_ ~

From a review of the U-bolt finite element analysis, Cygna has the following general questions:

a. The various finite element meshes used elements However, the circum-ferentially spaced at equal 10* intervals.

longitudinal element spacing is apparently not given in the report.

For each of the four pipes analyzed, please provide the longitudinal dimensions of the first fiveele .

U-bolt,

b. On page 26, the " error" in the finite element results

- with respect to a theoretical solution versus mesh errorsize in is plotted. What " error" is being measured:

stresses; error in . displacements?

l Reference 5_ (Pages 12,13,19, 67, 73, 74 and 79) i (B) ,

The U-bolt finite element analysis reports element centroidal stress l results for various elements adjacent to and in the vicinity of the *l contact region of the pipe and crosspiece, and the pipe and U-bolt. .'

It is these centroidal stresses which are used by TUGC0 in-theirF l

-evaluation of the pipe stresses. ~

ment results for the.10-inch.Sch A05 pipe, Cygna has the following comments and questions:

.a. The caption for Figure IV-1-indicates that the finite element mesh shown in the figure is applicable to 4-inch Sch 40S, 10-inch Sch.405, and 10-inch Sch 80 pipe support l finite element models.- This figure shows three elements in the meridional (longitudinal) direction'from the centerline of the U-bolt.to the edge of the crosspiece.

I

1 s_

uenus 84042.036 '

ttr. J.W. Beck Page 5 March 25, 1985 ATTACNIEMT 2 Cygna Comments / Questions Related to the TUGC0 U-Bolt Cinching Program The figures on page 67 and 79 also show three elements beneath the crosspiece. However, on page 73 only two elements are shown beneath the crosspiece of the 10-inch Sch 40S pipe. The only difference between the geometry l

of the 10-inch Sch 40S pipe and support, and the 10-inch Sch 80 pipe and support, is the thickness of the pipe and -

tne mean radius.

Neither of these differences requires '

Is the changing the meridian dimension of. any element.

mesh coarser beneath the crosspiece of the 10-inch Sch 405 pipe. or is page 73 in error?

b. Based upon the fundamental shell parameter /Rt , which is used to determine the relative rate at which bending stresses decay, Cygna believes that the finite element mesh used for the 10-inch Sch 405 pipe my be too coarse.

This is particularly true of the spacing in the longitu-dinal direction which may not predict with reasonable accuracy (5 to 10 percent) the maximum ~ stresses occurring in the pipe due to contact with the cross piece. The 10-inch Sch 405 pipe is the most highly stressed of all the pipes analyzed, yet relative to the three other pipe finite element meshes, the 10-inch Sch 40S mesh is the coarsest in the region of high stress. This can be seen in the table below, where the number in the last column - '

is related to the coarseness of the mesh.' The higher the -

number, the coarser the mesh, and, therefore, the lower its potential accuracy relative to the other meshes.

Element Radius, R' Thi ckness, -t length, L* 1./(Rtf/2

. Pipe 1.03 0.56" 0.55

- 4":.Sch 160 1.98" 0.531" 1.38 1.00"** 0.73 210" Sch 40S 5.19" .0.365" 0.43 0.594" 1.74 0.75" 10" Sch 80 5.08" 1.50" 0.32

.4.71-32" ' 15.28" .1.450"

• - Estinated longitudinal dimension of element adjacent- to U-bolt. Scaled from Figures IV-1 and IV-3.

• • - See question (8)a.

In view of the coments above, please provide the basis for determining the longitudinal spacing of critical elements. - Were any mesh convergence studies conducted I

which are relevent to .this specific type of _ geometry and l I i

l-

~P sievacil 84042.036 Mr. J.W. Beck Page 6  ;

March 25, 1985 ATTAD9qENT 2

. Cygna Comments / Questions: Related to the j TUGC0 U-Bolt Cinching Program i loading and which show that the meshes used reasonably predict the stress field in the pipe.

c. The centroidal stresses reported from the U-bolt finite element analysis and utilized by TUGC0 are not a true measure of'the eximum stresses 'which occur in the .

pipe. In the case of the 10-inch Sch 40S. pipe, Cygna ,

believes that the use of element centroidal stresses underestimates the maximum pipe stresses occurring near the crosspiece by between 25 to 50 percent for the rea-sons explained below. .

Element centroidal stress results, even when accurate at the point at which they are reported, are dependent on the geometry of the mesh:(i.e., location of the. element centroid). While element centroidal stresses are not naximum stresses, they do define a stress field and can be used to predict maximum stresses by extrapolating them to the boundaries of the-elements. Alternatively, stresses at the element integration points can be extra-polated. If the NASTRAN program does not evaluate ele- i ment nodal stresses or if it cannot develop extrapolated stress contour plots, then hand extrapolation techniques should be used to determine the maximum stress at the contact between the cross piece and the pipe.

If the element centroidal stresses are not the maximum stresses in the pipe, please provide justification for their use in evaluating the pipe.

(9) Reference 5 (Page 43)

a. According.to the analysis report on the Thernal Test /

Analysis:

"The [ pipe] skin' temperature was held constant i until the pipe hanger reached: equilibrium."

-This is Jilso.noted..on.page 15 of Reference 5:

" Steady state temperature distributions were '

• obtained from tests . . ."

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64042.036 -

Mr. J.W. Beck Page 7 .

March 25,.1985 ATTACMtENT 2 Cygna Coments/ Questions Related to the

-TUGC0 U-Bolt Cinching Program Steady state say not represent the worst condition ofThe -

thermal constraint between the U-bolt and the pipe.

worst condition could occur when a pipe at ambient tem-perature (for example, the RR system) suddenly expe-riences a high temperature due to rapidly flowing fluid ,

(for example, during initiation of Rm at 350*F in cool '

down). This would cause the pipe to heat very . rapidly -

and, at some point, be at a much higher temperature than the U-bolt. The " thermal cycling" for such a transient

.is shown in Figure 1. Contrast this with the data shown in. Figures 21 through 24 of Reference 4, which only shows the load at steady state. The analysis should be based y

on the neximum stress in the cycle, not the steady state result. What effect would this have -on the conclusions stated in the analysis?

b. ~The more critical cor011ary-to theeve is the condition whereby the pipe,- initially- hot, is cooled rapidly by an injection of fluid. While Cygna finds this hard to pos-tulate in most areas of the plant, it is possible in the region of the connection between the safety injection system and reactor coolant loop or the auxiliary feed-water and nain feedwater lines. In those cases, the branch lines, for a certain distance from the main lines, would-be hot. They would then be subjected to a cold shock, causing the pipe to shrink away from the hot U-bolt. This would result in a U-bolt load history as shown in Figure 2. This load decrease may result in an l unstable support. Has TUGC0 considered the possibility of this occurrence in determining required preloads? If e not, what effect. does it have if U-bolts are used in this

..< situation?

' (10)~ Reference 4 (Norml? Vibration and Seismic Tests) ,

These two tests are an integral part of the arguments a stabil- t ity.' As TUGC0 has stated in Reference 3, page 44 i

i "If the test shows:that the assembly does not move, then it is ' impossible to argue that it did. This is different

' than having a static, theoretical model predict-that it >

should not move." l 1

l 4

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,~,

84042.036 Mr. J.W. Beck Page 8 i

' March 25, 1985 ATTACIMENT 2 Cygna Comments / Questions Related to the TUGC0 U-Bolt Cinching Program Yet, there are some very basic shortcomings with these tests from the standpoint of configuration, relationship to expected plant worst case geometries, method of load input, and level of preload used. As can be seen -from the following questions, Cygna's mjor concerns about the ability cf the U-bolt to act as a clamp remin j

unanswered.

a. The -test used a strut with a 3.5* offset in two direc-tions. The worst case for axial stability is with the strut offset 5* axially along the pipe. The worst case .

for rotational stability is with the strut offset 5* in the plane of the. pipe cross section. By conducting the test in the manner described, TUGC0 has not enveloped either worst case. What effect does this have on the

. conclusions?

b. 7he static application of a load lower than a dynamic 7000 lb load at 9 Hz pay produce an unstable structure, Since only a dynamic test was done, this tells us nothing about the strut loaded in compression statically (such as SI-1-325-002-532R). What effect would a static test have on the conclusions?

c. What is the effect of'using a piping system which is so stiff (75 Hz)? More comon piping frequencies would be in the 9 Hz range, as noted by TUGC0 in various places.

A lower frequency would have permitted larger deflections at the load cell. for the same load, which nay have resulted in some instability by not transferring the full load.

i d. Neither the tests nor the analysis (Reference 5) address

. the worst support configuration in terms of distance of support attachment above the pipe. . For example, see sheet 4 of support MS-1-001-003-572R, which is attached.

In it, the clevis-is located two feet above'the pipe /

backing plate surface. Such a large offset of any lateral load component will negnify the destabilizing

- effect of the load. What preloads would be required to  ;

ensure stability for these geometries? What methods will be used to calculate .the required.preload? l i

e. Cygna believes that the major drawback to these~two' tests is the' dependence. on 50 foot-pounds showing that the - ,

t

u.n Mr.,J.W. deck 84042.036 .

March 25,1985 Page 9 ,

ATTACIMENT 2 Cygna Comments / Questions Related to the i TUGC0 U-Bolt Cinching Program support will be stable (Reference 4, pages 73 and 87).

The torque value is ininaterial. What is critical is the 4285 pounds of preload (page 73) and 4484 pounds of pre- l load (page 88) required to mintain stability for these l tests. Based on the original torque versus preload test 1 on the 10-inch stainless steel . pipe, it would require {;

.almost .100 foot-pounds of torque to achieve these pre- ,

loa ds. Thus, the question should be: with the mininum preload.available at 50 foot-pounds of torque, what load can be carried? The minimum preload for 50 foot-pounds in the 10-inch stainless steel pipe is 1600 pounds  ?

(Reference 10, graph of preload versus bolt torque). Had this level of preload been present during the seismic test, the support may have been unstable, as illustrated by the example below using actual test data.

During the seismic test, a -dynamic strut -force of 8600 lbs (sinusoidal) was applied to the 10" U-bolt support.

With the strut offset at 3.5* within the plane of the pipe cross section, the component of force tending to rotate the U-bolt about the pipe was: (8600)(sin 3.5") = i 525 lbs. With the U-bolt torqued to 50 foot-pounds, the average preload per leg during the seismic test was 4400 lbs (page 88). From the load distribution test, an aver-age preload of' 4400 lbs reduces to approximately 1950 lbs during the application of an 8600 lb compressive strut load (Figure 18 of' Reference 4). To maintain stability, this reduced average preload must generate sufficient '

frictional forces to resist the destabilizing force of 525 lbs, which wants to rotate the U-bolt about the pipe. From the friction test . data for the 10" Sch 405 pipe (Figure 11 of Reference 4), a 525 lb slip friction force corresponds to a U-bolt torque of approximately 26 foot-pounds. From the 10-inch Sch 40S data supplied in response to question 5 in Reference 10 the U-bolt torque -

of 26 foot-pounds corresponded to an average preload of '

approxistely 1470 lbs. Thus,. based on test data,1470 l

lbs will resist up to a 525 lbs lateral load. Since the l

actual average preload is 1950 lbs, which is greater than l the 1470 lbs required, instability should not occur and l

was not observed during the test. Therefore, the seismic l test appears to confirm the results of the above calcula-tion, which is based on data taken directly from other tests.

t

' b saavats:

84042.036 Mr. J.W. Beck Page 10  ;

!! arch.25,.1985 ATTActatERT 2 i Cygna Coments/ Questions Related to the TUGC0 U-Bolt Cinching Program Had the 50 foot-pounds of U-bolt torque resulted in only 1600 lbs of preload (see figure attached to response to question 5 in Reference 10) and had the strut been in-clined at 5' in the worst direction instead of 3.5*, the '

results could have been significantly different. Had.

these conditions existed, the destabilizing force com-(8600)(sin 5') = 750 lbs instead ponent would have been:From the load distribution test a 1600 lb of 525 lbs. -

average preload reduces to 500 lbs when 8600 lbs of strut compression is applied. To resist a 750 lb slip friction force requires 38 foot-pounds of torque which translates into 2070 lbs of average preload (see references already notedabove). Since the .2070 lbs preload required is much greater than the 500 lbs of average preload pro-vided, this support would be unstable. (It is important to note, and obvious from the above result, that an initial preload mth higher than the 1600 lb minimum.used in this calculation would have also produced an unstable condition.)

This example simply. demonstrates that 50 foot-pounds of torque can produce both stable and unstable supports.

s In addition to the above example, the tests showed that at 20 foot-pounds the support rotated and walked-(as stated in Reference 7, page 112) and at 35 foot-pounds l the support behaved in a stable fashion. The preloads for 20 foot-pounds and 35 foot-pounds are 900 and 1400Yet, pounds, respectively, from Figure 3 of Reference 4.

they were probably mch higher for:this test,. since the 50 foot-pounds produced 4200 pounds at the time of the dynamic tests versus the 2250 pounds from Figure 3. As illustrated above, 50 foot-pounds of torque on a U-bolt in the-field liny not produce a preload sufficient to carry the loads tested. Please show how the data from l

all the tests will he correlated and .used to ensure support stability.

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6 V

e usan 84042.036 tir. J.W. Beck Page 11 -

Marcn 1!,1985 i

ATTACletDIT 2 i

Cygna Coments/ Questions Related to the TUGC0 U-Bolt Cinching Program (Primarily Reference 5, Page 7, and Reference 10 Table 2

( 11) General _

in Response to Question 5).

i In References 6 and 9, Cygna has sought to understand how TUGC0 will l define the minimum preload necessary for stability (Reference 6 questions 6 and 19; Reference 9, question- 4) and what those preloads will be. Per Reference 10, response to question 5, TUGC0 states:

"The U-bolt torque values that will be used in the field has (sic) not been established yet for all pipe sizes and will be nede available as soon as the information is finalized."

TUGC0 has, however, presented a methodology and examples for the U-bolt sizes analyzed. Cygna will use one of those examples, Table

- 2 from Reference 10, to coment on .the methodology.

In arriving at the preload in Table 2 for 10-inch Sch40, TUGC0 has used the formula:

T= KFD Where:

T= Torque in foot-pound F= Preload in pounds D= Nominal U-bolt diameter in feet -

K= A correlation coefficient In Table 2. TUGC0 reports the following: Tension T1 Tension T2 (Kips) (Kips) 0.00 0.35

a. Leg force needed to provide resistance couple 2.79 1.05

b. Amount of unloading due to push

.2.79 1.40

c. Total preload necessary (sum 1+2)

Minimum Preload Moment = (0.4)(0.75) 1400/12 = 35 foot-pounds Cygna has the following questions:

i

adevsCES 84042.036 Mr. J.W. Beck Page 12 March 25,1985 .

ATTAcmENT 2 Cygna Convents / Questions Related to the TUGC0 U-Bolt Cinching Program l (a) The amount of unloading due to a push load of 10000 lbs is 2.79 kips from Figure 18 of Reference 4 Where does the 1.05 kips under the T2 column come from? It appears to be in contradiction to the data shown in Table II-2 of Reference 5.

(b) In calculating the " minimum preload moment", why was

- the 1400 lb preload used instead of the 2790 lb shown for T17 (c) The value of K used is 0.4. For 10 inch Sch 40

. pipe, why wasn't K based on the 1600 lb/50 foot-pound data point shown in the curves attached to Question 5 of Reference 10. With this data point as

- the minimum, K would be equal to 0.5, which would

- increase.the necessary torque:Dy 25%.

Based on the above comments, Cygna would arrive at' Minimum Preload Moment = 0.5(.75)(2790)/12

= 87 foot-pounds Note that this torquing value provides no safety factor for uncer-tainties. What safety- factor does TUGC0 propose to use to account for uncertainties in fit and configuration?

o 4

4

FIGUREk~

Probable U-Bo'It Leg load as a Function of Time During Rapid Heatup Fluid Transients-0-Bolt load Rapid Heatup (for exam'p le, step change)

-Probable . -

- Maximum i

Level Shown Slow Cooldown (for example,100 F/ hour) in Test for.

' Thermal' Cycling initial Preload I

• TlHE Start of Start of Cycle 1 Cycle 2

FIGURE 2 Probable U-Boit Leg Load as a Function of Time During Rapid Cooldown Fluid Transients U-Bolt Load Slow Heatup (for example,100*F/ hour)

Level Shown in Test for Thermal Cycling Rapid Cooldown (for example, step change)

Initial Preload Probable Minimum _ _

TIHE Start of Start of Cycle 2 Cycle 1

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10: Catto n.a s:ree: s#te 1003. san francisce. CA 9411158%t March 29, 1985 l 84056.060  !

Mr. J.W. Beck  !

' Manager - Licensing

Texas Utilties Generating Company

[

Skyway Tower 400 North Olive Street i L.B. 81 1 Dallas, Texas 75201

Subject:

Generic Issues Summary l

Comanche Peak Steam Electric Station (

- -Independent Assessment Program - All Phases Job Nos. 83090, 84042 and 84056 i

Dear Mr. Beck:

..On March 14,.1985, a meeting was held .between the Comanr5 Peak Review Team *

(CPRT) and Cygna to discuss the findings from all four phases of the Independent Assessment Program (IAP). At this meeting, Cygna supplied a preliminary docu-ment whicn surnarizes and provides references for all open and closed issues known at that time.The Thisattach'ments document will tobe thisreferred to as tne letter contain " Review seven Issues sets of ques-List" henceforth.

tions, one for each review discipline, which, if answered properly, could close all issues known at this time. The two currently incomplete areas are cable tray and conduit support reviews (Attachments C and D). The degree of incom-i pleteness is detailed on the respective attachment.

The questions. In the attached. Generic Issues Sunnaries provide the necessary

-focus for assessing the generic implications of interrelated issues and any l

cumulative effects. We have also attempted to. narrow some issues by highlight-cing Cygna'.s. specific concerns.

The more detailed, Review Issues List will be issued in final form this week.

Cygna personnel-will continue to' review this listing on a weekly basis to identify any necessary revisions as we complete our review documentation and obtain any outstanding documents. We do not anticipate any significant changes' to the attached Generit. Issues Sunnaries as a~ result.nf revision (s) to the

Review Issues List, however.

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58 JC#8 84056.060 '

J.W.. Beck Page 2 March.'29,.1985 i

If you -require additional information, please do not hesitate to call.

~ Very -truly yours, - '

-[lM.T/_hUuYo N.H. Williams

. Project Manager NHW/ajb-

- Attachments - (7) cc:- Mr. V.' Noonan (USNRC) w/ attachments Mr. . S. Burwell -(USNRC) w/ attachments Mr.:S. Treby (USNRC) w/ attachments Mr. J. Redding (TUGCO) w/ attachments

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Ms. J. van Amerongen ITUGC0/EBASCO)-w/ attachments Ms. J. Ellis- (CASE) w/ attachments 5

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4 Mr. d.W. Beck B4056.060 March 29,1985 Pa ge 1 ATTACIMENT A Generic.lssuas Sumery PIPE STRESS .

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- Two najor. items still remin open in the pipe stress area. They are:

.1.0 Mass Participation i

. "2.0 Cumulative Effects of Five Piping Analyses -

Observations i

If TUGCO/CPRT adequately answers the following questions, these issues could be resol ved. - l 1.0 - Mass Participation 1.1 Demonstrate how'TUGC0 will comply with theTSAR comittnents relative to imiss prticipation.

1.2 Demonstrate why the 30 percent pass participation cut-off used in the Gibbs A Hill reevaluation is reasonable, considering the fact that

~

higher order modes my contribute more than 10 percent. additional response to the piping system.

1.3 - Demonstrate how your final design documents will reflect the effects of question.1.1 and 1.2 above. ,

2.0 Cumulative Effects of Five Piping Analyses Observations 2.1 Considering the cumulative effects of stress intensification factor discrepancies,' inclusion of fluid and insulation weights at valves and flanges, ass point. spacing discrepancies, inclusion of support mass in the stress analysis, and pipe support ~ stiffness,. demonstrate how all systems achieve compliance with the ASME Code and other

' applicable FSAR. requirements such as the evaluation of-welded attachments. ,

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84056.060 l i

Mr. J.W. Beck Page 2 i March 29, 1985 1 j

ATTAtlWENT A J Generic. Issues Suunnary (continued) l 2.2 How are the results of the Component Cooling Water (CCW) study on Ine

~ effects of fluid and insulation weights at valves and flanges appli-cable to other systems?

2.3 The ass point spacing discrepancies found in the Gibbs Therefore, & Hill re-demonstrate how ,

analysis were statistically significant.

TUGC0/CPRT intencs to resolve this issue.

2.4 Tne ASLB is concerned with the effects of including appropriate  ;

fractions of the support ass in the pipe stress analysis. . Demon-strate how the effects of: including support mass have been evaluated 3

- and resolved.

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March 29.-1985 i ATTACIMENT B Generic Issues Summary PIPE SUPPORTS The major open items associated with the pipe support reviews may be divi into two categories:

1.0 . Design Loads. and Displacements

'2.0 - Design of Support Components P If satisfactory responses are received which properly a open items could be resolved.

1.0 Design Loads and Displacements ii

,11 Considering the cumulative effects of all previously s self-weight excitation in the unrestrained -direction,- please demon-strate how all. pipe support designs meet applicable code and FSAR requirements.

1.2 For all potentially unstable supports - please demonstrate how either:

i

a. the support maintains positive connection to the pipe throughout the design life of. the plant; or

b. the. redistribution of the load due to the potential' loss of restraint does not compromise the ability.of the pip-ing or other pipe supports to meet design requirements.

1.3 Demonstrate how'TUGC0 will ensure that dual strut / snubber designs consider- the effects of load imbalance due to pipe rotation in the design of support components and welded attachments.

1.4 Demonstrate-how

to concreta anchors and -TUGC0 has thru-bolt. ensured that connections loadsthe are within onorigina civil civil.' design loading.or have.been explicitly accommodated.

1.5 Some systems must be' designed for dynamic events' (i.e., steam and

-water haumer) which produce displacements much larger than those

resulting from' earthquakes. How have these larger displacements ig been

. accounted for in' the design cf frame igaps, . swing: angles and spr n

travel? .

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84056.060 Mr. J.W. Beck Page 2 March 29, 1985 I

ATTADRIENT B Generic Issues Summary -

(continued) 2.0 Design of S' upport Components  !

How is the design requirement that all attachments to embedded plates }

'2.1 L be spaced a minimum of 12 inches apart implemented and controlled in j

the field? ..

2.2 Demonstrate how all combination welded / bolted connection designs meet the requirements of. Paragraph XVII-2442 of the ASME B&PV Code.

2.3 Regarding Richmond Insert designs as discussed in Cygna letter 84042.025, dated January 31, 1985, demonstrate how Richmond Inserts are in compliance with the FSAR and applicable codes.

"2.4 Please provide a basis for evaluating punching shear in the tube steel around drilled holes . caused:by bolted attactunents. Describe how supports ~have been checked for tnese effects.

2.5 Demonstrate how both cinched U-bolts and box frames with 0-inch gaps maintain positive connection with the pipe withcut inducing excessive

' stresses in the support or the pipe.

2.6 Demonstrate how the range of the construction tolerances on bolt holes and base plates are accounted for in the base plate design r.alculations.

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. ~meen 84056.060 Mr. J.W. Beck Page 1 March 29,.1985 ,

ATTAC E NT C ,

Generic.Iccues . Summary 1

-CABLE TRAY SUPPORTS

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Cygna's sunnary documentation of the support reviews is approximately 90% com-plete. 'Specifically, Cygna has not yet received a response from TUGC0 to ques-tions concerning support Detail "5". In addition, as a result of the support f reviews, Cygna is also investigating the impact of the design specified support spacing on cable tray stresses. Other than the above incomplete reviews, the major open-items associated with-Cygna's cable tray. support reviews can be suntarized into five categories based on the particular aspect of the design affected and the number of supports :affected. These categories are:

,.1.0 Design Loadings 2.0 - Response Spectra Analysis 3.0 Senerit Studies .

4.0 - Systems Concept for Design

~5.0 Component Design If satisf actory responses to the following questions are received, the above open items could be resolved.

Many of the cable tray support findings are interrelated and therefore tend to produce effects which are cumulative. Since these relationships are sometimes complex and-difficult to analytica117 quantify, TUGC0 may wish to consider a comprehensive in-situ testing program.as a:means of collectively addressing ~

.Cygna's questions. If testing is selected, please provide a neta11ed descrip-tion.of how these " load rating" type in-situ tests will encompass the concerns hignlighted in items one through five above.

In lieu of de'veloping a . comprehensive testing program please provide responses

' to.the following questions:  ;

4

' 1.0 Design Loadings

-1.1 Demonstrate how the DBE load combination is the governing load case for'each component in the support designs (i.e., concrete anchors, l clamps, structural steel members, plates, welds, vtc.).

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IS 84056.060 '

Page 2 Mr. J.W. Beck.

Marcn 29, 1985 ,

ATTAQ MENT C Generic Issues Suimmary (continued) hip and jet im-  :

.1.2 = Explain why other TSAR required loads such asl 1.3 Demonstrate how the additive effects of support dead load, support self-weight excitation in the unrestrained direct tsion of a dynamic amplification factor low margin supports.

i h n compared to the 1.4- Demonstrate the adequacy of the support des gns w e original . design criteria, i.e., allowable transv .

2.0. Response Spectra Analysis When. response spectra analyses are used for evaluations,' how is 2.1 compliance with Regulatory Guide.1.92 ensured?

2.2~ Response . spectra analysis using only one support This does typenot nave been in generic studies or in response to Cygna questions. Since appear to be representative of the actual. installations.

modeling assumptions greatly influence system response, please demon-strate how the results are applicable to the balance' of. the designs?

2.3 Demonstrate how the boundary conditions and tray attachment- modeli assumptions are reasonable when compared to the hardware (i.e., bas angle connections and clamps).

3.0 Generic Studies 3.1 ~The< working point Land weld underrun generic studies d the as-built condition.

luate their effect on the results of these studies.

'3.2 . Demonstrate how the generic studies - envelop all possible as-b

configurations.

4.0 Systems' Concept for Design 4.1 Considering the fact .that bolted clamps are used for . connections  ;

between.tne tray and-longitudinal trapeze-type supports, please -l explain why these supports will not carry any transverse or ver:)

loads.

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84056.060 Mr. D.W. Beck' Page 3 March 29, 1985 ATTAtl9ENT C Generic Issues Summary (continued) f 4.2 Considering the fact that transverse . supports use tray clamps that allow a gap, what. is the basis for assuming that the tray provides sufficient support to:

a. minimize-the effects of torsion and bending in the beam '

' and hanger members due to eccentrically applied loads?

b. resist buckling in the hanger member due to compressive loads?

'c.- limit base angle rotations? ~

4.3 If the additional loading due to self-weight excitation of transverse supports .is carried by the longitudinal supports, how have the longi-tudinal' supports been designed to resist this additional loading?  :

5;D Component Design .

5.1 L How are construction 1olerances, drawing specified component sub-

stitutions, and design specification (i.e., SS-30 requirements on  ;

Richmond Insert spacing and embedded plate design) requirements accounted for in the design calculations?

5.2 Demonstrate how all base angle connection designs properly account for the effects of prying and eccentric load application. .

5.3 Why is ACI 349-76, Appendix B, an ' acceptable basis for a 1.8 safety

- factor in the. design of Richmond-Inserts and connections at .CPSES?

And, if ACI-349 is considered acceptable, please address why all other ACI 349, Appendix B requirements need not be met.

4 5.4 Demonstrate how member and connection designs ~ properly account 1or.

.the effects of eccentric load application.

.5.5 . Demonstrate how the ' design calculations account for all . applicable

. provisions 1of AISC as required by the~ ESAR?

In Jhen preparing responses,.please provide .the assessments.on a generic basis.

addition, for those items _ which may have cunulative impact on the overal1 ~ sup- -

port system integrity, please . address the additive effects of all such responses on a generic basis.

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84056.060 Mr. J.W. Beck Page 1 March 29, 1985 ATTACKNT D ,

Generic Issues .%-ary 1 CONDUIT SUPPORTS Cygna's sumary documentation of the conduit support reviews is approximately 857. complete. The following areas are still being evaluated for their effects on tne support designs. Tnese areas are: .

.a. changes in span lengths for unprotected and fire protected spans;

b. evaluation of cable tray stresses.due to attached conduit; ,

c. Nelson studs; and,

d. loads on grouted penetrations.

Additionally, since the technical requirements for. conduit support designs have ,

changed over time, Cygna is still reviewing the effect of these changes on the support. adequacy.

Other than the above incomplete reviews, the major open items associated with the conduit support reviews may be divided into three categories:

1.0 Design Loadings 2.0 Systems Concept for Design 3.0 Component Designs i

If TUGCO/CpRT adequately answers the following questions, and properly considers any associated cumulative effects, these items could be resolved. I 1.0. Design Loadings ,

1.1 Demonstrate how the'08E load combination governsrfor each component

.used in the support designs, i.e., concrete anchors, clamps,  ;

. structural .. steel members, r.old-formed members, plates, welds, etc.

I 1.2 Explain why other TSAR required loads such as pipe whip and jet im-pingement are not. explicitly addressed in the-design calculations. 4 I

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84056.050 '

i Mr. J.W. Beck . Page 2 March'29, 1985 ATTACMENT D j Generic Issues Susumary (continued) l 1.3 Quantify the additive effects of support dead load, support self-weight excitation in the unrestrained- direction, combininginclusion the dead of

-load with the SRSS concination of seismic loads, and the ,

a dynamic amplification. factor on conduit support integrity.

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1.4 How do amplified accelerations affect the integrity of LA-type con-

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duit supports which are adjacent-to flexible spans or are loaded with *

. flexible conduits.

1.5 What is the basis for excluding longitudinal loads on transverse-type '

supports given'that the same clamps are used for all support types.

2.0 Systems Concept for Design 2.1 'If' the additional loading due to self-weight-excitation of transverse L

supports is carried by longitudinal supports, how have the- longitu- ,

- 1dinal supports been &tsigned to resist this additional loading.

2.2 Gibbs & Hill has assumed that 1-clip rotations are limited by the

',. attachment to the conduit. How does the conduit support testing  ; .

program validate this assumption?

1

,3.0 Component Designs 3.1 How are construction tolerances, drawing _specified component sub-stitutions, and design . specifications, e.g., 2323-SS-30, accounted for in the designs?

?3.2 Demonstrate how all base connections preparly account for the . effects

.of prying and eccentric load application.

j 3.3 Demonstrate:how the design calculations account for all applicable provisions of AISC as required by the TSAR? '

3.4 'TUGCO has initiated 'a program which includes reanalysis using the

,. provisions of AISI and testing of conduit supports- to document the  :

o ' adequacy _of : support . designs which milize Unistrut components and 2- l

[ clip base connections. Explain how this _ program will demonstrate the ^  :

) . adequacy of all 'such supports at CPSES.

i '. 3.5 Explain how'TUGC0 will demonstrate the idequacy of support designs.

which employ. catalog components that have been altered from the l

manuf acturer; supplied configuration?

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B4056.060 Mr. J.W. Beck Page 1 March 29, 1985 l

-ATTACHMENT E l

. Generic Issues Summary  :

MECHANICAL SYSTDtS Three items remain open in the mechanical systems area. They are:

1.0 Single Failure Criteria 2.0 Changes in Design Parameters 3.0 Control of Appendix R Modifications

,uld be If TUGCO/CPRT adequately answers the following questions, these issues resolved.

1.0 Single Failure Criteria 1.1 Cygna has-identified a potential finding wherein single failure crf-teria may not have been satisfied for the Component Cooling Water (CCW) system valve which provides isolation in the event of a thermal barrier rupture. Demonstrate that this situation has been resolved -

and demonstrate that single failure criteria for valves has .been satisfied throughout the plant.

2.0 Changes- in Design Parameters 2.1 Given the situation with the conflicting design temperature documen-tation on the CCW system, .how does TUGC0 ensure that the final design loads are within the design envelopes for the. components such as pumps and heat exchangers?

2.2 By definition, . Class 5 piping is not intended to fulfill a safety

.related function. Explain the use of Class 5 piping in areas .where

. functionality is required following design basis events.

3.0 Control of Appendix R Modifications

.3.1 -How does TUSCO casure that the as-built Appendix R nodifications ar-  !

in conformance with the Appendix R design requirements and specifica- l I

-tions?

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84056.060 Mr. J.W. Beck Page 1 ,

March 29, 1985 i ATTACHMENT F Generic Issues Summary

1 I l I f ELECTRICAL The only item of potential significance' identified during the electrical reviews were two instances where the pressure-temperature ratings for installed Compo- '

nent Cooling Water (CCW) system instruments were lower than the maximum When pressure or temperature of the system as indicated by the Gibbs & Hill analysis.  !

design and operating data is revised, how does TUGC0 ensure that all existing

' system components meet the new operating' conditions? I I

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ATTACHIENT G I

dieneric Issues Summary UESIGN Colmt0L .  !

Given the data available from all four phases of the Cygna technical and design t control reviews, a cumulative effects evaluation of all observations and poten- i tial findings reports is being performed. This review will also focus on the cumulative effects of individually insiginificant discrepancies. Any trends 4 identified which indicate eitner strengths or weaknesses in the CPSES ' design /

design control program will be evaluated. Cygna is also evaluating the adequacy I of the overall design process exployed on the Comanche Peak Project. As part of i

.this assessment, particular. attention.is being paid to the control of design i organization interfaces, the adequacy of design procedures, the adequacy of. the design documentation, and the control of the design inputs.

I At this. time, the're are two open items. These items are:

i

.1.D Corrective Action i 2.0 Document Control 4

In order for Cygna-to complete the design control evaluations described above, -

please provide responses to the following questions.

, 1.0 Corrective Action ,

1.1 In-light of the observations identified through the Cygna reviews,  ?

demonstrate / quantify the degree of confidence TUGC0 has-in their '

j

' corrective action system.

.2.0 Document Control ,

Demon- ei i 2.1 By early 1984, TUGCD had inplemented a hetional DCC system.

i strate how TUGCD has ensured that changezdocumentation issued prior j to-the establishment of the present DCC system was incorporated into  ;

the- final installed designs. i i

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• March 6, 1985 l' l 83090.024  !

Mr. V. Noonan-U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 8ethesda, Maryland 20814 .

S'u bject: Response to Ntc Questions - Spent Fuel Cooling Pump Grounding Comanche Peak Steam Electric Station

• Independent Assessment Program - Phases 1 and 2 Texas Utilities Generating Company Job No. 83090 ,

Reference:

Cygna Final Report, Phases 1 and 2 TR-83090-01, Revision 0 Observation WD-07-01

Dear Mr. Noonan:

Attachment 1 documents a discussion with 'Mr. Om Chopra of your staff in which Cygna was requested to determine whether TUGC0 had performed any corrective action as a result of Phase 1 Observation WD-07-01. This observation concerns the walkdown in which it was noted that the spent fuel pool cooling pump was single grounded where design drawings call Sr two ground connections. Cygna originally closed this issue based on the fact that double grounding is required ,

for personnel safety only and not for the purpose of satisfying any safety re- '

lated system function or design requirement.

1 A subsequent discussion with Mr. Ivan Vogelsang of'TUGC0 (see Attachment 2) has revealed that the pump is double grounded by an acceptable alternate means dif-

' forent than the configuration shown on the design drawing. This ins not docu-manted by TUGC0 since the double grounding of the pump is not a safety related requirement and.as such-is not subject to the Class IE quality. assurance re-quirements applicable.to.the pump. .

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Mr. V. Noonan March 6, 1985 Page 2 I

I If you have any further. questions or wish to discuss this response, please call at your convenience.

Very truly yours, j s /

M.H.~ Williams .

Project Manager  !

.NHW/ajb ,

Enclosures cc: Mr. E. Bagchi l

- Mr. J.: George Mr. D. Wade Mr. D. Pigott Mr. S. Treby Ms. J. Ellis >

Mr. 5. Burwell l

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Texas Utilities " T X" " " * "

• Prosese Joe No.

83090 -

Comanche Peek Steam Electric Station Independent Assessment Program - Phase 1 2/4/85 Sampset Tame:

Observation WD-07-01 11:20 a .m. ,

Single Grounded Pump sFR0 Parncioents. of +

0. Chnora USNRC l N. Williams Cycna _ l l

neou,.o Action my '

Hem Comments i Mr. Chopra called to find out if TUGC0 had brought the single grounded pump into compliance with the drawing. He understood '

.; that the double grounding requirement tas for personnel safety but he was concerned that a design requirement was not implemen-ted. N. Williams explained that Cygna did not pursue the matter further since it was not a safety related requirement and as sucli the same quality assurance measures do not apply. Cygns will, however, check with TUGC0 to estabitsh whether they installed thit second ground and call S. Bagchi (301/492-8251) back with the ' +

response. -

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• N. Williams, D. Wade, J. van Amerongen R. Ness, L. Weingart, S. Treby, J. Ellis, ,

m. s. surwe i s , s . re r u n , u m , n vas u r . . ,

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comoear 1 T** con a con e meemt Texas Utilities Joe No.

W 83090 l Comanche Peek Stems Electric Station '

D**-

Independent Assessment Program - Phase 1 2/26/85 Teme:

anes ect 1:00 p.m.

Observation WD-07-01

• Single Grounded Pump SFR0

1. Vogelsang, J. van Amerongen 1DGC0 W

K. Zee. L. Weingart Cygna ,

Comments Action By hem

1. I. Vogelsang described the "as-built" grounding of the Spent Fuel Cooling Pump Motor:

A. A 1* rigid steel conduit-isinstalled between the motor space heater terminal box and the cable tray - no " flex" ud.

5. Another rigid steel conduit.is installed for the motor power circuit. Approximately 3' of liquidtight " flex" is used at the connection to the motor terminal box. Approximate total raceway length is 22'.

• C. One N/D ground cable is installed between the " ground loop" and the motor's ground pad - cable is routed in parallel to the 1" conduit.

3. ' One M/0 bonding jumper is connected in parallel to the

.liquidtight aflex* using approved fittings.

l _ II. Regarding conformance of the as-built configuration to the i grounding details shown on G4H drawing El-1703-01 Revision 6;

1. Vogelsang indicated that the "as-built" condition provided the ,

required tuo soonections.as per Table.1 of.the referenced details.

Krise agreed that although the instellation did not match the grounding details, it did " effectively" provide the two-point connection required by the grounding details.

2 I h Y) Ik ML4t./3' /ajb 1 K. Zee L. Weingart. l

• N. Williams, D. Wade. J. van Amerongen R. Ness. T. Martin

! we'. 5. Tracy, J. f. Ills, 3. surwelI, Project nie

t I COmmuf1]CatiOTIS ATTAC m NT 2 (cont'd.)

i & A Fl8 port .

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1. The first connection.is provided by Item 3 of the "as- l

.huilt" condition. l

2. The second cona1 tion is " effectively" provided by a combinktion of Items 2 and 4 of the "as-built

• con-

+

dition ax4 Details 3 and 4 of EH drawing El-1703 Revision C- ,

Discussion 1he bonding jumper and the physical connection of the power terminal box to the motor frame " effectively". bonds the rigid l

steel power conduit to the motor frame. The rigid steel conduit is acceptable as a ground conductor thus grounding the motor frame to the tray system. Detail 3 of G&H drawing El-1703 This Revision 6. shows the tray system p ounded via M /0 cable.

in combination with Itas 3 of the- as-built" condition provides I the required two connections of the " ground loop" to the motor.

, III.. According to.I. Vogelsang, this discrepant;y with the drawing was not documented due to the fact that double grounding the pump in gasstion is a non-safety related (i.e.,1m-1E) requirsuant.

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4*5 .197 5600 .

tot cai.?cma street swre 1000. San Faa sc: *t. Wit f 3N '

March 5, 1985 84056.057 l

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Mr. J. Beck Licensing Manager ,

Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 -

Subject:

TUGC0 Meeting Schedule

• Texas Utilities Generating Company -

Comanche Peak Steam Electric Station -

Independent Assessment Program - Phase 4 Job No. 84056

Dear Mr. Beck:

I On February 27, 1985 Cygna was informed that TUGC0 wished to arrange a meeting with Cygna on March 13, 1985. This meeting was to.be held at the Cygna San Francisco. office. Cygna was requested by. the NRC to obtain a court reporter for this meeting. Since that time, we have been informed by Ms. J. van Amerongen that the meeting nasst be rescheduled for March 14. This date is acceptable to us, howeve'r, we request immediate confirmation of this date 50 the appropriate arrangements can be nede for court reporters and meeting place. We also request an agenda one week before the meeting to prepare for the meeting and schedule availability of appropriate project personnel.

Very truly yours,

%%%144%

N.H. Williams .

j Project Manager NHW/ajb cc: r Mr. V. Noonan Mr. S. Burwell l Mr. S. Treby Ms. J. Ellis ,

l Mr. D. Wade i Ms. J. van Amerongen Mr. D. Pigott Mr. R. Ballard Mr. J. B. George [%o , y san eancisco sauen encaco a,e .re i f'd

-Es

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' ["L i d Ial a m.csssumE l s X, .

415 337 5533 t 101 Cahtorrus Street. Sune 1000. San Francsco. C A 94111 5894 March 8, 1985 ' '

.B3090.023 ,

~

i Mr. V. Noonan '

U.S. Nuclear Regulatory Commission -

7920 Norfolk Avenue .

Bethesda, Maryland 20814

Subject:

Response to NRC Questions , -

Conanche Peak Steam Electric Station Independent Assessment Program - Phases.1 and 2 Texas Utilities Generating Company 3

Job Mo. 83090

Reference:

N.H. Williams (Cygna) letter to S. Burwell (US NRC),

" Response to NRC. Questions," 83090.021, November 6,1984

Dear Mr. Noonan:

The above referenced letter transmitted responses for two'of-four outstanding questions associated'with the staff review of Cygna's Phase 1 and.2 Independent Assessment Program (IAP) final report. This letter transmits Cygna's response to the two remaining questions: ,

1. With the information available from the Phase 4 cable tray walkdowns, can Cygna issue a letter stating whether or not the cable trays have been constructed in accordance with the latest drawings? .

2. With the information available from the Phase 4 cable tray support reviews, can Cygna issue a letter: stating whether or not the design drawings match the construction drawings?

Cygna's Phase -4 cable tray support reviews included an evaluation of both the design and installation processes. ' This required a check of the original design calculations.. design drawings, fabrication drawings, and a walkdown of selected installations. Although these' reviews are not finalized at this time, suffi-cient information is available to provide a partial response to the above ques- ,

tions. Further detail will be available-in the Phase 4 IAP final report.

i In response.to Question 1. Attachment A sumar12es the major discrepancies iden-

' tified during the .Cygna walkdown of 49 supports- between the latest design draw- f Attachment B ing, . including applicable. design changes, and the installation.

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l Mr. V. Noonan March 8,1985 - .

Page 2

~~

i

. contains a tabulation of discrepancies between the fabrication drawings and the .

design drawings as requested in Question 2. Eighty-nine supports out of a total  :

sample of.91 supports exhibited discrepancies. And finally, Attachment C suma- .

rizes instances where weld' design details were omitted on the design drawings.

~

In order to assess the impact of these discrepancies and determine whether or not there are any resulting programatic implications, it is necessary to brief-ly describe TUGCO's documentation system associated with the-installation and inspection of cable tray supports.

Brown A Root (BAR) Procedure ECP-10. " Cable Tray and Hanger Installations,"  !

covers the preparation and control of hanger location and fabrication draw-  !

8 l

ings. 'The key documents discussed in this procedure are defined below- ,

l

• - ' Gibbs & Hill support plans (2323-El-XXXX-01-5, where XXXX is a ' unique number): Floor by floor cable tray plans which identify support types ,

and location along the run. Some specific. support details are also ,

i

.shown.  ;

e Gibbs & Hill design drawings (2323-5-09XX, where XX is a unique num-ber): Design details for generic support types and connections.

I e , B&R support nap drawings (FSE-00XXX, where XXX is a unique numer '

other than 159 or 179): Gibbs & Hill support plan drawing which nas been altered by B&R to include identification numbers for each caole tray support.

I e B&R fabrication drawings (FSE-00159 series): B&R detail drawing pre-pared from the Gibbs & Hill design drawings. -

e B&R attachment detail drawings (FSE-D0179 series)- B&R connection ,

detail drawings prepared from Gibbs & Hill design drawings. ,

s

.', (The first two types of drawings, hereinafter referred to as design-drawings, are  ;

. prepared by Gibbs & Hill (6&H), the original; design organization. The rensining I

three types of drawings are prepared by Brown..& Root (BAR), the constructor, for use in the support fabrication and installation. Any change documentation, .in  !

the form of CMC's and DCA's, is written against the G8H design drawings. The  ;

support number (as shown on the corresponding BER7 tap drawing) is noted in block l*

h three on a' CMC. Per TUGC0 procedure CP-QP-11.10-2, " Cable Tray Hanger Inspec-i 4

y.4.

did 2M mummmmmmans N._ . .

~' .

Mr. V. Noonan March 8,1985 Page 3 i or, if inspec-d ings tion," QC nust inspect the supports toto determine the G&H de i

In order is must be reviewed for compliance with the design dr i drawing for

• necessary to check all design changes written against the GAH d "

includes ,

applicability to a given support.on the design drawing f determining and an av .

revisions, may be written against a design drawing, the d time processTne consuming. o l the latest design configuration is extremelythecumberso i Cygna number, but it is not controlled and was found to be inaccurate dur n  :

review.

Theoretically speaking, this is an acceptable processthesince designall chan written drawings.

, against the design drawings and liance QC to the is requ while acceptacility of the installation is still judged by com However, problems with this' process design drawings.

dance with the latest design drawings. Evidence was found which indica '

- became apparent.

~1nstallations design drawings.

based on the fabricationi drawings h ges w against the design drawings and the inability to readily in-ih identif l are applicable to givendesign details changes.

on the design dr '

.does not incorporatesall of the necessary 4 smaspins.) f l As ' discussed above.nthe large number of design 1:hanges lity of the support installations and their documentation.

other weaknesses in the overall design process which Y k and also at impac

~

the installation. For example, G4H anintains design' groups in New C has the site and,'.either group ney reyfew and approve . design d change l identified instances where the site group has reviewed and appr impact l - changes to the generic support designs without i carefu I

on the original analysis.

sibility to review these design changes so that the The gener t

might.be more. fully evaluated.New York groupi was field de- perform purpose of these studies was to provide a bla l .. *

'E c s .

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i

. l Mr. V. Noonan _.' ' i March 8, 1985 Page 4 l l

4

. . j j

- i j

result of the deviation. Cygna noted that these studies were performed using the original design configurations and did not consider the effects of all design changes. . .

4 These concerns will be discussed in greater depth in the Phase 4 final report.

t until that report is issued, we hope that this information will give you a gen-eral understanding of the type of inconsistencies Cygna is finding with the design / construction interfaces. This letter should not to interpreted as a .

3 final conclusion by Cygna on this particular area. It is evident now that dis- >

crepancies exist but the cause and impact is still'being investigated by Cygna

' as part of the cable tray support assessment.

Please call at your convenience if you wish to discuss this informataion any further.

i I

Very truly yours, i 1.y.1sLudu  ;

I~ N.H. Williams 2 i

Project Manager NHW/ajb ,

Attachments l cc: 5..Burwell (U510tc)

' 3. Treby (UsistC)

. G..Sagehi (USNRC)

R. Kissinger (TUSCO)

• D. Wede (TUGCO)

- . R. Ballard (G4H) i - D. Pigott .(Orriet,.Harrington' A Sutcliffe)

'!J.' Ellis (CASE) '

' J. an Amerongen (EBASED/TUSCO) i

i i -l 9

0

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m hYol Ts1 s m -

March 8, 1985 ftr. V. Noonan - Page A-1 S3090.023

~

' ATTACMIENT A i Differences Between the Installation and the Design Drawings Without Appropriate Documentation

. . (Question 1) 1

1. Support No. 481 A longitudinal type As was installed using only single angles in -

tne icngitudinal cirection, not pairs which are required by tne design drawing. No change documentation was located. TUGC0 is-sued a CMC to address this discrepancy in response to Cygna's question.  !

4 2. . Support No. 408 Type B4

,, The lower corner of tne frame is 1mdified by CMC 9916 Revision

" 1, to. avoid interference with the CCW heat exchanger. This change shows that 4" channel sections are to be used for the prescribed modification. A 6" channel section is actually in- .

stalled. TUGC0 has revised CMC 9916 to reflect the existing

- condition in response to Cygna's question, however, no pre-viously issued documentation explained the discrepancy.

3. Support No. 649, Type A1 This installation uses concrete anchorage " Alternate Detail l'

(G8H design drawing 2323-5-0903) which requires the use of an L6x6x3/4. Cygna's fleid inspection discovered that an L5x5x3/4 was installed. No existing documentation accounted for this

. discrepancy. In response to Cygna's letter 84056.021, Question. '

~ 4,'TUGC0 issued CMC 99308. Revision 0, and perforned supporting

- * ' calculations to. justify the use of the san 11er angle. l i

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4 March 8. 1985

. Mr. V. Noonan - . Page A-2

~83090.023 "N", Drawing 2323-El-0601-DI-S

-4. Support Nos. 722 and .2606.. Detail Cygna's field inspection found a working point violation on the

' brace attachment to the mil. Design drawing 2323-S-0929 Con- ,

nec ton Detail '"F" wasiused (2323-S-0903) which has a tolerance  !

of

• 0.36 where 12"<bc30"g Cygna's field inspection results (i.e., the brace uns loca-l~ s the tolerance used was 0 In re.5bsponse to Cygna's letter ted in line with one bolt). 7 , l 84056.021, Question 5. TUGC0 issued CMC 99309, revision 0, to' ~

I document this condition.

j

. 5. Support Nos. 2992, 2994, 3005, 3017, 3021, 3111, 6654 Type A2 l 3 l l

I

References:

1. Gibbs & Mill. Inc., desip drawing 2323-El-0713-01-S, Revision 3 .

l l 2. Brown & Root, Inc., fabrication drawing l FSE-00159

.3. American Institute. of J5 teel Construction. . lac.,

Manual of Steel Construction, 7th Edition 1' .

Reference 1 identified the above seven supports as follows: "A2 I

(except all members shall be MC6x12)," where L = 8'-3" (frame i

width), h = 4'-2" (frame height).

i i There were no calculations showing MC6x12 members, as specified l The l j on the design drawing, are acceptable for this' size frame.

. original A2 calculations limit the width (L) to 6'-0" with l

' C4x7.25 beans and C6x8.2 vertical henger ameers. The .faerica-tion drawing (F5E-00159, Sheets 2992 and 3005) specified C4x7.25 I

basan and C6x8.2 vertical hanger aseers. The Cygna unikdown

' results show the installed member sizes are as noted in Table 2 below. An IC6x12 was used in one case only. Although Gibbs &

Hill has recently performed calculations which show that the existing usu6ers and frame sizes 'are acceptable, no documen-tation exists to reconcile the differences between the design ,

, j

- e Arawings, fahrtsatice: Areerings and the. installation.

i

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Mr. V..Noonan- March 8, 1985 .

83090.023 - . . Pa ge A-3

.~ . . .

l TABLE 1 i

Cable Tray Support Member Sizes ,

I i '

Dimensions (See Note 1) Member Size Flange .

Required l

Support Depth . Width Existing Per Ref. .Per Ref.

No. (In) (In) (Note 1) 1 2

.C6 x 8.2 l 2992 6 1-7/8 C6 x 8.2 MC6 x 12 2994 6 1-7/8 C6. x 8.2 MC6 x 12 MC6 x 12 '

3005 6 1-7/8 .C6 x 8.2 MC6 x 12 C6 x 8.2 3017 6 1-7/8 C6 x 8.2 MC6 x 12 MC6 x 12 3021 6 1-7/8 C6- x 8.2 MC6 x 12 MC6 x 12

]

'3111 6 2-1/2 tic 6 x 12 MC6 x 12 MC6 x 12 i

i 4

6654 6 2-1/8 C6 x 13 #C6 x 12 MC6 x 12 ,

Note:. 1. Dimensions of the vertical channels are based on measurements.by.Cygna. Member sizes are determined by . selecting the chen-

' nel type from Reference 3 which most closely ,

matches the measured depth and flange width.

6. . Support No. 456,' Type Sp-8 y . ,

Cygne's field inspection indicated that the brace connected to the ,

i l

wall on one side of the support is located outside of the bolt pat-

]

torn on the base angle. Tne pe Detail "B" (2323-5-0903) connec-tion requires a tolerance of

• 0.2b .. TUGC0 issued CiC 99307, '

Revision 0, to document this iscrepancy in response to Cygna's l question. l l l

'7.

• Support"Nos. 2998 and 13080, Specia17ype Supports f ~

"These supports were installed in' floor slabs with '2"' topping. The  ;

! etapping depth ens apparently not considered in selecting the length i Cof:.the anchor. bolt. Therefore, the required embedmont length.was j

.not achieved. I i

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March 8, 1985 Mr. V. Noonan ~

            -83090.023                      ..

Page C-1 . j

                                       ,              ,        . ATTiceENT C                                                                   a r
                                   ~ Omissions of idelding Requirements on the Design Drawings                                               .

(1) Support-Types Di aED '2. Detail "7", Design drawing 2323-5-0903 . The design drawing does not show any weld symbols for the i

beam-to-base angle connection, j I

(2) Support Type SP-4, Detail "F", Drawing 2323-5-0903 .

                                                                                                                                                ?

4 The design draw'ing does not show any weld sumbols for the connection of the 3/8" gusset plate to the base angle. (3) Support Type Detail'"11", Drawing 2323-5-0905 Tnis drawing does not show any weld syneols for the con- ' nection of the.thti M6x12 members together.ttrform a com-posite beam, for the connection of the HC6x12 beams to the L6x6x3/4 base angle or for the connection of the M6x12 beams to the C6x8.2 hanger. (4)s Support Type Detail "N", Drawing 2323-II-D601-01-3 - This drawing does not show weld symbols for any of the , connection details used. i (5) Support Type Detail *J", Drawing 2323-11-0601-D1-3 This drawing does not sher any weld symbols for the con- l

                                         -nection'of the C3x5 spacer to the C4x7.25 beam.                                                         j 1

In each of the above instances, no documentation could be found which' provided design direction to the craft or QC personnel regarding weld 4 . sizes and configuration. - Although craft or DC may have requested engi-neering direction-through a Request For Information/ Clarification-(RFIC),

- this is not.a controlled means of transmitting design information.

IFM!B , e V Sfpreta $ soi cautomra se..:. sun. toco. san Frencaco. c4 s4tii.sas4 4ss as7.ssoc April 4, 1985 B4056.062 Mr. J.W. Beck Manager - Licensing Texas Utilities Generating Company Skyway Tower 400 North Olive Street L.B. 81 Dallas, Texas 75201

Subject:

Review Issues List Transmittal Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Job Nos. 83090, 84042 and 84056

Dear Mr. Beck:

Enclosed is a complete set of the Review Issues Lists (RIL) which sumarizes all the findings and open items identified to date. The disciplines included and the corresponding RIL revisions are as follows: Pipe Stress Revision 0 Electrical /I&C Pipe Supports Revision 0 Revision 0 Mechanical Systems Revision 0 Cable Tray Supports Revision 8 Design Control Conduit Supports. . Revision 0 Revision D. These lists will be reviewed by Cygna personnel on a weekly basis and reissued as necessary.

• If there are any questions, please do not hesitate to call.

Very truly yours,

   %W.1&he-c N.H. Williams                                                                                                                                  1 Project Manager NHW/dco 1

Attachments cc: Mr.S.V.Burwell Mr. Noonan (USNRC) (USNRC) w/ attachments w/ attachments / Mr. S. Treby (USNRC) w/ attachments y

                                                                                                                       /j     yd Mr. W. Horin (Bishop. Libennan, et al.) w/ attachments                                                     J Mr. J. Redding (TUGCO) w/ attachments Ms. J. yan Amerongen (TUGCO/EBASCO) w/ attachments

[N t ' h)/[ r Ms.-J. Ellis (CASE) w/ attachments . Mr. D. Pigott (Orrick, Herrington & Sutcliffe) w/ attachments i0 0g Mr. 7. Dougherty (TENERA) w/ attachments '7 Mr. R. Ballard (Gibbs & Hill) w/ attachments Mr. R. Kissinger (TUGCO) w/ attachments l% he  : I s n% amon cwn.c.no ?NO s g,

• l

          . . ~.          ..._....__....~.ue                    .      .     - . . . . . .        . _ . . . -
                    ~
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    ~

3/28/85 Revision 0 Page 1 PIPE STRESS Review Issues 1.ist 1.' -Mass Participation / Mass Point Spacing  ;

References:

1. R.E. Ballard (G&H) letter to J.B. George (TUGCO),

                                                                      " Mass Participation," GTN-69454, Septemer 14, 1984

2. N.H. Williams (Cygna) : letter to J.B. George (TUGCO), " Phase 3 Open Items - Mass Partici-pation," 84042.017, September 21, 1984

3. N.H. Williams (Cygna) letter to J.B. George

                                                                    '(TUGCO). " Phase 3 Open Items - Mass Participa-tion," 84042.019, October 2,1984

4. L.M. Popplewell (TUGCO) letter to N.H. Williams 4 (Cygna) "Cygna Potential Finding Report _ Mass Participation 'and the Mass Points Spacing Error in Problem AB-1-61A " Deceder 7,1984 4

5. N.N. Williams (Cytyna) letter to J.B.; George (TUGCO),

                                                                     " Phase 3 Open items - Mass Participation and Mass j                                                                   . Point Spacing," 84042.021, February 8,1985
                                                            .6.      Cygna Phase 3 Final Report,'TR-84042-01, Revision 1, Observation PI-00-05, and PFR-01
                                       - Summary:           The pipe stress seismic analyses did not include sufficient modes.to comply with the FSAR which requires that the in-                                               .

clusion of additional higher order modes should not increase

                                                           ; system response by more than 10%. . In addition, the mass point spacing for the dynamic analyses.did not always meet project criteria..

Status:-

                                                                                                                                      ~

i. . Reference 5 documents Cygna's evaluation of the Gibbs- & Hill

. piping reanalyses-and lists recommended actions. No response

   ,.-                                                     ' has been received from TUGC0(' Gibbs & Hill'at this-time.

s.. _ l Texas Utilities. Generating Company. . 4

       --          ~ '

6.4 L t A 4 Comanche Peak Steam Electric Station  ! Independent Assessment Program- All Phases Job No. 84056'

              . s..~.'.____...,..__.-                                                     .. _.               .__. __           . _ _ _ _ . , . ,,,

e 4 3/28/83 e Revision U Page 2 PIPE STRESS Review Issues 1.ist

2. Incorrect Pipe Schedule Used for Calculation of Nozzle A110wables

Reference:

              .1.         Cygna Phase 1 and 2 Final ReEort, TR-83090-01 Revision 0, Observation PI-Dt.-05 Summary:'                  Cygna noted one instance in wnich the nozzle allowables were calculated using an incorrect wall thickness.

Status: Closed out based on expanded review to include the pumps on the diese) generator system.

3. Finite Element Model Error in Flued Head Analysis

Reference:

1. Cygna Pnase 1 and 2 Final Heport, TR-83090-ul, Revision 0, Observation PI-U3-01 Summary: ' The flued head finite element model was found to contain a geometry error due to improper generation of some elements.

Status: . Closed based.on: review.of liof.the remaining J8 flued head analyses.

4. Inclusion of Fluid and Insulation Weight at Valves and/or Flanges

Reference:

- 1. Cygna Phase 3 Final Report, TR-84042-01,. Revision 1, Observation PI-DO-04 and Section -5.1., Page 5-6 Sunnary: Cygna found that it was Gibbs & Hill's standard practice not to include fluid and-insulation weight at valves and flanges. l Status: Closed for the CCW system based on a Gibbs & Hill study which

                                                           - demonstrated that the effect is minor. Tne effects must still be considered in a. cumulative effects review.                                                                     l
                                                                                                                                                                                ,   s i

i Texas Utilities Generating Company I I JL A Comanche Peak Steam Electric Station  !

                       ' L.                           Independent Assessment Program - All Phases'
                       ' MMMWunmul . Job Mo. 84056 9    8' *W *  *h     e % he e 4 _ en e_q y      .gq e.  $.  &GSe,so     5 g...,,,g,, -
                                                                                      .v         -

   ,                                                                                                                       3/28/85 Revision 0 Page 3 PIPE STRESS Review Issues List

5. Discrepancies-in Pipe Support Loads Between Analyses and Support i Design

Reference:

1. Cygna Phase 3 Final Report, TR-34042.01, Revision 1, Dbservation PI-00-06

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 29, 1984

3. 'R2. Ballard (Bibbs & Hill) letter to J.B. George (TUGCO), GTN-69233, dated July.10, 1984

4. Comunications Report between J. Finneran (TUGCD),

N. Williams and J. Minichiello (Cygna) dated 7/13/84, 2:45 p.m. Summary: Cygna found that in some instances the latest support loads were not' used in the pipe support design calculations. Status: Closed except 'as input- to the cumulative effects review.

6. Snubbers on Fisher Valves

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation PI-00-07 and PFR-02

2. -L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated July 9,1984

3. 1..M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated August' 29,1984 Summary: The snubbers on the Fisher valve operators were not qualified for the as-built loads. This issue led to questioning whether the valve itself was capable of transmitting these loads and still maintaining operability.

                       . Status:                       Closed based on TUGCD'.s..requalification of all .affected                        '

valves and snubbers.. , . m Texas Utilities Generating Company r .- [ g Comanche Peak Steam Electric Station ! gagggggg Independent Assessment -Program - All Phases Job No. 84056

         . _ . ~ .     , . . . . . . . . . . . . . . .                     .    .           . _ .

                ~
   ,.                                                                                                                                                   3/23/85 Revision 0 Page 4                         l PIPE STRESS Review. Issues List

7. Snubbers Close to Equipment Nozzles

Reference:

1. Cygna Phase 4 Pipe Stress Walkdown Checklists (not issued)

Summary: Cygna noted several snubbers on the Component Cooling Water System (CCW) which were located close to equipment nozzles. Due to their proximity to a rigid attachment point, the dy-namic displacements at these locations will be very small such that the snubbers inay not perform their intended func-tion.- Status: Closed with Cygna's recommendation that these snubbers be candidates for a snubber elimination program.

8. Lack of Traceability for ANSYS/Relap Runs

Reference:

            .l. Communications Report b'etween S. Lim (Gibbs A Hill) 'and.L. Weingart (Cygna) . dated 3/8/84, 8:45 a.m.

2. Consnunications Report between H.-~Mentel (Gibbs &

Hill) and J. Minichiello (Cygna) dated 3/13/84, 3:00 p.m., Revision 1

3. Comunications Reports between S. Lim (Gibbs &

Hill) and L.Weingart (Cygna) dated 3/15/84, 8:15 a.m.- Summary: There are four programs utilized by Gibbs & Hill in performing a steam hansner analysis:-

1. RELAP

2. ' GHFORCE - provides italance loads

                                                                . 3. Program to. convert.to ANSYS format
     ~

4. ANSYS l 1

                                                          ' Sufficient documentation did not exist to provide cross                                                                    )
                                                          . referencing of the four . runs for a particular Main Steam                                                               -)

loop. I l

                                                 . Texas Utilities Generating Company                                                                                              ,

L i.( ) A A Comanche Peak Steam Electric Station' Independent Assessment Program- All' Phases t l l melmittiilil m . ! Job . No. B4056 l l

o. s i 3/28/85 Revision 0 Page 5 PIPE STRESS Review Issues List Status: This finding was closed technically, however, it remains open from a QA standpoint.- This issue is being addressed as part of Cygna's Phase 4 design input control review.

9. -Inclusion of Support Mass In' Pipe Stress Analysis

References:

1. Communications Report between G. Krishnan (Gibbs &

Hill SSAG) and J. Minichiello (Cygna) dated 3/19/84, 8:30 a.m.

2. Gibbs A Hill letter GTN-68852 dated April 25, 1984

                                                                   ' 3.        Comunications Report between H. Mentel (Gibbs &

Hill), G. Grace (EBASCO), N. Williams and L. Weingart (Cygna) dated 5/24/84, 10:00 a.m.

4. Prefiled Testimony nf Nancy H. Williams, Response

                                                                              .to. Doyle Question 14,.. June 12,.1984

5. . Cygna Phase 1 and 2 Final Report, TR-B3090-01, Revision 0, Pipe Stress Checklist General Note 1 4 6. Connu~nications- Report between D. - Wade '(TUGCO) and N._ Williams (Cygna) dated 1D/11/84, 4:00 p.m.

7. N.H. Williams (Cygna) letter to V. Noonan (USNRC), -

84042.022, dated January 18,1985 "Open Items Associated with Walsh/Doyle Allegations" Summary: - The weight of the pipe supports was included in the stress , analyses for the Main Steam Inside Containment only. In j Reference 1 Cygna requested justification for this prac-

                                                                   ..tice. Gibbs & Hill responded in Reference 2 by pointing out that the -supports associated with the Main Steam lines were relatively massive and as such, a judgement was made to
    >-                                                                include their mass 'in .the stress analysis. ~ For other
                                                                     -systems, a judgement was made that the effects would be
                                                                    ' negli gible. However. .per Reference 4, the effect of this; omission on support . loads.was shown to be.as high as 24%-on

.the RHR.. system.; ,,,

                                  ! Status:                           Open, however, per Reference 7,' item 13, further Cygna review is;not. authorized.

i Texas Utilities Generating Company A{n 3 Comanche Peak Steam Electric Station

                                                         - Independent Assessment Program - All Phases magggummmmmm ' Job No. 84056-I         k
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. 3/28/85 Revision 0 Page 6 PIPE STRESS Review Issues List

10. Stress Intensification Factors (SIFs)

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation PI-00-01

2. . Cygna Phase 3 Final Report, TR-84042-01, Revision.1, Observation PI-00-01

                              . Summary:                      Cygna found numerous instances where S&H either neglected to input the required SIF into the stress analysis (References 1 & 2) or misc'alculated the SIF (Reference 2).

Status: Closed based on expanded reviews; however, this problem should be checked as part of the mass participation reviews.

11. WehdedAttachments

References:

                    .1.  .Cygna Phase 1.and 2 Final Report, TR-83090-01, Revision 0, Observation PI-00-02 and PI-02-03
                                                             .2. Cygna Phase 3 Final Report, TR-84042-01, Revision.1, Observations PI-00-02 and PI-06-01 Sunnary:                       Cygna found several problems with G&H's treatment of welded attachments:
                                                         .

• Use of an increased allowable in the eva-luation of local stresses for upset and emergency combinations (Reference 1).

t* Use of- thermal. expansion 1oads rather than load ranges for. evaluation .of _ local stresses (Reference 1).

 '~
                                                              -*    Failure to consider local stresses in break exclusion zones (Reference 2).
                                                         -*         Failure to consider combined effects of two supports at. a single welded stachment                            '

(Reference 2). , Status:~ ' Closed based on the use of rationale from later. codes, recalculations, and expanded reviews. Texas Utilities Generating Company ( i i Comanche Peak Steam Electric Station AMMMih8BMM -Independent Assessment Program - All Phases Job No. M056 s

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3/28/85 Revision 0 Page 7 PIPE STRESS Review Issues List

12. Use of Incorrect Pipe Wall Thickness References.: 1. Cygna Phas~e 1 and 2 Final Report, TR-83090-01, Revision 0, Observation PI-01-01 Summary: Cygna fourd two piping segments which were input to the.

stress analysis with the inc9rrect wall thickness. Status: This pros'lem was considered isolated and closed . based on Cygna s ..ecalculation of .the pipe stresses.

                     .13. Inclusion of Appropriate Responses Spectra

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision D, Observation PI-02-01 Sumry: Cygna noted that stress analysis problem AB-1-70 did not

_ consider all the appropriate response spectra from all

                                                 .. buildings.

Status: Closed based on an evaluation of the omitted sp'ectra and an

                                                  . expanded review to determine if this situation occurred in other stress problems.
                   -14. Support Location Discrepancy

References:

1. Cygna Phase 1 and 2 Final Report, TR-33090-01, Revision .0, Observation PI-02-02

2. Cygna Phase 3 ~ Final Report, TR-84042-01,

                                                         . Revision 1, . Checklist -Pl-09, Jtem~ 14 Summary:               Supports were inodeled at locations outside ci allowable tolerances. The Reference 1 observation was ' closed based on an evaluation .of the pipe stresses and an a:sessment- that these occurrences were sufficiently isola:ec. The Reference 2 discrepancy was noted and evaluated by 61 cs & Hill in their QA binder.                                                     ,
                          . Status:                 Closed.                                                                                      .

Texas Utilities Generating Company Leg'{ ; 3 Comanche Peak Steam Electric Station , ggggggggg -Independent Assessment Program - All Phase Jab No. 84056

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   .                                                                                                                                                                              3/28/85 Revision 0 Page 8 PIPE STRESS Review Issues List

15. . Use of' Incorrect Damping in Seismic Analyses _

Reference:

  '1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation PI-00-03 Summary:     .Cygna noted that Gibbs & Hill did not tonsider the lower damping response spectra in some systems with mixed sized                                                               -

piping. Status: Closed based on Eygna's expanded review. f-4 I : f Texas. Utilities Generating Company' , J (y , , Comanche Peak Steam Electric Station . WHWmmmmmmet Independent Assessinent Program - All Phases Job No. 84056

      #94 3/28/85
  . :                                                                                                                                                      Revision 0 Page 1 i
                                                               ~
                                                                                     ' PIPE SUPPORTS Review Issues List

1. / Box Frames With 0" Gap

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), ~ " Box Frames with 0" Gap", 84042.023, dated 1/28/85-

2. Comunications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84, Item 2

3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 4/19/84

4. L. M. Poppelwell (TUGCO)' letter to N.H. Williams (Cygna), Attachment B dated 6/8/84

5. " Affidavit of John C. Finneran, Jr. Regarding Consideration of Local Displacement and Stress" Summiary: . The original support calculations did not consider the

                                                     -e  effect of the box frame.and . pipe interaction (Reference 2).

In addition later TUGC0 calculations (References 4 and 5) used .unconservative temperature and frame stiffness assump-

                                                     ' tions and.did not include the effects of Cygna conrnents.

Status: -On hold pending TUGCO. response to Reference' 1.

2. Design of Welded / Bolted Connections

References:

~ 1.                         N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Design of Welded / Bolted Connections,"

84042.024, dated 1/28/85

2. Consnunications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/21/84. Item 1.c.

3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 4/19/84

4. - Cygna Phase 3 Final Report. TR-84042-01, , '

Revision 1. Observation PS-06 7

Texas Utilities Generating Company i Conanche Peak Steam Electric Station

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3/28/85 Revision 0 Page 2 PIPE SUPPORTS Review Issues List Sunnary: Cygna found no evidence that welded / bolted connections are designed in accordance with paragraph XVII-2442 of Section III of the ASME' B&PV Code. Status: - On hold pending TUGC0 response to Reference 1.

3. Richmond Insert Allowables

References:

1. N.H. Williams (Cygna): letter to J.B. George (TUGCO), " Richmond Insert Allowables and Bending Stresses," 84042.025, dated 1/31/85

2. Communications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/16/84, Item 2

                                                        - 3. Communications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/30/84, Jtem.1

4. 1.. M. Poppelwe'll"{TUGCO) letter to N.H. Williams (Cygna) dated 5/2/84

5. L. M. Poppelwell- (TUGCD) letter to N.H. Williams (Cygna) dated 5/8/84

6. Communications Report between Bezkor (Gibbs & Hill) and Minichiello (Cygna) dated 6/12/84, item 4

7. " Affidavit of John C. Finneran, Jr., Robeit C.

Iotti, and R. Peter Deubler Regarding _ Des gn of Richmond Inserts and their Application.tu Support i Desi gn" l 1 Summary: Cygna has concerns with the following issues. ,

• Justification for single -insert allowables based l on test concrete strength.  ;

o

                                                         -e       Justification for bolt loads due to " axial                       i torsion" of the ~ tube steel.                ,
                                                        - *-       Interaction results from STRUDL analyses.

o Bending stresses in bolts. Texas Utilities Generating Company a.4 [.. ;i 4 Comanche Peak Steam Electric Station - mitetsstimmmmt. Independent Assessment Program - All Phases J Job No. 84056

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Revision 0 Page 3 PIPE SUPPORTS Review Issues List

                               ; Status:        On hold pending TUGC0 response to Reference 1.

4. Punching Shear (U-Bolt - Tube Steel Design)'

References:

. 1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Phase 4 Open Items - Punching Shear," 84056.053, dated.1/31/85

2. Comunications Report between Finneran (TUGCO) and Minichiello (Cygna) dated 10/4/84

                                             . 3. TUGC0 Calculations dated. 10/11/84, received by Cygna 10/18/84-

4. . Communications Report between Finneran (TUGCO) and Minichiello (Cygna) dated 10/30/84

                                              .5. . J.B. George (TUGCO) letter. to M.H. Williams (Cygna) dated 11/8/84

, 6. . N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Phase 4 Open Items - Punching Shear" 84056.058, dated 3/12/85 Summary: Cygna has not found' evidence that the stresses in the tube steel or coverplate in support MS-1-002-005-572R near the U-bolt hole were evaluated. Cygna has found.that this absence of supporting calculations is typical for this type of design. Status:- On hold pending TUGC0 response to Reference 1. 9 9 i i Texas Utilities Generating Company Comanche Peak Steam Electric Station , L L 1 4 Independent. Assessment Program - All Phases

                     ? M8HMHunnungM ' Job . No. ' 84056
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3/28/85 Revision 0 Page 4 l PIPE SUPPORTS )

                                                                  . Review Issues List                                                :

3. ' Mas's Participation / Mass Point Spacing

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Mass Participation / Mass Point Spacing,"

84042.021, dated 2/8/85

                                                  -2. R. E. Ballard (G&H) letter to J. B. George (TUGCO), " Mass Participation," GTN-69454, dated
                                                         '9/14/84

3. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Phase 3 Open-Items - Mass Participa-tion," 84042.017, dated 9/21/84

4. N.- H. Williams (Cygna) letter to J. B.- George (TUGCO), " Phase 3 Open Items - Mass Participa-tion," 84042.019,-dated 10/2/84

5. letter to N. Williams L.M. Poppelwell (Cygna), "Cygna (TUGCO)

Potentia l Finding Report Mass Participation;and the Mass -Point Spacing-Error in Problem AB-1-61A," dated 12/7/84 Summary: Due to the detailed nature of this subject, please see Reference 1. Status: Dn hold ~ pending T1)GC0 response to Reference .1.

                 '6.      Stability of Pipe Supports

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Stability of Pipe Supports," 84042.035, dated 2/19/85

2. Comunications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/20/84, _ Item 3.

3. L. M. Poppelwell (TUGCD) letter to N.H. Williams

(Cygna) dated 4/19/84- '

4. - Comunications Report between'Rencher/Grece -

(TUGCO) 'and Minichiello/Wong (Cygna) dated 5/24/84, Item 15 l f Texas Utilities Generating Company. I Comanche Peak Steam Electric Station t i;g i Independent AssessmentJProgram - All Phases lilillllHilillllllHillillIll ' Job No.~84056 l

         .       . .c- .

3/28/85 Revision 0 Page 5 PIPE SUPPORTS Review Issues List

                                              '.5. . L. M. Poppelwell {TUGCO) letter to N.H. Williams.

(Cygna) dated 7/12/84

6. " Affidavit of John C. Finneran Jr. Regarding Sta-r ' tility of Pipe Supports and Piping Systems"

7. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Appendix J General Note 12, and Appendix G, Observation PS-02 i

Summary: . The issue of support . stability is quite detailed. Please see Reference 1 for a discussion of Cygna's concerns. Status: .On hold pending TUGC0 response to Reference 1.

7. . Cinching of U-Bolts

References:

1. ~N.H. Williams (Cygna) letter to J.W. Beck (TUGCO), " Cinching of U-Bolts," B4042.036, dated 3/25/85

2. Comunications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84, Item 5

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams .

(Cygna) dated 4/19/84

4. L.M. Poppelwell (TUGCO) letter to N.H. Williams -

(Cygna), Attachment C, dated 6/8/84

5. " Affidavit of Robert C. lotti and John C. <

Finneran, Jr., regarding Cinching Down of U-Bolts" )

                                                     '(received 7/12/84)

6. Westinghouse Electric Corp. Report EQ&T-EQT-860,

                                                    - Revision 0,

• Comanche Peak Steam Electric' Station U-Bolt Support / Pipe Test Program" (received 7/12/84)

                                              "7.       Westinghouse' Electric' Corp. Report entitled.
                                                        " Comanche Peak Steam Electric Station U-Bolt
                                                   ' Finite Ilement Analysis",1 dated 6/12/84 (received 7/12/84)

Texas Utilities. Generating Company i Comanche Peak Steam Electric Station ' I a Independent Assessment Program - All Phases gunmmmmummim - Job No. ~ 84056-

                                                                                                                                                                                   'l 1  .. . .c.    .
                                                                                                                                   . 3/28/85                                          i Revision 0                                      l Page 6 PIPE SUPPORTS Review issues List t

8. N.H. Williams (Cygna) letter to J.B.~ George (TUSCO),

U-Bolt _ Cinching Test / Analysis Program - Phase 3 4-Open Item," 84042.015, dated 8/23/84

9. -Transcript of Meeting between Cygna Energy Ser-

                                                        ' vices .and Texas Utilities Generating Company and                                                                          ,
                                                      ' Ebasco Services. Inc., dated 9/13/84

10. R.C. Iotti (Ebasco) letter to N.H. Williams

                                                       '(Cygna), " Additional Information as Follow-Up to
'                                                       Meeting of 9/13/84," 3-2-17 (6.2), ETCY-1, dated 9/18/84-

11. N.H. Williams (Cygna) letter to J.B. George (TUGCO),

                                                       '" Status of Cinched _U-Bolt Testing and Analysis Pro-l                                                        gram,"-84042.018, dated 10/1/84
                                              .'12.      J.B. George (TUGCO) letter to N.H. W1111ans (Cygna),
                                                         " Cinched U-Bolt. Testing and Analysis Program -

Additional Information," dated 11/1/84

13. J.B.- George (TUGCO) letter to N.H. Williams (Cygna),

                                                         " Cinched U-Bolt Testing and. Analysis Program -

Additional Information," dated 11/16/84 Sumary: Please'see Reference 1 for details. I Status: Dn hold pending TUGC0 response to Reference 1.

8. ~ Richmond Insert Allowable Spacing 1

References:

1.. Comunications Report between Rencher (TUGCD) and Minichiello -(Cygna) dated 3/10/84,. Item 1

2. Communications Report between Rencher .(TUGCO) and

    -                                                    MinichielloL(Cygna) dated 3/12/84 i

1 Texas Utilities Generating Company.

                                          ~ Comanche- Peak- Steam Electric Station

[ i Independent: Assessment Program - All Phases JJob.No. 84056. _ s 4 6 4 88 1 e p , .. ' ,wg,. ,, ,, ,,,,g . y, w ,- . - --- c , n. - . , - ~ , , , < , - < w + - - - - - - -

l l 3/28/85 Revision 0

 -                                                                                            Page 7 PIPE SUPPORTS Review Issues List Summary:     - Cygna had asked TUGC0 how the-designers ensured that the al-lowables they used for pipe support attachments correspond to the installed Richmond Insert spacing. TUGC0 responded by stating that their designers used minimum allowables, un-less a walkdown was performed to ensure that-larger spacings existed, thereby permitting the use of increased allowables.

There was .no written procedure documenting this direction to the designers. While Cygna could not find evidence that this unwritten procedure was not followed, Cygna has no assurance that conservative allowables were always used. Status: See. Cable Tray Open Items and Generic Issues, item 3. o

9. Embedment Attachment Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Pipe Support Review Questions," -item 5, 84056.'13, dated 7/31/84

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 8/24/84

3. Comnunications Report 'between Purdy (Brown 1 Root) and Minichiello (Cygna) dated 3/4/85

4. Brown & Root Procedure CCP-45, Revision 1, dated 8/18/80

5. Brown & Root Procedure QI-QAP-11.1-28, Revision 24, dated 4/18/84

6. Brown & Root Procedure .QI-QAP-11.1.28, Revision

      -                                      29, dated 1/25/85

7. Connunications Report between' Warner (TUGCO) and Wiliiams/Minichiello/Russ (Cygna) dated 2/27/85

8. CPSES Procedure QI-QP-19.5-1,' " Separation .

hspection for Unit.1 and.rn=nnn Bulldings" ,

Texas Utilities Generating Company ' Comanche Peak Steam Electric Station

                  -t    { t a      Independent Assessment Program - All Phases
                  . WMallMMMMI Job No.-84056

l 3/28/85 Revision 0

   ;                                                                                                 Page 8
                                                              . PIPE SUPPORTS Review Issues List Sunnary:        Cygna-has found two pipe. support base plates welded to em-bedded plates with less than 12" required spacing between the edges of the support base plates (per Reference 4).

This was not a CPSES inspection item at the time of the Cygna review (Reference 5); however, the Brown & Root-

                                             . procedure was . revised to include th.e proper- checks for pipe supp' orts (Reference 6). .Since this affects all hardware attached to embedded plates (HVAC.' raceway, and pipe sup-ports), not just a single discipline, and since it was not an inspection item in other discipline procedures (per Referencu 7 and 8), this item.has generic implications.                     ,

Status: .TUGC0 should provide evidence that the spacing requirement

                                            'has been or will be checked on a plant-wide basis.

10. Thru-Bolts and Concrete Acceptability Refe nnces: 1. . Connunications Report between 1tencher (TUGCO) and Minichiello (Cygna) dated 3/30/84, Item 2

2. L.M. Poppelwell (TUGCO) . letter to- N.ii. Williams (Cygna). dated 5/2/84

                                            ~. 3. L.M. Poppelwell 7(TUGCO)' letter to M.H. Williams (Cygna) dated 6/8/84 item 3 and Attachment D Summary:        Cygna is concerned 'that the loads on the walls may not -be acceptable. Although.Gibbs & Hill has walked down several
                                            -highly loaded areas per Reference 3, there is no written l                                              procedure fdocumenting the transmittal of .as-built loads on concrete structures to the structural group. Thus there is                      l no assurance that each area, particularly near free edges,                      j
                                             .is acceptable'.                                                                 1
                            . Status:        TUGC0 should demonstrate that the civil structures are acceptable for the applied loading.

Texas Utilities Generating Company . Comanche Peak' Steam Electric Station M ;g 3  : Independent Assessment Program - All Phases i NNWWWWmmuum Job No. 84056. 4

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3/28/85 , Revision 0 I Page 9 - l l J PIPE SUPPORTS Review Issues 1.ist

                     - 11. Bolt Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George

                                                                   .(TUGCO), " Pipe Support Review. Questions," item 3, 84056.14, dated 8/6/84
                                                      . 2.         L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 8/11/84
                                ' Summary:                 ln certain base plate designs in Phase 4 (CC-2-019-715-A43K,

for example), the bolt hole dimensions are detailed as ."1-

                                                           . 1/2 MIN TYP" from the edge of.the plate. In some cases,                                               >

this could result in a dimension from.1-1/2 to 3-1/2 ! inches. While this may have:little effect on the bolt load,  ! it does effect- the maximum plate stresses by as noch as 157, for a strut, spring, or_ snubber .with _ a 5* offset. i- Status: TUGC0 should demonstrate how this location tolerance.is

addressed in the design calculations.

I 4 '12. Support Self Weight Excitation During a Dynamic Event -

References:

-1. 'Comunications Report between Rencher/Finneran (TUGCO) .and Minichiello '(Cygna) ' dated 3/10/84

2. TUGC0~meno CPP-9977-

3. Cygna Phase 3 Final' Report, TR-84042-01,

                                                                  - Revision 1 Appendix J,. Note 7

4. N.H. Williams ,(Cygna) letter to V. Noonan (USNRC),

                                                                  '"Open Items Associates with Walsh/Doyle Allega-

! "tions," 84042.022, dated 1/18/85 i Susanary: - TUGC0 has not considered the loads due to the support

        ~

i - dynamic excitation in the. pipe support . designs. Status: Cygna has deferred this-issue,to the USNRC review,.as noted

• in Reference 4, item 14. This subject needs to be

                                                  ' .. considered in.any .comulative affacts . evaluation 4 Texas Utilities Generating Company

• l' Comanche- Peak Steam Electric Station IIndependent Assessment Program -- All Phases I

                       -L N JL
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' ~                                                                                                                                        Page 10 PIPE SUPPORTS                                                                            l Review Issues List
                        -13. : Support Stiffness ~                                                                                                                         ;

References:

  .1.~    Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Appendix J, Note 8                                                  -

2. N.H.'. Williams (Cygna) letter to V. Noonan (USNRC),

                                                      "Open Items Associated 'with Walsh/Doyle Allega-tions," ~ 84042.022, . dated 1/18/85
                               . Summary:'-     In designing Class 2 and 3 supports, TUGC0 has used a de-flection criteria for support stiffness. For supports with low design loads, this can result in very flexible sup-ports. This_ could affect the stress analysis results and redistribute support loads.
                              -Status:.         Cygna has deferred this. issue to the USNRC per Reference 2, item 15. This subject needs to be considered in any cumulative effects evaluation.

14.- Hydrotest Support / Stress Design

References:

1. Communications Report between Rencher (TUGCO) and -

Minichiello (Cygna) dated 3/20/84, Item 1 - l

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 4/19/84 with TUGC0. Instructions CP-EI-4.0-30, Revision'~1, attached

3. . .D.G. Eisenhut- (USNRC) letter to M.D. Spence (TUGCO),

Ites Y.E., dated 11/29/84 Summary: Cygna did not find any evidence in either the support design calculations or the pipe stress analyses -that hydrostatic test loads. had been considered. . TUGC0 responded with a copy of. their procedure which addresses the design .of temporary

    -                                            supports.

Status: Open for' internal Cygna discussion. Texas Utilities. Generating Company - l Comanche Peak Steam Electric ' Station . l L4[ , , 3 Independent Assessment Program - All Phases 1 Mmmmimmmam Job No. 84056 . , a

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3/28/85 Revision 0

                                                                .                                                            Page 11 PIPE SUPPORTS Review Issues List

. 1

15. Dynamic Pipe Movements in Support Design

References:

1. Comunications Report between Wade (TUGCO) and

                                                           -. Williams. (Cygna) . dated 9/28/83, Pipe Support Item 3

2. Comunication report between Wade (TUGCO) and Williams (Cygna) dated 10/4/83, Pipe Support Item 3

3. Cygna Phase .1 ~ and ~2 Final Report TR-83090-01, Revision.0, Observation PS-09-01

4. . Comunications Report between Rencher (TUGCO) and

                                                           . Minichiello (Cygna) dated 3/20/84, Item 2

5. . . L.M. :Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 4/19/84 Summary: JTUGCO. does not. include dynamic pipe movements in support design when checking frame gaps, swing angles, or spring

                                            ' travel. Cygna was concerned this"tould affect tiesign ade-quacy, and received a response (Reference 2) which only addressed the seismic effects. Other_ dynamic loads such as
                                               . steam hammer were not mentioned in the responser.
                       . Status:              'TUGC0 should demonstrate that dynamic events (i.e.,

steam / water hammer) which produce much larger displacements than seismic events do not impact design.

16. Dual Strut / Snubber Design

References:

'1. ~ Comunications Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/22/84, Jtem 2.b

2. L.M. Poppelwell- (TUGCD) letter.to N.H. Williams l (Cygna) dated.6/8/84^ l 1

3. Cygna . Phase 3 Final Report, TR-84042-01, '

Revision 1, Dbservation PS ' t 4. - Cygna Phase '3 Final Report,7-84042-01, Reviston 1,' Page. 5-5 ' k~ Texas Utilities Generating Company. , [ ;g , Comanche Peak Steam Electric Station f i Independent Assessment Program All Phases  : L genmummma (Jab No. 84056- ' f

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   -                                                                                                                                 Page 12 PIPE SUPPORTS Review Issues . List
                                                           " Affidavit of; Robert C. Iotti and John C. Finneran,
 ~

5. . Jr., Regarding1 Consideration of Force Distribution in-Axial-Restraints"

6. . N.H. Williams ,(Cygna) letter to J.B. George (TUGCO), .* Force Distribution in Axial Restraints - ,

                                                          . Phase 3 Open Item," 84042.014, dated 8/10/84 Summary:           While most.of the discussion on this subject has centered around axial restraints, Cygna is concerned about all types of dual restraint designs (trapezes- double trunnions, riser
                                                   - clan.ps with shear lugs). . .TUGC0 has designed each restraint in these . cases .to-take only 1/2.the total load. Also, Gibbs
                                                    & Hill stated standard practice in local stress analysis                                               4 assumes the trunnions equally. share the load. Cygna finds this inconsistent 'with other design organizations, which usually assume one side takes more than 1/2 of the overall support load. TUGC0 is currently performing an assessment in response to Reference 6.
                                 . Status:          Open pending 47UGC0 response to Reference 6.

17. . Hilti.. Kwik-Bolt Embedment length References

References:

1. Communications Re j ,

Williams (Cygna)dated port 9/28/83,-

                                                                                                   .betweenPipe      Wade   (TUGCO)

Support Item 1 and 2.1 ~ Comunications Report between Wade (TUGCO) and +

                                                          -Williams _(Cygna).-dated 10/4/83, Pipe Support Item 1                                              .
                                                   -~3. Communications ' Report between Rencher (TUGCO) and Minichiello (CYGNA) dated 10/6/83, Item 1                                                        .
                                                  . 4. - Cygna Phase I and 2 Final Report, TR-83090-01, .

' Revision 0, Observation PS-02 ' ~ Summary:  : Eeedment: lengths shown on the support drawing do not match those in the support calculation. Additional investigation by Cygna revealed that.this item has no impact on -design. . . For further details Twfer-to Reference 4.

                                  .9tatus:           Closed.                                                                                               ,

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3/28/85 Revision 0 Page 13 PIPE SUPPORTS Review Issues List

                    '18.       Incorrect Data Transmittal                                                                    l

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, l Revision D, Dbservation PS-10-01 l Summary: The displacement transmitted for support RH-1-064-001-522R had an incorrect sign.,

L5tatus: Ilosed and isolated.

19. Incorrect Standard Component Allowables

References:

1. Communications Report between Wade (TUGCO) and

                                                     . Williams (Cygna) dated 9/28/83, Pipe Support Item 4

2. Comunications Report Between Wade (TUGCO) and Williams (Cygna) dated 10/4/83, Pipe Support Item 4

3. .Cygna_ Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation PS-12-01 Summary: The incorrect U-bolt allowables were used in the design of support RH-1-064-011-522R (formerly RH-1-062-002-522R).

Status: Closed and isolated.

                  - 20.         Input Errors in the Design of Support MS-1-001-006-C72K

References:

1. Communications Report between Grace (TUGCO) and Minichiello .(Cygna). dated 5/22/84, Item 10

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams

                                                      .(Cygna) dated 6/8/84 item (41)

3. Cygna Phase .3 Final Report, TR-84042-01,.

                                                    . Revision 1, Observation . PS-01 Summary:. Jrrors wre found in the section properties and. boundary                     ,

conditions which will affect the STRUDL results. The STRUOL

                                              . input was not. checked or approved at the time of Cygna's review.

Comanche Peak Steam Electric Station M,TexasUtilitiesGeneratingCompany Independent Assessment Program - All Phases 5mMMWum Job.No. 84056 wi'

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3/28/85 Revision D Page 14

                                                                                 ' PIPE SUPPORTS Review Issues List
                                     . Status:            Closed technically. Dpen for QA significance.                                         ,
                         ~21.          Undersized Fillet Welds

References:

21. Comunications Report between Rencher (TUGCD) and

                                                                  . Minichiello -(Cygna) dated 5/16/84, Item 5

2. L.M. Po ) letter to N.H. Williams i

                                                                   .(Cygna)ppelwell dated 6/8/84   (TUGCO item (31)

3. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, .0bservation PS-04 Summary: Two fillet welds were designed under the minimum required by the ASME B&PV code, Table XVII-2452.1-1. ,

                                     ' . Status:          Closed and isolated.
                         ~22. ' Improper Weld Calculations for Three-Sided Welds

References:

1. Comunications Report between Grace (TUGCO) and

                                                                   'Minichiello (Cygna) dated 5/22/84, Item 1
                                                         .2.        L.M. Poppelwell (TUGCO) letter to N.H.. Williams (Cygna) dated 6/8/84 item (32)

3. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Dbservation PS-05

4. N.H. ' Williams (Cygna) letter to J.B. George (TUGCO) " Box Frames with 0" Gap," 84042.023, dated 1/28/85 item 3 of the Attachment

. - 5. M.H. Williams (Cygna) letter to J.B. George (TUGCO) " Mass Participation and Mass Point Spacing," 84042.021, . dated 2/8/85 pipe support review Item 5 Summary: 'TUGC0 'does not always consider-the tecentricity'-between the member center of gravity and the weld center of rigidity - . when determining weld loads to be used in the design. 5 Texas utilities Generating Company Comanche Peak Steam Electric . Station gy , Independent Assessment Program - All Phases m Job Mo.' M 56 ammimi 4

3/28/85 Revision 0 Page 15 4 , PIPE SUPPORTS

• Review Issues List

                         ' Status:        Closed for the supports reviewed in Phase 3 'and 4.                   TUGC0 should evaluate these calculations for any revision to the
                                       , pipe stress analysis which increases loads, such as those                                            l reevaluations associated with References 4 and 5.

23. -Improper Weld Calculation for Composite Sections I

References:

1. Communications Report between Finneran (TUGCD) and Williams /Minichiello (Cygna) dated 7/11/84 Item I i

2. Communications Report between Finneran (TUGCO) and Minichiello (Cygna)-dated 7/11/84

1. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 7/12/84 .

4. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation PS-07 Summary: When welding cover plates to tubesteel or widefianges to

                                         ' form composite sections, the method used for the weld design is not always correct and all the loads are not always considered.
                          -Status:         Closed based on additional calculations for the Phase 3 review scope. However, these errors should be corrected if loads increase in later revisions to the stress analyses.

24.. Untightened Locknuts on Struts

References:

1. Cygna Phase 1 and 2 Final Report..TR-83090-D1, Revision 0, Observation WD-01-01 -

  -                                        2. TUGC0 Memorandum from M.R. McBay dated 6/9/83 Summary:       During the Phase 1 walkdown, ~ Cygna moted one support on
                                         ;which the upper locknut on the strut was not. tightened.

This situation could lead to rotation of the strut and a subsequent redistribution'.of load among neighboring

                                          . supports.

Texas Utilities Generating Company Comanche Peak Steam Electric Station i- g [ 3, g Independent Assessment. Program - All . Phases

                      ,m        g    -Job Mo. 84056 o

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3/28/85 Revision 0 Page 16 PIPE SUPPORTS Review Issues List Status: Closed based on previous identification of the deficiency by TUGC0 (Reference 2) and proposed corrective and preventative actions.

25. Inverted Snubbers

References:

1. Cygna -Phase 1 and 2 Final Report, TR-83090-01, Revision D, Observation WD-02-02

2. N. Williams (Cygna) letter to S. Burwell (USNRC),

83090.021, dated 11/6/84 Summary: During the Phase 1 walkdown, Cygna note'd four supports in which the snubbers were installed 180* from the configura--

                                          ' tion shown on the support drawing.

Status: -Closed based on lack of design or safety impact. Texas Utilities Generating Company ' Comanche Peak Steam Electric Station q{ , Independent Assessment Program - All Phases Job No. 84056 q - g

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3/28/85

  ,           K                                                                                                                                  Revision 8
                                                                                                                                              Page 1 i                                                                                                                                                                                     1

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CABLE TRAY SUPPORTS , iteview Issues List l l

                  . 1. Contro111ng' Loa'd Case for Design L

References:

1. Gibbs & Hill Calculation Binder 2323-SCS-101C, 1 Set 5. Sheets 16-20, Revision 5 E

2. Consnunications (Gibbs & Hill) andReport J. Russbetween and W. P. Huang,.(Cygna Horstman S. Chang )

F dated 11/13/84

                                                   ' 3. : Gibbs & Hill Calculation Binder 2323-SCS-101C, Set 5.-Sheets 1-7, Revision 1 4       CPSES FSAR, Sections 3.8.3 and.3.8.4 1
;   ,                   Susunary:                  ' Gibbs ~ & Hill design calculations (Reference 3) assumed that the design of cable tray supports was governed by the 1/2 SSE (OBE) seismic event. The assumption was based on a
-                                                     comparison between a 50% increase in seismic accelerations from the OBE event at 4% damping,- the SSE. event at 5% '

4 damping, and an allowed increase in. design stresses of 60%

for the SSE event. :per. Reference 4.

} For' the design of structural ~ steel members, the 60% increase

cannot -be applied to certain allowable stresses. For exam-pie, in weak axis bending of wide flange beams and bending in ~ base plates,' increasing the allowable by 33% will result in:a stress level equal to yield. In addition, the allowable loads for concrete anchors-(see Generic Issue 3) '

. cannot be increased by 60% for the SSE event. Neither of 4 the- above limitations were considered in the selection of the governing load case for design. In order to reduce the loads' for SSE, Gibbs & Hill elected

                                                   - to use 7% damping for the cable trays at SSE, as allowed for

bolted structures.

. .Gibbs & Hill.provided tables -of peak spectral accelerations  ! for OBE at 4% damping and SSE tt 7% damping -(Reference 1). l

'The' reduced SSE accelerations appear to demonstrate that OBE q

                                                    ' governs' for support designs on a generic basis. However, .for
                                                                .                                                                                                                    l supports designed.using-accelerations for .a specific build-                                                                    )

ing elevation:(e.g.. elevations 773', 785' and 790':in the -

                                                    . Safeguards-Building) the. ratio of:3SE to DBE exceeds 33%.

Therefore, SSE-'can-potentially govern the design of these l

I ' Texas Utilities Generating Conpany l Comanche Peak < Steam Electric Station ~ -! < ,;.,m J'.A 1, ., . Independent Assessment Program -~All Phases ~ g a .;

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3/28/85 Revision 8 Page 2 CABLE TRAY SUPPORTS Review Issues 1.ist

                                               . supports. Support systems -at these building elevations are not included in Gibbs & Hill's dynamic analyses. The supports at the three elevations-indicated above may require additional review.

Status: Qualification of supports within Cygna's scope is complete. This issue .should be considered in any cumulative effects evaluation for generic applications.

2. Seismic R.asponse Combination Nethod l

References:

1.. CP5ES FSAR Section 3.7B.2.7 , 2.- Gibbs & Hill Calculation Binder 2323-SCS-215C, Sets 2-6 i

3. USNRC Regulatory Guide 1.92, Revision 1 e

4. N.H. Williams- (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.031, dated August.31, 1984

5. Gibbs-& Mill calculation response to IAP Phase 2 questions, Cygna Technical File 83090.11.2.1.50 Sunumary: A. Closely Spaced Modes (10% Modal Combination) in Spectral Analysis In the response spectra analyses performed for the working point deviation generic study (Reference 2),

Cygna noted that modal responses were not combined considering closely spaced modes as' required by References l.and 3.

  -                                              B. .Inclusiori of.. Dead. Load in SRSS Combination:

Gibbs & Hill design calculations typically included the

                                                      - dead load ti the SRSS with the seismic loads. This
                                                      -issue was discovered in: Phase 2 of this rev,iew, and Gibbs & Hill-performed a study to quantify the impact of-this error (Reference 5). Gibbs & Hill . calculations did not consider the effects .of frame aspect ratios 'on the
                                                      . resultant loads. Reference 4 discusses a Cygna study on
                                                                                                                                -i Texas. Utilities Generating Company g               Comanche Peak- Steam Electric Station Ly                 Independent Assessment Program- All Phases                                          ,

Job No.-84056

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   -                                                                                                                             3/28/85        l Revision B
       -                                                                                                                         Page 3 CABLE TRAY SUPPORTS Review Issues List A

the effects of aspect ratios for frame types within the review scope. The study results indicated the increases in resultant loads by combining the dead load with the seismic SRSS may be larger than those predicted by Gibbs

                                                                         & Hill.
                                        . Status:-                fA. Gibbs & Hill -has revised the working point analyses to                  .

account for. closely spaced modes in accordance with

                                                                       ~ Reference 3. For a discussion of other discrepancies in the working point deviation study, see Generic Issue 12.

3 B. 'TUGC0/Gibbs & Hill should consider the effects of the worst case frame aspect ratio on the results of the SRSS study. The~ above . issues should be considered in any evaluation of cumulative effects. Anchor Bolt Design

                                                                ~

3. ,

References:

. 1. Gibbs & Hill calculations,l" Evaluation of Detail 1, single-bolt connection," Cygna Technical File 84056.11.1.259

2. Gibbs & Hill Calculation Binder SCS-212C, Set 7, ,

Sheet 4-11, Revision .0

3. Gibbs & Hill calculations, " Justification of the adequacy of 1" Richmond Inserts for the effects of prying action," Cygna Technical File 84056.11.1.219 Summary: A. Additional Tensile Forces Induced by Rotation of Base Angles About the Centerline' of Bolt Pattern:

c n- Gibbs & Hill has evaluated Alternate Detail 1 and a single anchor base angle using A4 loads (Reference 1). v" These loads were . chosen since.the questions. regarding design adequacy originated from discussion of the A4 desi gn. . The resolution of this generic issue. requires an evaluation .of the worst case.. load and geometry for

• all; app 11 cable : supports. The geometries considered should include the effects of any generic change notices such as those for the ' base angle edge- distance (CMC 1970) and the use of shims .under base plates-(CMC 1969).

A " D L Texas -Utilities Senerating Company , Comanche Peak Steam Electric Station '

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                        ' t1
                                                                            - CABLE ltAY'5UPPORTS Review Issues List

B. - - Safety' Factor on Hilti Expansion Anchors at SSE Levels.

Also'see Generic Issue 1. . C. Inconsistent Application of ACI 349-76, Appendix B. Gibbs A Hill-has used the provisions of Reference 1 to qualify several ; designs. Examples include the qualification

                                                     , of anchorages for-Detail *11" (Gibbs & Hill drawing-2323                                                        0905,. Reference 2).and the use.of code provisions as justification' for the factors of . safety used for. Richmond Inserts.' However, other code sections,.such as B.7.3, which

, requires ~ a factor of safety of 6.0 for single expansion ' ' " anchor connections, were not adhered to. Cygna believes i ythat the philosophy of the entire code appendix should be considered prior to employing selected portions of the code.. D.' Factor.of Safety on' Richmond-Inserts. See Item C.above. E. Richmond Insert Design Allowables.

1. Prying ~ action was not considered in the original design of Richmond Insert connections for cable tray supports. c To qualify those connections which utilize Richmond Inserts,~Gibbs & Hill performed calculations which reference'the results of the Richmond Insert testing program'(Reference 3).

                                                           - These calculations showed that Richmond Inserts were .not the controlling anchorage type, but rather that the,Hilti expansion anchors were the limiting case. - Cygna' has the following consnents regarding these calculations:

w a. The ; calculations do not account for the instances where the allowable values for Richmond' Inserts from Gibbs & Hill .

                                                                      . Specification 2323-SS-30 (Ta = Va = 11.5                              ,

kips) were used without the prying

• factor.e This. situation could' occur -

whenever a CMC was reviewed. : Although .

                                                                     .- Gibbs A Mill -has stated that their !                                                      .

engineers' were instructed to include. the Texas Utilitie's Generating Company _

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3/28/85 Revision 8

• Page 5 CABLE TRAY SUPPORTS Review Issues List j i

l prying factor, Cygna could not locate any supporting documentation.

                                                           .b.- The original design calculations for concrete connections utilizing Richmond Inserts employed allowable values of tension . (Ta .= 10.1 k) and shear (Va =

9.5 kips). With the issuance of Gibbs & Hill Specification- 2323-55-30, restrictions were placed on the al-lowable values for Richmond Inserts. These restrictions dealt with the use of Richmond Inserts in cluster arrangements

                                                                  - and Richmond Inserts used in spacings less. thari.those originally considered by Gibbs & Hill, through a corresponding decrease in allowable tensions and shears. Since these restrictions were.

imposed after the. original . design .of the Richmond. Insert connections was completed, Cygna is concerned that they were not properly evaluated by Gibbs & Hill. 'In: discussions with TUGCO, Cygna - was told that the smaller spacings.of Richmond Inserts were for clustered areas that.were reserved for whip re-straints. Any use of Richmond Inserts in these areas-would require authorization from the responsible group and a corresponding. evaluation of the installation. F. Connection Designs: The' cable tray support designs provide for the use.of angles

                                                   ~ or plates at . base . connections. These designs also provide for various tolerances in the anchor bolt spacings and member placement. Additionally, field requirements may produce concrete connections which are.outside.the                                                        ;
                                                   . tolerances provided by the designs.                                        ,
                                                    - Gibbs & Hill has not' fully evaluated the effects. of all                                        ,

allowed tolerances on the base member stresses or the anchorages. , l Texas- Utilities Benerating Company Comanche Peak Steam Electric Station

                                   ' '          Independent Assessment Program - All' Phases                                                                   '
                   - IlWilmillWilllWWilli      Job No.- 84055'

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  .                                                                                                                        3/28/85 Revision 8 Page 7                       ?
                                                                    ' EABLE TRAY SUPPORTS Review Issues List port types A4 'and B4 , respectively). .If the correct unsup-
                                                    ~ ported lengths as well as pinned ends are assumed, the
                                                     ' slenderness ratio for these members will exceed 200, which
                                                      .is.theilimit for compression members per AISC Specification
                                                    ' Secti on - 1.8.4.
                                                     ;In. order to reduce the slenderness-ratios below 200, calcu-lations were performed to show that k = 0.8 (Reference .1,
                                                      . Sheets 128-146, Revision 3, and Reference.2). These calculations assumed that. rotational restraint is provided by the clip angle used to attach the hanger to the bottom of
                                                   -the slab. Additionally, since the compressive load is applied at .several points .over. the length of. the member, the
                                                    -allowable' axial stress was. increased based on the ' buckling analysis of columns with multiple, discrete axial loads
                                                                                     ~

(Reference 4). Cygna has analyzed one 'and two-bolt clip angles under compressive loading and . determined that it .is reasonable.to assume partial rotational fixity for weak axis bending of the. attached hanger. The assumption that- the tray provides

                                                     ' lateral bracing to the frame Tus not been validated (see Generic Issue 18 for a discumion of tray clamps). Cygna
                                                    ' believes that it is acceptable to consider the effective
                                                    -increase in 'allowaole axi11' loads based upon a multiple load application. Howevere the irtrease is a function of the
                                                                                                              ~

applied loads,-and must -be cElculated individually for each .

                                                     . support configuration:and load. case.

Status: - Open pending further discussion with Gibbs & Hill /TUGC0 regarding the Systems Concept (Generic Item 10) and its

                                    "                  application to the design- of cable tray supports as well as
                                                     - compliance with the' AISC specification.

5. Vertical' and Transverse Loading on Longitudinal Type Supports

References:

! 1. .Gibbs & Hill . Calculation Binder. 2323-SCS-101C, Set 2-
                                               . :. 2.        N.H. . Williams (Cygna )' letter to J.B. - George >

1(TUGCO),c" Cable Tray Support Review Questions," . .,

                                                            '84056.025,-dated August- 21 1984,- questions 3 and 4 e

Texas Utilities; Generating Company.

                  'g [ J ' A              -Comanche Peak Steam Electric Station -
    -                                     : Independent Assessment Program - All Phases 1118H111111111111111111111111 - Job No. 84056

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t 3/28/85 Revision 8 l Page 8 l CABLE TRAY SUPPORTS Review Issues List

3. R.E. Ballard (Gibbs-a Hill)-letter to N.H. Williams (Cygna), GTN-69437, dated September 10, 1984, with e attached calculatic.is

4. Gibbs- A Hill Calculation Binder 2323-SCS-101C, Set 5 .

                          . Summary:        ' Longitudinal trapeze type supports (e.g., L-A1 , L-A4 , L-C4 ,

etc.) were' assumed to act independently of the transverse supports (see Reference 4). Calculations for these longi-tudinal supports (Reference 1) consider only longitudinal

                                            . loads in the design of frame members and anchor bolts.

Since.these . supports are rigidly connected to the cable trays with " heavy duty clamps", a tributary tray mass will

                                            ' be associated with these supports.- It is- Cygna's belief that these- supports must be designed for vertical and trans-verse. seismic loads as are the transverse supports (see
                                            ~ References 2 and 3). .

Status: Gibbs & Hill should consider ~these effects'in the dynamic analysis- of .the selected systems being run in response to generic issues. Further consideration.must be given to l

                                             . isolate the above effects _ to ensure acceptability on a l                                              generic basis.

6. Support Frame Out-of-Plane Inertial Loads

References:

None Summary: Gibbs & Hill did not consider out-of-plane inertial loads in the design of two-way cable tray supports. Such loads should, as a minimum,. be. considered -in the design of base i connections and' anchorages.- Assuming'that tray clamps are able to transmit the' loads from the two-way, supports to the

   -                                          cable trays, out-of-plane loads must.also be considered in the member design of longitudinal supports (see Generic issuel8).

, Status: - Gibbs 4 Hill should provide -technical justificapion for - iignoring out-of-plane inertial; support loads. t i-L 1 Texas Utilities Generating Company

                                     . Comanche Peak Steam Electric Station bJ' A        ' Independent Assessment Program - All Phases-                                                      '

litmilmt!!mmimmm. : Job No. 84056

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M. 3/28/85 Revision 8 Page 9

                                                                 ' CABLE TRAY SUPPORTS
                                                                  ' Review Issues List ~

7. Design of Angle Sections Neglecting Loading Eccentricity

References:

 'I. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.025, dated August 21, 1984, questions 3 and 4

2. .N.H. Williams (Cygna) letter to J.B. George-

                                                       . (TUGCO), " Cable . Tray . Support Review Questions,"

B4056.027, dated. August 27,-1984, question 2

3. AISC ' Specification, 7th Edition, Sections 1.15.2 and 1.18.2.4

4. . Gibbs & Hill, calculation " Cable tray support type SP-7 with brace. Brace eccentricity -calcula-tions." Cygna Technical File 84056.11-1.228

                                                 ~5.  - Gibbs 8: Hill- calculation " Verify the adequacy of
                                                       . brace 13x3x3/8 of 4he governing support . Case C Gibbs & Hill Calculation Binder 2323-SCS-101C,3 "

Set 1, Revision _1, dated 11/16/84

6. Gibbs &. Hill caltulution " Justify the use of two L3-1/2x3-1/2x3/8 angles' to take the appropriate load and moment individually in the longitudinal tray supports at the lower brace." Gibbs & Hill Calculation Binder 2323-SCS-101C, Set 2, Revision 6, dated 9/15/84 Summary: A. Longitudinal cable tray supports typically use angle sections as bracing to resist the longitudinal loads 4 (e.g., SP-7 with brace, L-A 1

                                                                                              ,1-A4, etc). For the l                                                        member design, _ loads were assumed to produce only axial l                                                        stresses. The induced bending stresses due to eccentric h                                                        end connections were not ' considered. _ Neglecting these
                                                      -flexural . stresses can result 1n members which are under-
                                                                                            ~

I . Aesigned.-- For certain longitudinal supports, double i angles are . required. The design: assumes that.the angles L .e - behave as a composite member. However, no intermittent ,

                                                      . filler plates are provided tas required by AISC               ,

Specification Section :1.18.2.4. Thus, the houble angles must be ronsidered.to act independently. . 7 Texas Utilities Generating Company Comanche Peak Steam Electric Station L bJL 1 Independent Assessment Program - All Phases - 1

                        'lillillimillialuuluum ' Job No.' 84055

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   -e 3/28/B5 Revision 8 Page 10 CABLE TRAY SUPPORTS                                                                         i Review Issues List.

[ 1. Transverse and longitudinal cable tray supports typically use angle sections as in-plane braces to a il a . resist transverse' loads and provide bracing points on f

                                                           '. the - vertical members (e.g., A , . 4A , B3 , B4 , L-Aa, etc). For the member design,3 loads were. assumed to
                                                            . produce ~only axial stresses. ~ The induced bending stresses due to eccentric end conditions were not considered. Though it. is. not explicitly stated in the
                                                   ,         AISC Specifications, .it is. standard practice (Reference
                                                           ' 3, Sheet 3-59) to consider the bending stresses due to end connection eccentricity,and check the interaction
                                                       . ratio considering the principal axes section moduli.

C. - Single longitudinal. braces are typically connected to the frame by. welding along the legs of the angle. Some brace designs provide welding on only one angle leg at-one 'end of the brace; while, at the other end of the brace, welding is provided on the other angle leg. Such . end conditions.may lead to failure by-twist buckling. Status: . A. Gibbs!& Hill- provided calculations which considered end

                                                            . eccentricities as well as independent ' action for. each i

angle in double-angle braces (Reference 6). Case L-B4 was assumed to provide enveloping brace loads. Calculations (Reference 4) were also.provided for support type SP-7.with brace, which has a single angle

t. brace. Cygna- believes that the approach is acceptable. However, Gibbs & Hill should provide '

justification for the enveloping cases.. B. Gibbs & Hill provided.a' calculation 1(Reference 5) which . considered eccentric load application for in-plane braces.: .By reviewing'the results .of the'-working point deviation study, Gibbs & Hill found that Case C had the highest brace loads. See Generic Issue-12 for3 a

        +                                           .

discussion of the working point. deviation study. C. Cygna is presently evaluating the. possibility of twist-buckling an single-angle braces. I I L o

                        W' ::              Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program-- All Phases summmmtemum Job No. 84056 i

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              >'                                                      CABE TRAY SUPPORTS
                                                                    -. Review Issees. List                                                                        ;

8. Dynamic ' Amplification Factors -

References:

-1.=        Gibbs & Hill Report. ." Justification of the Equiva-lent Static. Load Method Using a Factor of 1.0
'                                                       Times- Peak Spectrum Acceleration for the Design of
                                                       ' Cable Tray Supports; Comanche Peak Units 1 and 2." '
                                                 ;2. Comunications Report.between J. Jan (Gibbs & Hill),
      ~

G. Bjorkman (Cygna) dated 10/4/84, 4:00 p.m.

                                                 - 3. Communications Report between J. Jan, P. Huang, J.

. Pier (Gibbs & Hill), N. Williams, G. Bjorkman

                                                                                               ~
                                                        -(Cygna) dated 9/13/84, 3:00 p.m.

.., ~4. Communications Report between J. Jan, J. Pier L (Gibbs '& Hill), G. Bjorkman (Cygna) dated 10/12/84,.10:00 a.m.

4 5. Communications Report between J.-Jan (Gibbs & . Hill), G. Bjorkman (Cygna) dated 10/18/84

.6. - Comunications Report between J. Jan, et. al.

                                                       - (Gibbs & Hill), ~H. Levin (TERA), R. Kissinger, et..

al.- (TUGCD) N. Williams, et. al. '(Cygna) dated

10/31/84 References 2 through 6. established that 1.14 is an Summary:.

Lappropriate dynamic ~ amplification;(DAF) factor. The support DAF study was based on continuous . uniformly supported L ~ spans.. ' Current' CPSES cable tray -support design methodology calculates static loads based on tributary -length. Any F future use of the.1.14 support.DAF;must account for the

                                               . difference between the tributary support reactions and the support reactions based upon continuous cable tray spans..
                                            *    - further, it may' not be appropriate to use a DAF of 1.14 if

, - ' supports are ' designed using non-uniform. tributary span length loads..

                                                                                          ~

l - Status: *

                                                  .No further work .is required, but this issue should be considered.in .any avaluation of rumulative affects.

t , s..

~

                                             ' Texas Utilities Generating Company.                                                                            ,

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CABLE TRAY SUPPORTS Review lssues List

9. Reduction in' Channel Section Properties due to Clamp Bolt Holes  ;

References:

1. N.H. Williams (Cygna) letter to J.B. George

                                                                -(TUGCO), " Cable Tray and Conduit. Support' Review Questions," 84056.015,. dated' August 6,.1984,
                                                                -Attachment 3, question 2
                                                          .2. Gibbs & Hill letter GTN-69371, dated 8/23/84,

' Calculation SCS-111C, Set.8, Sheets 34-39 Susenary: - Cygna asked about the reduction in channel section proper-ties due'to clamp bolt holes in Reference l. Gibbs & Hill. provided a response in Reference 2. 4 - The response did not to consider the following items:

A. Cable trays may be pihced anywhere in the beam span (for example, see~ CMC 2646).

                                                          -B. The resolution = did not tonsider cantilevered supports where one. tray is close to the wall and other trays are                                                     '

further out. C. The' effect of DCA 17838, which provides bolt hole gage tolerances, is not considered. D. All unused welded and flange may beholes

                                                                                               ~

present areinnot required h1gh momenttoregions. be plug-(See Note,15.on Gibbs & Hill Drawing 2323-5-0901, Revision 4.)

                                   . Status:                Gibbs & Hill should provide technical- justification for the solutions.

1

                                                                        - .ausur . [r
                                                    ~ Texas Utilities Generating Company Comanche' Peak Steam Electric Station
                          , , d{i .. Independent Assessment Program - All Phases                                                                                            ,
                                                    . Job Jo. 84056-

      . ~ . _   . . . . . .       .

i l 3/28/85 l

                                                                                                                     ~ Revision 8           )

4 Page 13 EABLE TRAY SUPPORTS Review Issues List

                                ~
                      - 10. System Concept

References:

~ 1.                N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.031, dated August 31, 1984, Attachment A.

                                                                  . question 2-

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna),' dated September 28, 1984 with attached calculations Sunnary: Gibbs - A Hill has- assumed that the cable tray and supports '

act as a system. . As part of this " systems" approach, the

                                                          - following behavior was assumed:

A. For vertical loading, torsion in the beam.as well as weak axis bending in the hanger due to the load placement eccentricities is taken out- by the tray (References .1 and 2).

                                                            .B. In the design of trapeze support hanger members for compression loads, the trays provide lateral bracirg at points along the length of the hanger (see Generic T.ssue 4).                                  .

C. The-longitudinal and transverse support systems act independently. T.herefore, the longitudinal supports are , designed for longitudinal loads only, i.e., no

                                                                   . transverse or vertical load contribution is considered (see Generic Issue 5).

D. Rotation of the base connection angles about the bolt pattern axis is minimzed by the hanger attachment to the tray (see Generic Issue 3). - .

   --                                                      ' E. . Out-of-plane seisinic inertial loads- from -two-way support frames (self-weight excitation) are resisted by .the longitudinal supports (see Generic Issue 6).
                                                    ~ Texas Utilities Generating Company
                                       -              Comanche Peak -Steam Electric Station
                       '             J'A              Independent Assessment Program - All Phases llufttilllfliittilftutnini . Job No. 84056

7, . .. + 3/28/B5 Revision 8 Page 14 CABLE TRAY SUPMRTS Review Issues List

                        . Status:             Gibbs & Hill is presently evaluating the effects due to Item

, A as part of the dynamic analysis. . Items B through E have not been fully justified considering the hardware. .Gibbs & Hill is in the process of. completing this qualification. Cygna is concerned that Gibbs & Hill's use of a " systems" concegt may not be consistent with the actual ' behavior of the c. umps used in the field..

               ~ 11'. Validity of NASTRAN Models u

References:

1. Gibbs & Hill Calculation. Binder 2323-SCS-215C, Sets 2-6

2. G'bbs & Hill Calculation Binder 2323-SCS-101C, Set 3, Sheets 234-243, Revision 9

3. Gibbs & Hill Calculation Binder THI-13C, Set 1 Sumary: Cygna has questioned the validity of the NASTRAN models used in the Gibbs & Hill generic studies, e.g., working point deviation study (Reference 1) and the qualification of-Detail Di (References 2 and 3). The models assume a row of one support type all having identical configuration and spans. This will influence the . system frequencies and seismic response. Such models may not be representative of an actual installation where a mixture of support types and spans is used.

                        ' Status:             Further justification is required prior to applying the results of these studies throughout the plant.

12. , Working Point Analysis' Study

References:

.1.          Gibbs & Hill Calculation Binder .2323-SCS-215C, Sets 2-6
                                            .2. Gibbs & Hill Calculation Binder 2323-SCS-216C, Sets 1-5                                     ,

Texas utilities Generating Company Comanche Peak Steam Electric Station [ , Independent ~ Assessment Program - All Phases gg, ,. Job No. B4056 9

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y 3/28/85 M Revision 8. Page 15 CABLE TRAY SUPPORTS Review : Issues List ,

                                         ' Summary: -                 5 A.2 ' Gibbs & Hill's working ' point' study -(References 1 and 2)

does not fully- consider the effects of change l

                                                                                ' documentati.on and previously approved. design                                                                           l deviations.. . Cut-off elevations were established using

an assumed critical: case of 8'-6" spans, enveloping  ;

frame dimensions and maximum permissible working point [ deviations. Frames below the cut-off elevations were - . not checked for compliance-with the study parameters. ' Frames above the ~ cut-off elevation were analyzed on a case-by-case basis but did not. consider the effects of change notices. The ' allowable working point deviations

                                                                           .        resulting from the study were to be used by QC to accept o                                                                                 ' installed supports. Since changes to- atty one of the above assumed parameters may effect the acceptability of the study, QC's check of working point deviations alone

i. will not assure support acceptability.

l' B. The effects of -vertical and transverse loads on longitudinal support frames were not considered in the working point study (reference. Generic Issue 5), f C. - The: portion of the study that evaluated : longitudinal

supports only checked inember interaction. No evaluation E was made to ensure that this component governed the design.

{ ' D. Modeling Assumptions t- , 1. Instead of nodeling a longitudinal support, !- the ' ands nf thedray run were assumed to be fixed. The effect of this tray ' boundary condition'on Ahe. system response was not

 ;                                                                                        ~ justified.

i F 2. The analysis assumed a single two-foot tray l- :per beam and did not assess the inpact = of more ,

realistic multiple tray loadings. -

h' 13. Eccentricities (refemnce Generic: Issue 10).  ; " ll

                                                                        .          4.--    The. assumption of tray attachment fixitt to                                                                    l the support was .not justified.                                                                           . ,   1 1                                                                                                                                                                                                         i I,                                                 +                                                                                                                                                       :

l Texas Utilities' Generating Company L . ML . - A 1 Comanche Peak Steam Electric Station

                                                               . Independent Assessment Program nAll' Phases
                                                           ' cJob No. 84056 i

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. ..- E. l 3/28/85 Revision 8 Page 16 CABLE TRAY SUPPORTS Review Issues List

5. : Selection of run configuration (reference

                        ,                   Generic Issue 11).

6. The base angle modeling assumed a simply supported beam for two bolt base connections.

7. ~ Excitation-in the longitudinal tray direction was not considered.

IStatus: Gibbs & Hill /TUGC0 should justify the modeling assumptions, the applicability of the analysis results for global support qualification, and the use of working point deviations by -QC

                                . to assure support acceptability. The above concerns should be considered in the Gibbs & Hill dynamic analysis of the five selected cable tray systems.

13. Reduced Spectral Accelerations

References:

1. Gibbs & Hill . calculations, " Analysis of Alternate Detail 1" ,

2.- Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheet 247, Revision 9 .

3. Gibbs' & Hill Calculation Binder SCS-215C, Set 4

                  'Sussnary:    - For the qualification of the supports discussed below, Gibbs
                                 & Hill used reduced spectral accelerations based on a calcu-lated support-tray system frequency
                     ,a          A. For the analysis of transverse supports,. such as type A4 which was used in analysis of Alternate Detail 1 (Reference 1). a reduced acceleration was used._ This acceleration is based on a calculated frequency which is beyond the spectral peak. The study assumes a tray weight of 35 psf and tray' spans of 8'-6". Use of this
                                   . study's results will not be valid in instal 1ations where etther 'of the above parameters have been exceeded without considering the 'effect on frequency.

B. Similarly, for longitudinal supports (e.g., type SP-7 . with brace [ Reference 3),'L-Ai [ Reference 2], etc.) the , frequency will decrease due t6 tray weights exceeding 35  ; Texas utilities Generating Company * ' q{ Comanche Peak' Steam Electric Station Independent Assassment Program - All Phases antialilli!ast i Job No. 84056-

6

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m ,m; f 3/28/85 Revision 8 Page 17

        .g CABLE mAY SUPPORTS Review Issues List
           -                                                       psf 'or longitudinal spans exceeding 40'-0". In addition, the frequency calculations for' support types-C                                                                   L-A4 , L-8 4, etc., did not' include the effect of the axial frequency .of the tray.

Status: Additional discussion' between Cygna and Gibbs & Hill is required. l 14. Non-Conformance with AISC Specifications f

References:

1. AISC Specifications for the Design, Fabrication '

and Erection of Structural Steel for Buildings, 7th Edition Susumary; Gibbs & Hill failed to properly consider the requirements of Reference 1 as discussed below. A. Unbr. aced . length for. axial buck 1ing:

1. .Section 1.8.4 requires that kl/r < 200.

Examples where kl/r-limitations were exceeded. 2. . a. See Generic Item 4. 4 b. Detail SP-7 and associated supports  ;' are checked for buckling, assuming F that the tray provides a pinned restraint at the tray attachment -

                            .*.                                                         point; therefore, k = 1.0.'.However, i                                                                                         since no restraint can be assumed,

. k = 2 and k1/r > 257 for a 12" tray. i B. Unbraced length for. lateral torsinal buckling:

    ~

1. Section 1.5.1.4.6a Tequires that' Equation 1.5- -

                                                                               '7 be used to calculate the allowable bending
                                                                           ' stress for channels. In the denominator, "1" is the_unbraced. length..of the. compression flange.                                                                 '

[ -2. Exangles where the specifications were ignored or improperly applied. MA Texas _ Utilities Generating Company Comanche Peak Steam Electric Station "o-Independent Assessment Program -All Phases 111111111 " j' - .Joh No.184056 q

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                     - -                                            ,.a                                                           .        ,..         _          _

,?}  ; , :- 3/28/85 Revision 8 w-- pag, ig CABLE TRAY SUPPORTS

                               .                     ,                            Review' Issues List
                                                                   'a. iThe ' working point analyses use 22 '

ksi for the allowable flexural .."

                                                                               -. stress without checking Equation 1.5-7. - Since the frame heights are on the order of 144", an allowable d-
                                                                               - flexural stress of 15.ksi is
                                                                         .        calculated by Equation 1.5.7.

!' Jb. . Detail SP-7'and similar supports consider "1" to be the distance to

                                                                      .        .the tray centerline and not to.the 4                                                                       .          outside rail-where the load is                                                           i
                                                                               ' applied. Use of the larger distance

. - will result = in lower allowable bending-stresses. C. Reduction in section due to' bolt holes in flanges per

                                                             'Section ^1.1D;1 (see Generir. Issue 9).

. .- D. Lacing of double angle braces'-(see Generic Issue 4).

E. Eccentric connections - Specification Section 1.15.2.

                                                             .1. This section requires that any axial members

not meeting at 'a single' working point be

designed for-the eccentricities.

2. Examples of Sesigns where this specification section applies are the gusset plates used for single angle ' braces, especially- type SP-7 with '

! , brace. Status:- l Technical justification for not complying with the Code

                                                         .should be provided by TUGC0/Gibbs '& Hill.

( i l > Texa's . utiliSies ' Generating ' Company , l

Comanche Peak Steam Electric Station d : Jab.No. 84D56-Independent ' Assessment Program - All Phases

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3/28/85 l Revision 8 Page 19 l

                                                        ' TABLE 'IRAY SUPPORTS Review. Issues List

15. Member Substitution

References:

-1. Comunications Reports between R.M. Kissinger
                                             '(TUGCO) and J. Russ (Cygna), dated 1/17/85, 8:15 a.sw and 3:45 p.m.
                         . Summary:     . A. Note' 9 on Gibbs & Hill Drawing 2323-5-0901, Revision 4, states:
                                                    " Structural members shown on' drawing numbers 2323-5-900 series may be substituted by one step heavier shape of the same size."
                                             .Cygna interprets this note as ' allowing craft to interchange structural shapes, e.g., an MC for a C or vice versa, as long as the substituted shape _is heavier than, but of the same depth as the original members.

This would allow the use of substitute sections which 4 have lower.section mduli. TUGC0 has stated that they interpret this note as requiring the craft to stay with the same shape, i.e., a C section can only be substituted by a C section (Reference 1). B. Within Cygna's walkdown scope, support number 6654 (see

                                             -Generic Issue 6) was reviewed and found to be an example of Cygna's concern as discussed above. The' design required an MC6x12 and the installed member was q C6x13                       '

which has a smaller section gdulus (S = 5.80 ind for a C6x13 compared to 5 = 6.24~in for an MC6x12). For the other supports listed in Generic Issue 6, the required MC6x12's were substituted with C6x8.2's, a substitution not permitted by this note. C. Cygna could not locate any documentation which informs engineering where such substitutions .are made. Status: TUGC0/Gibbs & Hill should provide justification of such substitutions and the. requirements for documentation of the substitutions. ,

                                                                                                                           . i t

4 Texas Utilities Generating Company Comanche Peak Steam Electric Station

                   -     b     L A    Independent Assessment Program - All Phases-i
                     ## E " " E -Job No. 84056

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3/28/85 Revision 8 Page 20 f CABLE TR U SUPPORTS <1 Review Issues List 1 1

                                            .-                                                                                                                                                t
              ;16.f Weld Size Requirements                                                                                                                                                    .

1

                      ~ 

References:

- 1. - N.H.: Williams ' (Cygna) letter to V. Noonan (USNRC),                                                                                              l
                                                " Response to 15tC Questions," 83090.023, dated

March 8,'1985 .

                                           -2. Comunications Report between Chang and Huang (Gibbs & Hi11).and Horstman, Russ and Williams (Cygna) dated 10/27/84

! 3. Comunications Report between Chang and Huang (Gibbs 8 Hill) and Horstman, Russ and Williams (Cygna). dated 11/13/84

4. Communications Report between Chang and Huang

. (Gibbs & Hill) and J. Russ -(Cygna) dated.11/17/84 i ! 5. Communications Report between R. M. Kissinger (TUGCD). and J. Russ (Cygna), dated 11/30/84 I

6. N.H. Williams (Cygna) letter to J.B. George ,

(TUGCO),: " Cable Tray Support. Review Questions," 84056.041, . dated February 12, 1985 Summary: Cygna has discovered the following problems with the weld designs of cable tray supports. 4

                                         - A.  .The design drawings are missing the weld details as described in Refe.ence 1. Attachment C.
                                         .8. Per discussions with Gibbs & Hill /TUGC0 (References 2,

! 3, 4 and 5), Cygna has noted that.the weld sizes shown  ; on the fabrication drawings differ from those shown on the design drawings and those that were assumed in Gibbs t 3

         ,                                      & Hill calculations.                                                                                                                          l C. Eccentricities were not~ considered in-weld connections.                                                                                      l

1. Detail'5P-7 with trace and similar connections i 7 require a partial. penetration groove weld at >-

the gusset plate / beam connection. The design , calculations did not consider the eccentric ' load transfer from the brace member. The 1 eccentricity of the brace loads results in a ' wald e+emee in avemee af Ann be4 , l Texas Utilities Generating Company g( , , Comanche Peak Steam Electric Station. Independent Assessment Program - All Phases >

Job No. 84056 i- l

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    .                                                                                                                                            i 3/28/85 Revision 8 Page 21 CABLE ' TRAY ~ SUPPORTS Review Issues List                                                                 .

2. Weld designs for base angle connections never considered the eccentricities of the applied' '

loads from the connecting members. ' D. The weld designs did not consider the thickness of the

connected parts. Gibbs & Hill's weld designs assumed that the full weld throat would be developed without considering the thickness of the-connected member.

E. Gibbs & Hil1 ~ assumed an incorrect ninimum weld length for the beam / hanger base angle connection.

1. Gibbs & Hill assumed a distance of 1-k, where 1 = angle leg width and k - distance from back of angle. leg to-end of. fillet.

                                        ~ 2. Because'of the Tadius of the curve at the angle toe, r (approximately equal to one-half the leg thickness), the actual weld length is 1-k-r.

Status: Items A-D are open pending response to Reference 6. Item E i requires discussion with TUGCO. - 1 '

17. Embedded Plates Design

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable -Tray Support Review Questions,"

84056.041, dated February 12, 1985, Attachment A, , question 1

2. L.E Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984, page 11

3. Comunications Report between Williams, Russ -and

                                      . Horstman (Cygna), Kissinger and Keiss (TUGCO).and
                                         .Bhujang, Huang and Chang (Gibbs & Hill) dated                                                     4 9/15/84                                                     ,

I

4. Comunications Report between & Warner (TUGCO) .

and N. Williams, J. Minichiello and J. Russ

                                          -(Cygna)-dated 2/27/85 Texas Utilities Generating Company Comanche Peak Steam Electric Station            '

sessment Program - All Phases h  ; jne de ,

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o 3/28/85 Revision 8 Page 22 CABLE TRAY SUPPORTS

                                                         - Review Issues List Susunary:    - Cygna's review of cable tray attachments to embedded plates
                                    -indicated that the allowables for the embedded plates may                                      )

not have included the effects of prying action (Reference 1). -Additionally, questions from Cygna's pipe support reviewers and cable tray reviewers on the stiffening re-

                                    . quirements for embedded plate moment connections elicited conflicting responses. from TUGC0 personnel. One response indicated that attachments to embedded plates act as stif-feners for moment connections (Reference 2) while another indicated that any moment attachment must be stiffened or sufficiently ' analyzed (Reference 3).

Cygna has also noted that cable tray embedded plate designs were not 'within the tolerances of Gibbs & Hill Specification 2323-SS-30 " Structural Embedments" (Reference 1). Cygna is 'also evaluating the lack of attributes for embedded plate inspections on.the QC Inspection Report forms. as -well as the verification procedures for1ttachment proximity criteria (Reference 4).

                    ' Status:        TUGC0/Gibbs & Hill should provide justification for the above items.

18. Tray Clamps

References:

None Sununary: The cable trays have been assumed to provide bracing to the tray supports for the following modes of behavior:

• Buckling of the hanger members.

    .-                                       *   .. Lateral torsional . buckling of the beam mem-bers.

e ' Bracing of-the support frame to prevent frame ' rotation which would result in anchor bpit ' overload. Such tracing,nay occur only if the tray' clamps provide suitable compatability conditions. Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program:- All Phases

               .b   [ilHHmiltithi i

Job No. 84056

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. , i l V CABLE TRAY SUPPORTS Review. Issues List Status: Cygna is currently evaluating the various clamp designs to establish their: capability to provide sufficient load tran-

                                                          .sfer.

19. Other' Loads-in'the FSAR Combinations

References:

. ^ 1. :CPSES :FSAR, Section 3.B.4.3.3 . t-

2. Gibbs & Hill Calculation Binder SCS-103C, Set 1

                                                                 ' Sheets 14-19

3. Gibbs-& Hill Calculation Binder SCS-103C, Set 2

' Sheet 32-I Summary: Cycna is concerned that all applicable loadings, as defined

                                                         -in Reference 1,-are considered in the design of. cable tray J supports.: Among these concerns are.10CA' loads. Reference.2
                                   ,                     - provides the calculations for Detail "A". (Gibbs & Hill

, drawing;2323-El-0500-01-5), which 'was. originally designed

,' ' for 'use in containment. Only dead weight and seismic loads were considered in this design. Similarly,-Reference.3 is l the design calculation for Detai1 ="C" (Gibbs & Hill drawing i i 2323-El-0500-04-5). .This

support was only evaluated for dead weight and seismic loads.

                                                                           ~

i-L Status: Discussion with Gibbs & Hill /TUGCO.is required to establish the exact criteria for not specifically evaluating other possible ~ support loadings.

20. . Differences Between the Installation and the Design / Construction Drawings without Appropriate Documentation 4  ;.. .

References:

- 1. Gibbs &' Hill, Inc.,. support ~1ayout drawing t

                                                                 ' 2323-El-0713-01-5                                                                            i

2. Brown.A Root Inc., fabrication drawing FSE-00159 ,

3. Amerien Institute of Steel Constrection, Inc., -

Manual of Steel . Construction, 7th ~ Edition ' ,

                            ~
                                                         ;4. Gibbs & Hill support layout drawing 2323-El-0601-DI-S I                                                    Texas . Utilities' Generating Company -                                                                  ,

Comanche Peak Steam Electric Station ' ' ' ' Independent Assessment Program -' All Phases

                                                ' Job'Wo.'84056

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e 3/28/85 Revision 8 Page 24 i CABLE TRAY SUPPORTS Review issues List

5. Gibbs & Hill support layout drawing 2323-El-0700-01-5

                                           '6. . Gibbs '8' Hill cable tray. support design drawings 2323-5-0900 series -

Summary: Cygna performed walkdown inspections on 49 of the 92 , supports within the' review scope. . Certain discrepancies  : between the as-built' support configurations and the design

                         -                  requirements were as noted below.

A. Support No. 481, Longitudinal Type A4 Single _ angles were installed as braces in the longitudinal direction. A pair of angles is required by the-design drawing. No change documentation was located.

                                           .B. . . Support No. 408, . Type B4_

4 ' The lower corner of the frame is modified by CMC 9916 Revision 1 to avoid interference with the CCW heat ex- - changer. This change document shows that 4" channel sections are to be used for the prescribed modification. A 6" channel section is actually i installed. ! -C. Support No. 649 Type - Ai This installation uses toncrete anchorage " Alternate

Detail 1" (Gibbs & Hill design drawing 2323-S-0903) which requires the use 'of an L6x6x3/4. Cygna's field 4 inspection discovered that an L5x5x3/4 was installed. No existing documentation accounted for this discrepancy.

,   v                                       D. . Support Mos. 722 and'.2606..Deta(1 L*N"4 Drawing
;                                                 2323-El-D601-01 i                                                  Cygna's' field -inspection found a. working point violation on the brace attachment to the wall. Design drawing ,                                        ,

I 2323-5-0929 Connection Detail "F" was used 12323-5-0903) which has a tolerance of b/2

• 0.3b where 12"<b430". ..

                                                 ' Cygna's field inspection results show the tolerance used was b/2- 0.5b (i.e., the brace was located in line with
                                                   ... w Texas Utilities' Generating Company                                                                 ,   i

! Comanche. Peak -Steam Electric Station ' ' l A Independent Assa.ssment Program -'All Phases Rellumn'muil Job Mo. 84056

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                  ,                                                                                                                                          Page'25 CABLE EtAY SUPPORTS Review lssues. list 1

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                                                               ..E.-            Support Nos. 2992, 2994, 3005, 3017, 3021, 6654. Type A2 Reference 1 identified' the above six supports as
                                                                             ;follows:          "A where L = 8'2-3"(except   -(frame.allwidth),members  h =shall 4'-2"be(frame MC6x12),"height).

1 The Cygna walkdown documented the installed hanger member. sizes, 'as listed below in Table 1. Due to the ~

                                                                             - presence of Thermolag coating, Cygna was unable to
                                                                             -determine the-installed beam member size. No documentation existed to reconcile the differences between the design requirements and the installation.

l TABLE 1 l j - Cable Tray Support Member Sizes Dimensions (See Note 1) Member Size i - Flange l Support Depth Width Existing i No. (In) f(In) -(Note 1) ! 2992 6 1-7/8 -C6 x 8 7 2994 6 1-7/8 C6 x 8.2. ,

                                                                                  '3005               6                  1-7/8          C6 x 8.2 3017               6                .1-7/8           C6 x 8.2.

3021 6 ~ 1-7/8 C6 x 8.2

      .                                                                            6654               6                  2-1/8          C6 x 13^
                                                                                                                                   ~
                                                                                                                                           .                                             i Note:           1. Dimensions of-the vertical channels are based on measurements by Cygna.

l Member sizes are -determined by selecting the channel type from j, ' , Reference 3 which most closely , inatches-the measured depth and flange i width. 1 F. . Support 'Nc. 455. Type SP-8 Cygna's field inspection indicated that the brace connected to the wall on one side of the support is located outside of the bolt pattern on the base angle'.  ! The Detail "B" (2323-5-0903) type connection requires a - tolerance'of b/2 1 0.2b. In response to Cygna's - question, TUGC0 issued CMC 99307,~ Revision 0, to document this discrepancy. *

                                                                      ~
                                                      --Texas Utilities Generating Company                                                                                            ,.

Comanche Peak Steam Electric Station L L { 4 . Independent Assessment Program - All Phases-mmm==mummemmum Job No.-84056' i l , t

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3/28/85 Revision 8 ) Page 26 CABLE TRAY SUPPORTS Review Issues List [ G. Support Nos. 2998 and 13080, Special Type Supports These supports were installed in floor slabs with 2" topping. The topping depth was apparently not considered in selecting the length of the anchor bolt. Therefore,-the required embedment lengthLwas not achieved. Status: ' A. TUGC0 provided CMC 2635 Revision 1, to document the l' installation discrepancy for support number 481.

 .                                           B.       TUGC0 provided CMC 9916, Revision 2, to document -the installation discrepancy for support number 408.

C. TUGC0 provided CMC 99308, Revision 0, to document the installation of the incorrect size base angle for support number 649. D. 'TUGC0 provided~ CMC 99309. Revision 0, to document the ' anchor bolt installation discrepancy for these two supports. E. TUGC0 provided the CMC's listed below to document the installation of the , incorrect member sizes. Support - Number CMC No. . Revision 2992 44519 2 2994 99326 0 3005 96079 1 3017 99327 0 I 3021 30452 2 6654 90714 6 F. .TUGC0 provided CMC 99307, Revision 0,' to document the

                                                     -installation discrepancy for support number 455.

! .S. TUGC0 is to evaluate the effect of reduced ymbedment ' l . length for supports 2998 and 13080. Cygna is evaluating the action required by SDAR 80-05 for supports -installed "* after its issuance. .

M . TexasComanche Utilities. PeakGenerating Steam Electric Station Company sessment Program - All Phases g, e de j 9

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3/28/85 Revision B Page 27 CABLE TRAY SUPPORTS

                                                                    -Review Issues List

21. - Design Control t

References:

' 1.

Gibbs & Hill Drawings 2323-El-0601-01-5, 2323-El-0700-D1-5,.2323-El-D713-01-5

2. N.H.' Williams (Cygna) letter to J.B. George (TUGCO), "Catie Tray Support Design Review Ques-

                                                         .tions," 84056.022, dated August 17, 1964, ques-tions 1, 2, and 6

3. N.H. Willians (Cygna) letter to J.B. George

                                                          -(TUGCO), " Cable Tray Support Design Review Questions," 84056.025, dated August 21, 1984, question 1

, 4. . Gibbs & Hill-Cable Tray Support Design Drawings 2323-5-0900 Series

                                                    .5. . Gibbs A Hill Calculations for Support Nunbers ^3025, 3028, 2861 Cygna Technical File 84056.11.1.225

6. L.M. Poppolwell (TUGCO) letter to N.H. Williams (Cygna), " Responses to Cygna Review Questions,"

                                                          - dated September 4,1984, with attached calculations

7. Gibbs & Hill Calculation Binder 2323-SCS-101C, Set 3. Sheets 206, Revision 6

                                                    .8. L.M. Poppelwell' (TUGCO) letter to N.H. - Williams (Cygna), " Response to Cygna Design Review Ques-tions," dated September 11, 1984, with attached calculations

! 9. Gibbs A Mill . Calculation Binder 2323-SCS-101C, Set 5

                                                 .10.      Gibbs & Hill Drawing 2323-5-0901, Revision 4
 .                                                                                                                          ,      i.  ',

i

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! Texas utilities Generating Company ! Comanche Peak Steam Electric Station k A Independent Assessment Program -- All Phases i '. Job No. 84056

   ,                                                                                                         '3/28/85 Revision 8 Page 28 i
                                                  ~ CABLE TRAY '5UPPORTS Review Issues List

11. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support and Electrical Review Questions," 84056.019, dated August 10, 1984, ques-tions 2.1 and 2.2

                                -12. Gibbs & Hill Drawings 2323-El-0601-01-S, 2323-El-0700-01-5, ' and 2323-El-0713-01-S Summary:         A. Lack of consideration of the effects of generic CMC's

. - and DCA's .on the original designs:

                                        .1. -Support type SP-7 with . brace is affected by CMC 6187. The CVC was approved and design reviewed by Gibbs & Hill, New York, but its effects were not considered in the SP-7 with brace calculations or any generic reviews.

2. ' The effect of CMC '1970, which specifies the i allowable edge . distance for anchor. bolt holes in base angles. was not considered in the design of the anchor bolts.

B. Criteria violations in individual support specifications on support plans: In the generic design of cable tray supports, support dimension and loading limitations are determined for each support type. These limitations are typically stated in the design calculations, but are not shown on the generic support design drawings (Reference 4). The dimensions for each support are specified in a descriptive block on the support plans (Reference 1) and the loading. is indicated by the supported tray width shown.

The tray supports listed below were identifind as having loadings or support geometries which exceeded the design limitations. Prior to the Cygna review, justifying

! documentation did not exist for these individual . support i , . designs. , i l 1 Texas Utilities Generating Conpany l J( , Comanche Peak Steam Electric Station g ,g g g e nde t Assessment Program - All Phases

                                                                              ..                         .                    ..    -                .=              ..
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3/28/85 Revision 8 Page 29 CABLE ' TRAY SUPPORTS

                                                              . Review Issues List 1.: Support Nos.'3025,~3028, 2861 Type Di.
                                                      . Drawing 2323-El-0713-01-5 calls out tfiese supports as type D 16.3), L = 11 -9*,3h (except                = 4'-2", beam   to be and shows            MC6 x
                                                                                                                           . a tray width of 78". The FSE-00159 fabrication drawing sheets reflect these dimensions. How-ever, the Gibbs & Hill design calculations for Type Di supports (2323-5-0901) limit L < 8'-0" and tray width to 48".

2. Support No. 2607. Type A1 . Drawing 2323-El-0601-01-S specifies dimensions of L = 2'-9" and h = 4'-6" for this support. ' The design calculation for this support type (S-0901) limits h < 2'-4".

3. Support No. 657. Type A1 . Drawing 2323-El-0601-01 calls out this support as Type A1 , L *

' 7'-0", h = 2'-0". . The design calculation for this support type limits L 4. 6'-0".

4. . Support No. 734, Detail H. Drawing 2323-El-0501-01-5. This drawing specifies that one beam is to be an MC6x15.1 rotated 90' from its normal orientation. ihe support design requires the use of C6x8.2 beam . sections. CMC .

00164 requires the use of " heavy duty clamps" for this support, which introduce it,ngitudinal loads. The support design requires the l addition of a longitudinal

• brace if longitudinal loads are to be resisted.

5. Suppor, No. 3011. Type SP-6. Drawing 2323-U-0713-01-5 specifies dimensions of L = 8'-9" and h = 4'-6". The design calculation for this support; type limits L < 6'-0".

6. . Support Nos. 2992, 2994, 3005, 3017, 3021, 3111, 6654, Type ;A2 . Drawing 2323-El-D713 5 specifies dimens1ons of L = 8'-3" .and -h = <' /

4'-2", and shows a tray width of 78". The design calculation for this supoort type .. limits L 4,6'-0" and the tray width to 48". l Texas utilities Generating Company i M Comanche Peak Steam Electric Station l Immtemte *( 5 f

            - , , . . . . . . . . . . ... .             - . - - - . . . . .        . , +              .     .,                      .-
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CABLE TRAY SUPPORTS Review Issues List C. Consideration of as-built support . conditions in generic reviews which require a case-by-case review:

1. LThe SP-7 weld underrun analysis considered 5/16" . fillet welds ^which are specified on the design drawings. However,~the FSE-00159

                                                                            - fabrication drawings specify smaller weld sizes. : .In addition, the underrun analysis did not consider the effects of any design changes to the supports which were reported in CMC's and DCA's.

2. --Working point studies (reference Generic Issue

                                                                            ~12).

D. Inconsistent application'of as-built and design

                                                                   ' information in the. evaluation of cable tray supports for
>                                                                     Tharmolag application:

1. Tray cover weights were not -included in the development of the allowable span length table (Procedure CP-El-4.0-49)..

                                                                     .2. Cygna believes that longitudinal supports are

not evaluated for the added weight 07' fire j protection. Evidence of the above includes the fire protection review for the tray run containing Detail "N" (Gibbs & Hill Drawing.

2323-El-0601-02-5) which did not note the lack ' of any longitudinal supports in the tray run. . 3. Fire protection evaluations are performed on a tray-by-tray basis. The cumulative effect of multiple trays with fire protection on one support may not.be considered. t !~ Texas utilities Generating Company 3 a Comanche Peak Steam Electric Station Independent Assessment Program - All Phases . NN - SWR i

                                                    . Job No.-84D56

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                                                 ~

r , t CABLE. TRAY SUPPORTS  :

                                                                                               %                Review Issues List

[ ..E.  : Tray' span between supports used in the original support , layout: L 1. . . Ref erence - 9 ; indicates that' cable tray supports , . i~. are tof be designed for '8'-0" spans. Reference "10,; Note 13, allows a location tolerance for

                                                                                                       ~ supports of

• 1/2 Richmond Insert spacing parallel to. the' tray, and limits the maximum s

spacing between supports to g'-0." Gibbs &

                                                                                                      ' Hill- cable tray support design calculations
                                                                                   ?

assume a maximum tributary span- of- 8'-6 " to i account for!a support spacing of 8'-0" on

,                                                                                                       center and an' erection tolerance of

• 6."

Cygna reviewed: Reference 12 and noted 14 , i

                    +,-

locations 'where the as-designed. tray spans

                                                                                                      . exceeded- 8'-0." Cygna's walkdown of. these
                                                                                                     . tray segments discovered five locations where

! the' as-built ~ tray spans exceeded 9'-0" (see " i- -Reference.11). This indicates that .the design and-installation .111nitations-for support. I spacings 'were .not adhered to. h ) 2. ' Longitudinal . support designs indicate that the

maximum longitudinal tray span is 40'-D". For

several- supports' within Cygna's review, the support plan drawings!.(Reference 12). specified t

                                                                                                     'these supports to have tributary spans greater                                                                                   .        ;

than 40'-0" (see Reference ~11). In'. addition. L .several horizontal tray segments were 'not-provided with longitudinal supports (see Reference 11). This indicates that the design limitations for the location :of ' longitudinal supports were not adhered to.

                                                                                                                          ~

s F. Use.'of "For Reference Only" Calculations: 3

. Cygna has noted several design reviews of change notices l' where the CVC was marked to indicate that new.or revised

!- calculations'were not required. :However, attached to i< v the CfC are . calculations that are marked "For Reference _Only..- i G. .. Cygna is concerned about support : design calculation retrievability and coupleteness.

                                                                      . Texas utilities Generating Company                                                                                                                                .

• b ~ Comanche Peak. Steam Electric -Station

                                         *                             ~ Independent                    ' Assessment             - Program            - - All Phases -                                                                   ',

l Job No. 84056 - , r A P Y I

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7/ 3/28/85 s ^ Revision B

                               -                                                                                          page 32 CABLE TRAY SUPPORTS                                                         I Review Issues List                                                         l H.         Lack of Controlled Design Criteria:

1. - Cygna has noted instances where the field design review group did not utilize the proper criteria to evaluate support adequacy. The

                                               '                       evaluations for fire protection compared the
                                                                   , actual load to a design load based upon a 9'-

0" tributary tray span. The maximum tributary i, span assumed in the current design is 8'-6". 21 Cygna has asked what supplements to the 7th

                                                                     ' Edition of AISC . Specifications were committed
-                                                                      to in the FSAR. 'No evidence was found to indicate th'at proper direction was given to 7

design engineers to utilize the requirements of any supplements to which CPSES was

;:                                                                     committed.

Status: ' A. No further discussion is required. B. Gibbs & Hill has indicated that the engineer preparing a support layout drawing would be- familiar with the design

                                                               -limitations. Based upon engineering judgement, these limitations could be exceeded without preparing supporting calculations, since the support map drawings would be subject to design review.
                                                       . . For the' individual supports referenced above:

(1) Gibbs & Hill provided calculations (Reference

5) evaluating these. supports. Support i numbers 3025 and 3028 were found acceptable, support number 2861 shows 30% overload of anchor bolts.

(2) TUGC0 provided' calculations (Reference 6)

                                                                     -   demonstrating the acceptability of support

_ lumber 2607. ,s ' '1 Q (3) LTUGC0 provided calculations (Reference'6) demonstrating'the. acceptability of support - 1 j . nunber 657. y ?q

                    '3;                                      1 l
                                               */ Texas Utilities-Generating Conpany                                                                '

L. g Q e , , Comanche Peak' Steam Electric Station' .

muunnummmuumn Independent Assessment Program - All Phases q l 2ob-No. 84056 L:  ?

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l 3/28/85 l l Revision 8 l Page 33  ! CABLE TRAY SUPPORTS Review Issues List (4) Gibbs & H111/TUGC0 have not provided a response. (5) Gibbs & Hill provided calculations (Reference

7) demonstrating the acceptability of support number 3011.

(6) TUGC0 provided calculations (Reference B) demonstrating the acceptability of.these supports. C. No further discussion is required. D. Cygna is continuing internal evaluation. E. Gibbs & Hill has indicated that the engineer preparing a support map drawing would be familiar with the span limitations for transverse and _ longitudinal supports. Based upon engineering judgement, these limitations could be exceeded without preparing supporting calcula-tions, since the support map drawings would be subject to design review. For the individual _ span violations moted above,

1. Gibbs & Hill /TUGC0 provided calculations qualifying trays and supports for the transverse . span violations.

2. Gibbs & Hill /TUGC0 provided calculations qualifying trays and supports for the indicated longitudinal span viola-tions. For tray segments lacking

                                                         ' longitudinal supports, the load was applied as additional transverse loads
 .                                                        on transverse. type supports located around a 90* bend from the unsupported tray segment. ;For one tray run without any existing wechanism to resist longitudinal loads, segments T1205BC25    '
                                                                                                        /
                                                        < and T1305CA45, the addition of a hew
                                                         -longitudinal support was required.                ..

M( ~ Texas utilities Generating Company. Comanche Peak Steam Electric Station Independent - Assessment. Program J All Phases ImlilillHillllilllillt -Job No. 84056

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                                                                                                .3/28/85' Revision B Page 34 CABLE TRAY SUPPORTS Review. Issues list F. Cygna is continuing internal evaluation.                                           '

G. 'Cygna is continuing internal evaluation. H. Cygna is continuing internal evaluation. l .. l Texas utilities Benerating Company g i j, ,  : Comanche Peak Steam Electric Station . Independent Assessment Program - All Phases Isilillmmminimmt

                               . Job-No. 84056

i * , , l [ 3/28/85 Revision 0 Page 1 CDMDUIT SUPPORTS- < i Review Issues 1.ist

1. Cont' rolling Load Case for Design

References:

fl. Comunications Report between R. Kissinger (TUGCO), B. Bhujang (Gibbs & Hill), and J. Russ 1 and N. Williams (Cygna) dated 10/1/84 Summary:- A. Gibbs & Hill r.alculations assumed that the design of

                                                                      . conduit supports was : governed by the 1/2 SSE (OBE) seismic event. The assumption was based on a comparison                                                       '

between a 50% increase in seismic accelerations from the OBE event at 2% damping, the SSE event at 3% damping, and an allowed increase in design stresses of 60% for the SSE event, per Reference 4. B. For the design of structural steel nembers, the 60% increase cannot be applied to certain allowable stresses. For example, using a 33% increase, allowable stresses for weak axis bending of wide flange beams and

                                                                     . bending insbase plates will equal the yield stress. The allowable loads for concrete anchors cannot be increased by 60% for the SSE event. Additionally, the catalog component allowables are not allowed.an increase for SSE

' loads. The-above limitations were not considered in the

                                                                    . selection of the governing load cas,e' for design.

L Status:. - Discussion with Gibbs & Hill is Tequired. Also see Cable

                                                                                                   ~

Tray Generic Item 1..

2. Dynamic Amplification Factors

References:

.1. Comunications Report between P. Huang (Gibbs & Hill)-and J. Russ (Cygna) dated 2/5/85

2. Comunications Report between P. Huang (Gibbs &

Hill) .and J. .Russ (Cygna) dated 2/6/85 . 3. Gibbs. A Hill Calculation 2323-SCS-100C, Set 4 Sheets 1-11 ,

                                                                                                                               ,         .?

Texas Utilities-Generating"Iompany gd', . Conanche Peak: Steam Electric Station Independent Assessment Program - All Phases. . l f Job No. 84056~ l __...-.--___-_._L_'__.LL..--_. . - . - - - . . ~ . . -- - ,

3/28/85 Revision 0

        .                                                                                                    Page 2 CONDUIT SUPPORTS Review Issues List Susumary: -        Gibbs & Hill has submitted a calculation for justification of a dynamic amplification factor- (DAF) of 1.0. That cal-culation was based.on a Class 5 piping damage study. The results of'a similar study.for cable tray supports established 1.14 as an acceptable Dynamic Amplification Factor. .

Status: . A reevaluation of the conduit DAF is required based on the

                                                  - results of the cable tray amplication factor evaluation (see
                                                  ' Cable Tray Generic Item 8).
                        .3.

Combination of Deadweight and Seismic Responses

References:

1. Gibbs & Hill Calculation 2323-SCS-109C, Set 1,

. Sheets 154-163 Susumary: Deadweight is added to the vertical acceleration, and then combined using.an SRSS . combination with the hori2ontal acceleration components. Gibbs & Hill has submitted calculations which consider the acceleration vector magnitudes-and compare the standard combination method to the SRSS method used in the support designs. The unconservatism -is' .small and conditionally acceptable. . The effect, however, must be considered with other cumulative effects (see Item 24). --Also see Cable Tray Generic Item 2 for a discussion of the effect of aspect

                                                  - ratios on the resultant loads.

4 Status: TUGC0/Gibbs & Hill consider the ' effects of.the -worst case frame aspect ratio on the results of the SRSS - study..

4. . Measurement of Embedment from Top of Topping

References:

None Samunary: Note 5a on 'Gibbs & Hill Drawing' 2323-5-D910, Sheet G-4a allows reduced.embedment for..certain. supports at . lower- , ,

building elevations. * <

                                                  ..Such a reduction is not acceptable for 1/4" and 3/8" Hilti Kwik-bolts with 2" embedment requirement since-these' bolt:;
                                                   .are embedded in topping only.

Texas Utilities Generating Company Comanche Peak Steam Electric Station L L ;L A . Independent Assessment Program - All Phases

                     . gungnu ;       ..m .
                                              . Job No. 84056 1'     '

3/28/85 Revision 0 Page 3

                                                       ~ CONDUIT SUPPORTS Review Issues-List The reduction may not be acceptable for other sizes depending on the actual acceleration versus the design acceleration. The affected support types within Cygna's scope are the CSM-18 and CST-17 series.

Status: ~ Technical justification is required for instances allowed by the note.

5. Bolt Hole Tolerante and Edoe Distance Violation

References:

1. Gibbs & Hill Drawing 2323-5-0910, Sheet G-Ib, Note 15

2. AISC Specifications, 7th Edition, Section 1.16.5, Minimum Edge Distance

3. AISC Specifications, 7th Edition, Section 1.23.4, Riveted and Bolted Construction - Holes Summary: The AISC Specifications do not provide for bolt hole tolerances.- Per Reference 2, bolt holes are 1/16" larger than the bolt size. Reference 1. allows a tolerance, which varies with the bolt size.-

Reference 2 requires that a minimum clear distance be ' maintained for oversize holes. Gibbs & Hill . designs do not l provide the minimum edge distances required in the AISC Specifications. Support types CA-Sa and CSM-42 provide edge  ! distances of 3/4". Per Reference.2, 25/32" is required. l I Status: Discussion with Gibbs & Hill is required.

 .                    6. -Other Loads in the FSAR Combinations

References:

.'1. CPSES FSAR, Section 3.8.4.3.3 Susmeary: .Cygna is roncerned that all. applicable loads as defined in

                                         ' Reference 1 were not specifically considered the conduit support designs.                                                   ,        j 1

Texas Utilities Generating Company Comanche Peak Steam Electric Station  ! y[dd Independent Assessment- Program - All Phases .

                                     , Job No.-84056 1

I

                      ~:. . , :.        .

3/28/85 Revision 0 Page 4 CONDUITESUPPDRTS Review Issues List These concerns include loads due to pipe whip and jet impingement as well as the use of design accelerations which do not. envelop Containment . Building and Internal Structure spectra. Status: Discussion with Gibbs & Hill is required to determine 'if any

                                              ~ justification exists. Also see Cable Tray Generic Item 19.

7. Support Self Weight

References:

1. Cygna Generic Conduit Support Review Checklists-(not yet issued)

Sumary: Cygna's review has noted that support self weights were not uniformly considered. For some' designs only a portion of the support weight was considered. Examples include conduit supports which consist of cantilevered tube steel sections where only the length to the conduit centerline was considered. Additionally, the brace weight for. support type CSM-6b was not considered.

                                              'For other designs the support self weight was neglected such as CST-3 and CST-17 Unistrut supports are affected.

Status: Discussion with Gibbs & Hill is required. This item affects the design of anchor bolts. See cumulative effects, Item

                                               .24. Also see . Cable Tray Generic Item 6.

< 8. Torsion of Unistrut Members l

                                                                         ~
                                                                                                                                         \

References:

1. N.H. Williams (Cygna) letter to J.B. George 1 (TUGCO), "Cygna Study of Unistrut Torsional  !

l Capacity,5 84056.040, dated January.18,1985 2.' Comunications ' Report between R. Kissinger (TUGCO) and J.' Russ '(Cygna) dated 1/8/85

3. Comunications Report .between S. McBee (TUGDD) and J. Russ (Cygna) dated 2/21/85 -

4 Texas Utilities Genarating Company I 4[tj g' 3 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases mimillillimmimum Job No. 84056

                                                                                                               - - + ,    - , , -

             , - - - .          .-  .            _.        . ....-    w..   . .,   .._ , .. .,.,a_.__,,,,            ,
  .     .-   r 3/28/85 Revision 0 Page 5 CONDUIT SUPPORTS Review lssues list
                                         '4. Communications Report between R. Miller (CCL), R.

Kissinger and S. McBee (TUGCO), and J. Russ and N. Williams (Cygna) dated 2/25/85 Sussiary: Torsional loading of Unistrut members is not considered in the support designs. Unistrut does not support the use of members for torsional loading. Status: TUGC0/Gibbs & Hill are ' evaluating the effects of torsion in the Unistrut test program. Cygna personnel visited the CCL test labs (Reference 4) and provided t.he following comments en the test scope and procedures:

1. Worst. case . support configuration:

                                               *    'The chosen member lengths and load magnitudes and directions may not be the critical case.

Cygna noted .that the selected configurations may not adequately address . torsional behavior of the generic support design nr address the . capability of the spot welds to resist tensile forces.

• Documentation is not readily available to evaluate the criteria used in choosing the test configurations.-
• The choice of larger diameter conduits for i.

some supports precludes testing of-P2558 clamps, since.I708-S tlamps;are required for large conduits. 2.: Direction of loading to test weak link:

• Clag loadings should in' duce tensile forces in the clamp bolts. Many tests load the members

                                                     -in bearing instead of maximizing clanp load.

• For composite Unistrut sections, the loading direction-should be selected to provide

                                                    -tensile loads on spot welds to test the,           .

integrity of the xomposite section. i Texas Utilities-Generating Company Comanche Peak Steam Electric Station i L-til . J t a Independent Assessment Programa All Phases mmmmimimagmu - Job No.: 84D56 t l l l . a - -

                                                                --.    . ..                                   -,a,     , - .

           .            . . . . .                       ... _s             .            . _ , _ _ . _ , , , , _ _
                 , ,                 ._.,.1-.                                                                           ,             ,           _

• 3/28/85 Revision 0 Page 6 CONDUIT SUPPORTS

                                                                       -Review Issues List Gibbs & Hill is' also reanalyzing some supports per AISI code e                                                     provisions. Additional information is required by Cygna to
                                                  ..' evaluate the adequacy of those analyses.

9. -Improper- Use of Catalog Components

References:

1. Comunications Report- between P. Patel, et al.

(Gibbs & Hill) and J. Russ, et al. (Cygna) dated 9/20/84

                                                   -2. . Communications Report between D. Kissinger' (TUGCO) and N. Williams (Cygna) dated .10/11/84

3. Comunications Report between E. Irish (Unistrut) and D.- Leong and J. Russ (Cygna) dated 1/21/85

4. Connunications Report .between E. Irish (Unistrut) and D. Leong and J. Russ ~(Cygna) dated 2/4/85

                                                  - 5. .Gibbs & Hil1 Calculation 2323-3CS-153C, Sheet 1/37
                                                                             ~

6. .Cygna Generic Conduit Support Review Checklists (not yet? issued)

Summary: . A. In addition to Cygna's comments on the implicit increase in allowables for SSE loads -(see Item 1), Cygna has - other concerns regarding the support designs using catalog components. AISC-derived allowables are used in the design process. These values are generally conservative for bending,-but are generally unconservative for axial allowables, as catalog allowables. are based on the AISI Code which considers buckling of thin, open sections.

 - - -                                                       Exanples of Cygna's concem are discussed-below:

o , l Texas l Utilities Generating Company 1 i

=!

f Comanche' Peak Steam Electric Station j ,yn ',".

                                              -Independent Assessment Program - All Phases                                                          ;
                                              ~ Job No. 34056

     . .a   . ;
                . . . , . . . .         . . .       .         .    . .   . .    . . . . . _      .     .: a .   . . . .. . .       ..

3 3/28/85

    ~

Revision 0 Page 7 CONDUIT SUPPORTS Review Issues 1.ist e CSM-Sb: 20 ksi' was used for Fa, the axial allowable. This value is equal to . .6 Fy, where Fy = 33 ksi and was

                                                                         'used for any member . length which neglects slenderness effects.

Catalog values range from 5.77 ksi for a brace length of 60" to 13.9 ksi for a 24" brace. -

                                                * . CST-3:               The design employed the AISC table of axial stress allowables for 35 ksi steel..

• CST-17: The design employed the AISC tables of axial stress allowables for 36 ksi steel. The table value was then reduced by a ratio. of 33/36.

                                           .B. cUse 12f: components tin ways not intended- by the vendors.-
                                               . Cygna concerns in this area are cas follows:-

• Ailowables are not listed for P1001C3 sections in the Unistrut. catalog. ~ Member properties are given for the X-Y axes instead of the principal . a'xes. Discussions with Unistrut indicate that the uses of P1001C3 are unique with respect to load. application and mencer restraint.' Thus, no generic allowables can be ~

provided. Unistrut places the burden on the

                                                         . designer to properly consider.the . capacity of
                                                       - the section for.its intended azse.
                                               -e'       The Unistrut, catalog indicates that-the intended use of P1325, P1331. P1332.br.ackets

! is for single members in a pinned

                                                      - connection.7 Gibbs & Hill uses twn. brackets on
                                                      < 1 double members, which .Cygna believes to be a
                                                        . moment resisting connection. . Gibbs.'& Hill                    -

considers these connections pinned-for some

                                                       - brackets in CSM-6b, CST-3, and CST-17 type                              ".

supports. However, Unistrut. does 'not provide

allowables for this bracket configuration.

l Texas Utilities Generating Company - Comanche Peak Steam Electric Station gMalmg$mmimm " '

                                    - ob No 8 5 u

i I .

                                                                                           ..,;._.          _ g , z.        . ,_, _ ,,_ _ ,_
           .e                                                                                          ,

3/28/85 Revision 0 Page 8 CONDUIT SUPPORTS Review Issues List e Gibbs & Hill references Unistrut Test C-49 to obtain allowables for the double bracket

                                                                               . connection in CST-3. This connection is subject to tensile and , shear loads. The' test provided data only on loading the bracket in tension. Gibbs &_ Hill compared the calculated tensile load to the. allowable, ignoring the
                                                                                                     ~
 .                                                                               calculated. shear..
                                                                          .*     P1941 plate connectors are used to connect headers to outriggers in CA-la and CA-2a supports. Gibbs & Hill calculations indicate
                                                                               -that tightening the Unistrut . bolts to the specified. torque overstresses the plate and causes excessive bowing of the plate.

Discussion with Unistrut indicates that these connectors are-to be used to construct frames where the. connected members are restrained .at both ends.- Clarification of this concern is required-for CA-la a'nd CA-2a supports, since

                                                                               .the member end restaint~ required by Unistrut                               .

has not been provided. - In Revision 1 of- Gibbs- A Hill Drawing 2323-S-0910, Sheet CA-la, Note 7, was added.to provide P1064. plates if bending of the P1941 plates occurs. In Gibbs A Hill Calculation 2323-SCS-153C, Sheet 1/37 a discussion of field installation-practice, documents that the P1064 plates do not reduce the bowing of i the outriggers. ' Unistrut . tests showed no bowing of the outriggers when the P1064 plates were used. Verification of the bolt torques . .msed in the test. set-up is required. .

       .                                                                                                                                                         l e   I708-5 clamps are not ~ designed for three-                                     I

directional loading. -Allowables for tensile.

                                                                               - loading only.are given in the Superstrut
                                                                               . Catalog.                                    ,               -

Status:' TUGCO/Gitts' & Hill should provide technical .

                                                                      - justifir. tion for the above issues.

l

                                                           ' Texas Utilities ' Generating Company
                                               ;i 3          Comanche Peak' Steam Electric Station L:                             .llill!!alittiilinnunann 1 Independent Assessment Program - All Phases                                                          '-
                                                           -Job No.:84056
      .         .        .                ..             .                 .        .-             .            -                            . . - -        . .:l'

y.... _ . . . _ . . . . . _ . _ . .

                                                       .    .u.. _.          . . _ . _ _ . , , . . . . . .   , _ _ , _ _ .                       _

e .. o 3/28/85

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Revision 0 Page 9 l I l CONDUIT SUPPORTS Review Issues List l

                  -10. Anchor Bolts

References:

      .1. - N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions," 84056.015, dated August 6, 1984, question A2b regarding CSD-la Sunnary: '          Cygna has the-following concerns regarding anchor bolt
                                              ' designs:

• A prying factor of 1.5.was used in most cases without

                                                    - justification. The Teledyne method predicts higher factors for CSM-18d and CSM-18f (rectangular plates).

• The AISC Bth Edition method was used to omit a prying factor for CSD-2, Detail 8 (U-clips).

                                          .

• No prying factor.was used for CST .17, Type 17 (box f.

                                                    . bracket).

• No prying factor was used for CSD-1, Detail.2 (Z-clips). The behavior of this detail is to be addressed

                                                     ~ in the Unistrut test program.

Status: 'TUGC0/Gibbs & Hill _ should provide technical justification of the above issues. Also see table Tray Generic item 3 for ' related anchor bolt issues.

11. Longitudinal Loads on Transverse Supports

References:

1. Communications Report between E. ' Irish (ttnistrut) ~

and J. Russ (Cygna) . dated 7/25/84

                                               .2. Cygna Generic Conduit. Support Review Checklists                                                      i (to be issued)

Summary: Some transverse supports any be on_the same order of stiffness as long cantilever multi-directional supports.  ;

                                               ' Since conduit clangs provide restraint in' tnree directions, longitudinal loads, which were not considered in the design,                                      '

_ may be imparted to the supports. l l Texas Utilities. Generating Company Comanche Peak Steam Electric Station [ t i Independent- Assessment Program - All Phases . 1 Imtmetimimamm - Job No. 84056 l

1

     .   . . . . . . . . . _ .      .. .    ,__,         __,,.s.       . . . . . . , _ ,___. _ ... _ . , ,__ _ __              _

l 3/28/85 i Revision 0 Page 10 i CONDUIT-SUPPDRTS i Review Issues. List  ! l Additionally, the displacements due to torsion of

                                              . longitudinal support beam members may induce some longitudinal loads into transverse supports.

Status: Technical' justification of the above assumption by Gibbs & Hill is required. -

             - 12. Hilti Kwik-Bolt- Substitutions                                                                 .

References:

None Summary: Note 4 on Gibbs & Hill Drawing 2323-5-0910, Sheet G-4a, allows the substitution of all Hilti Kwik- and Super Kwik-bolts with those of a larger size. A reduction in-the allowables for the larger bolts nay be necessary since the actual spacing may be sneller than that. required. Thus, a situation way occur where the replacement bolts have a lower capacity than the.tolts in.the original Aesign. Examples of Cygna's concern :are described below: e .CSM-18c: 1/2" Hilti Kwik-bolts at 5" spacing were used in the original design. If all 1/2" bolts are substituted with 3/4" or 1" bolts, the tensile allowable for the replacement bolts will be less than the design tensile allowable of 3012 lbs..(2750 lbs for 3/4" bolts and 2930 lbs. for 1" bolts).

• CSM-42

                                                     " Type lII:        1" Hilti Super Kwik-bolts at 7.5" spacing were used -in the original
                                .                                     . design (allowable tension = 12452 lbs, allowable shear = 6884 lbs).

If all 1" bolts are replaced by 1-

                                                                     "1/4" bolts of equal embedment, the                         !

bolt capacity is significantly reduced (allowbie tension = 6405  : lbs, allowable shear = 6221 lbs). i i

                                        ' Texas Utilities Generating Company eg [tj g 3              - Comanche Peak-Steam Electric Station                                                   '

gggggggg Independent Assessment Program - All: Phases

                                        . Job No. 84056

         .       .              .. .          . .m   . . . . . . .      . _ _ . . _ ..

3/28/85 Revision 0

     ~

Page 11 CONDUIT SUPPORTS Review Issues List Status: ~ Technical justification by Gibbs & Hill is required for

                                         ' supports affected by this note.
                     ~

13.' Substitution of Smaller Conduits on CA-Type Supports

References:

1. Comunications Report between S. McBee (TUGCO) and J. Russ (Cygna) dated 3/7/85 Summary: CA-type supports are designed using~2PA for large (> 2")

diameter conduits while-peak; accelerations are used for small diameter conduits (<2"). For CA-type supports where capacities are tabulated on the drawings, small diameter conduits may be installed unless specifically prohibited on the drawings. Although the deadweight load of the small diameter conduits must be less than the capacity, the accelerated. load of the small diameter conduits may exceed the equivalent accelerated load of the large diameter con-

                                         ?.duits r.onsidered in the'. original. design.

! As an example, support type CA-15 was designed for two 3" conduits with a deadweight capacity of 156 lbs. However, five 1-1/2" conduits can be installed on a CA-15 support, giving-higher accelerated loads.than designed for. The rigid span loads for two 3" conduits are 343 lbs. and 109 lbs. for the vertical and horizontal directions respectively. The flexible span loads for five 1-1/2" conduits are 504 lbs. and 450 lbs. for the vertical and ! horizontal directions respectively. This item possibly affects support types CA-6, CA-7, CA-12, CA-14 Series .and CA-16a. Status: Discussion with' TUGC0 and Gibbs & Hill is required. TUGC0

                                          . is investigating this item with respect to fire protected l--                                         . supports.                                              .

I

                   '14. Use of CA-Type Supports in 1.5 Spans                                                                 .

l

References:

-1. . Communications Report between M. Warner, et'al.

l (TUGCO) and W Horstman, et al. (Cygna) dated l 2/20/85 '~ Texas Utilities Generating Company t i ;, ,  : Comanche Peak-Steam Electric Station gaggggggg . Independent Assessment Program - All Phases Job No. 84056 i

j . ,. . ., ..- . . . . . . _ . _ , . ... . 3/28/85 Revision 0 Page 12 CONDUIT SUPPORTS

                                                                            . Review issues List

+

2. Comunications Report between S. McBee (TUGCO) and

                                                               - J. Russ -(Cygna) dated 3/7/85 Summary:          CA-type supports are used to support LA spans, which are
                                                        -limited to a 6': length. CST-type and CSM-type supports are used to support LS spans, which can be-up to 12' for trans-
                                                                     ~

verse spans and 24'-for longitudinal spans. In field in-

sta11ations, when conduits run from walls to equipment in

                                                      - the middle of.a room, a transition is made between LA spans                                                             ,
                                                        'and LS spans. Thus .CA type supports may. support LS spans.

The concerns are discussed below. l 9 For 1arge. diameter' conduits (>2"), IPA was used to calculate

                                                                ~

the accelerated _ design load. For the.CA-type. support with an adjacent' suspended support -(CST- or CSM-type), the peak acceleration should be used to check support capacity, since Tigidity of the transitional span can no longer be guaran-teed.' - There is evidence that decreased support capacity is

                                                       ' consitiered for the-fire protected supports (see CP-El-4.0-49), since support capacities are viven for both LA spans and LS spans. ; For unprotected lines, there is no indication that this was considered.

Status: TUGC0 is investigating the practice for fire protected supports.

15. Stresses-in Cable Trays Due to Attached Conduit' Supports

+

References:

1. Cygna Generic Conduit Support Review Checklists -

(to-be issued) Gibbs & Hill Calculation 2323-SCS-156C, Set 1, 2. Sheats~101-104 Summary: - This item applies to CSD-16 in the Cygna review scope and to any similar details. Cable tray spans-are ostensibly designed.to the capacity of the tray. The- addition of these types of conduit supports-to the tray rails adds loads above l

                                                       -the calculated tapacity. Therefore, a generic stress check                                                              -
                                                       . for the trays .is_ not possible, and all tray spans with these                                               

conduit supports should be individually checked. Since the design drawing does not _ preclude the use of-this detail on fire protected trays, and since the_ conduit support L Texas Utilities Generating Company-4{tj g 3 ' Comanche' Peak Steam Electric. Station Independent Assessment Program - All Phases , umummanumm y ' Job No.;84056 c v'- ,,- - 4 - - - nO_ - -+-,, - . +- - , , . ~ . . ~ - . - , - ,,-e- -- -..-r.- -

        -, - .      ..(   .
    ~

3/28/85 Revision 0 Page'13 CONDUIT SUPPORTS

                        ,                                                    Review Issues List
                                                                                                                                                        )
                                                          ' designer, instead:of a cable tray designer, is responsible
                                                        ': for showing adequacy of .the tray when using this attachment
                                                          . detail, a proper check must be made for all uses of this                                    i detail.

Status: Cygna has reviewed the Gibbs & Hill calculation for CSD-16.  : Cygna's comments require-discussion with Gibbs.& Hill.

16. ilncreases in Allowable Span Lengths -

A

References:

.1. : Comunications Report between P. Huang (Gibbs A

                                                                  . Hill) and D. Leong and J. Russ (Cygna) dated                                       '

12/27/84

2. .Gibbs & H'ill Calculation 2323-SCS-189C, Set 1.-

Sheets 15 ' L= mary: In the revised .Gibbs. A Hill . Drawing .2323-5-0910. package, LA - span lengths.were increased by a ratio of the' refined to the unrefined spectra. Gibbs & Hill provided a calculation to

                                                                                   ~

show that the above changes are correct and that' rigid spans remain rigid (diameters r 2"). This is indequate for support ' 1

                                                          . designs, since suppo'rt loads are proportional to span i                                                            lengths. However, an evaluation of the conduit stress is required, since conduit bending stress is proportional to t                                                         ' the square of the span length.                             -

Status: Gibbs a Hill should provide technical justification for the

increased span length.-

17. Substitution of Next Heavier Structural Member

References:

None Summary: This item refers to Note 5 on Gibbs & Hill Drawing

                                                         .2323-5-0910,' Sheet G-la. Most supports are designed to the allowable loads for the Hilti Kwik-bolts. In 11ght of.the
                                                          ; discussion in Item 7.A.. generic designs' using strictural

• 1 steel. are affected but are not checked. .

Status:' Discussion with Gibbs & Hill -is required. See rumulative effacts,. Item 24.. .

                                                   . Texas Utilities Generating Company 1         ji ,           , Comanche Peak Steam Electr               i c Station-

!. unmann o n,, g ~ ' Independent- Assessment Program - All Phases s Job No. 84056 i

l

     - -=      ---        -
                                                               .            .t    . . _ .            _. . . _ _

3/28/85 Revision 0 Page 14 CONDUIT SUPPORTS Review Issues list

18. Clamp Usage-

References:

1. -N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit. Support Revies Questions" 84056.015, dated August 6, 1984, question A4

2. ' N.H. Williams. (Cygna) letter to J.B. George (TUGCO), " Conduit Support Walkdown Questions,"

84056.020, dated August 13, 1984, question 3

3. Comunications Report between E. Irish (Unistrut) and J. Russ (Cygna). dated 7/25/84

4. Comunications Report between T. Keiss, et al.

(TUGCO), B. Shujang, et al. (Gibbs & Hill)-and W. Horstman, .et al. (Cygna) . dated 10/9/84

                                  '5.      Cygna Generic Conduit' Support lleview' Cher.klists (to be issued)
                                   .A. For small diameter con'duits (<2"), clamps may be reamed Summary:

to: accommodate 3/8" Hilti-bolts. . t.s a result, the minimum edge distance requirement., are violated. Additionally, the washer for 3r/ Hilti Kwik-bolts will not fit on clamps for small v  ::ter conduits (<2"). The washer is an integral part of the bolt, and _ justification for its omission is required. B. In the Cygna walkdown, clamp distortion was noted for the following supports. Support ID . Support Type

 ~

C12G93528-8 CSM-18f C12002935-3 CA-Sa C12G03126-18 CSM-42

                                        ' C1?nn?R51-6               -   CA-Sa I                    . Status:      -A. Cygna is reviewing calculations on clamp reaming -                   -

provided by TUGCO. Further discussion is required on the subject of Hilti washers. l l ' Texas Utilities Generating Company L [jg i Comanche Peak Steam Electric Station l

            .immmimminium . Independent Assessment Program - All Phases

c. Job No. 84056

      '~~                                      ~     -      -- -                   . .        . . . . . , . . .

3/28/85 Revision 0 Page 15 CONDUIT. SUPPORTS Review Issues 1.ist B. Discussion with TUGC0 is' required.

19. ' Documentation Deviations Between Inspection Reports, CMC's and

+ IN-FP Drawinos

References:

1. 'Comunications Report between P. Patel (TUGCD) and

                                      .D. Leong and.J. Russ (Cygna) dated 2/18/85

Summary: For each conduit line, an inspection is performed and documented on an inspection report (IR). All CMCs and applicable IN-FP drawings should be reflected on the IR.

Examples of.Cygna's concerns are discussed below:

• Line C11003395, IRME-18120F, Support -1: On the IR, the support is listed as CSM-18f, Revision 4.

On CMC 62903, the support is listed as CSM-18b,

                                     -Revision -14. . Based orrthe CMC information, the IR is in error, e     Line C12G-05087, IRME-16817F, Support -4: On the IR, the support is listed as CSM-18C, Revision 13.

On CMC 62905, Revision 0, the support is listed as Revision 9. On CMC 62905, Revision 1,. the. support is listed as Revision 12. e Line C12004695, IRME-16089F, IN-FP-216, and IN-FP-226: There are discre and both IN-FP drawings support for' pancies between the IR types CA-la and CA-2a. There is no structural difference in the supports, but a documentation inconsistency exists. Status: This item is'still under review. Additional issues will be

 -                                noted .as-the review progresses.

20. Nelson' Studs

References:

1. Communications Report between P. fiuang andR'.

Sanders (Gibbs & Hill) and J. Russ (Cygna) dated - 8/7/84 Texas Utilities Generating Company LT [t';[ 3 Comanche Peak Steam Electric Station NWmHmmmuma Independent Assessment Program - All- Phases

                             . Job No. 84056

3/28/85 Revision 0 Page 16 ,

                                                     ~C0llDUIT SUPPORTS Review Issues list i
                                    '2. Gibbs & Hill . Calculation 2323-SCS-156C, Set 1, Sheets 131-160

3. Gibbs & Hill Calculation 2323-SCS-109C, Set 1, Sheets 164-184 Summary: - The Nelson stud allowables used by Gibbs & Hill do not conform to those given by TRW/ Nelson.

                                   ~ Gibbs & Hill. calculations use the pretension force in the Nelson studs to resist applied conduit loads. The
                            ,        pretension-force should consider the flexibility of the shim plate and clamp, as distortion and/or relaxation in these components- will decrease the stud preload. Gibbs & Hill provided.Cygna with a calculation to address shim plate
                                   , stresses.                                                                             .

Filler. plates .with oversized or. slotted holes allow the .

studs to be . loaded. at the . clamp, thus applying a shear load eccentric to the stud weld. Transfer'of side- or longitudinal loads on the clamp is provided through shears and bending of the Nelson stud rather than pure shear as considered in the design. Status:- A. Justification of allowables used for the Nelson studs is required. B. Further evaluation of the actual preload and its effect

                                         - on the stud . capacity is required.

C. Evaluation of the Nelson studs for any effects due to bending is required.

                                   .D. . Cygna has reviewed the shim plate calculation and j.,                                        requires technical justification of the following issues regarding the yield line analysis:

• The reason weld underrun..was-not included in.

the . analysis. _

                                        -*     The assumed stress distribution in the fillet                    ,

weld around the plate is. unrealistic, as it assumes .an infinite stress on the tottom of the plate. 'A more realistic stress

- . Texas

Utilities Generating Company l te h(;g i = Comanche Peak Steam Electric Station-L

            'Istmmmimustem' Independent. Assessment Program - All Phases

! Job No. 84056-r L i

w e _ 3/28/85 Revision 0 Page 17 CONDUIT SUPPORTS Review Issues list  ; distribution shows that the weld does not have sufficient capacity to allow the plate to yield. This should be considered in a revised yield line analysis. 21.; Conduit Fire Protection Configuration

References:

1. Comunication Report between T. Keiss ITUGCO) .and U W. Horstman, et al. (Cygna) dated 10/16/84

! Summary: Gibbs & Hill fire protection calculations consider a round configuration of Thermolag material'around conduits. The

-                                   Thermolag weight on the spans was calculated based on this configuration. The Cygna walkdown and discussions with TUGC0 indicate- that a square configuration was also used in                                  ,

tre field installations. Documentation of the specific corfiguration installed was not maintained. Status: Ivaluation- by Gibbs & Hill of theas-tuilt configuration with respect to the design configuration is required to in-sure that'the design adequately envelops the field condi-1 tion. Preliminary evaluation by Cygna indicates that small .n unconservatisms exist for some cases. See Item 24 for cum-ulative affects. l!

22. Span Increase for Fire Protected Spans

References:

1.- - Comunications Report between T. Keiss (TUGCO) and W. Horstman, et. al. (Cygna) dated '10/16/84 ,

2. Comunications Report .between T. Keiss ~ (TUGCO) and J. Russ and N. Williams (Cygna) dated 10/27/84 h- 3. TUGC0 Instruction-IP-EI-4.0 ,

4. Gibbs & Hill Drawing 2323-5-0910, LA Series 2

5. Gibbs'& Hill Drawing 2323-5-0910 LS Series, [

                                    -6. -Gibbs & Hill Calculation :2323-SCS-1017, . Set 1 i

• . Texas Utilities Generating Company L% .[4"; i _ i Comanche Peak -Steam Electric' Station buuuuuuuuumunm 11ndependent Assessment Program - All-Phases-  :'

                               . Job No.: B4056 4

e-- .. 3/28/85 Revision 0 Page 18

                                                  -    CONDUIT SUPPORTS
                                                     . Review Issues List Summary:       The allowable spans for some fire protected cont..          runs are longer than allowable spans for unprotected runs.

Status: Cygna has reviewed calculations provided by TUGCO. Addi-tional discussion with TUGC0 and Gibbs & Hill is required.

23. Grouted Penetration Loads

References:

. None Susumary: For straight conduit runs embedded in walls and -floors, longitudi ,1 conduit supports are not required if there are no bends in the run. For very lor.g conduit runs, the loads on the grouted penetrations may be large. Status: Technical justification is required.for the ~ capability of grouted penetrations to resist longitudinal conduit loads

                                    .for runs where no other longtidunal supports are consid-ered. These -justifications should, as a minimum, address the following:

• The capability of the grout:to resist applied

                                         . loads.

• The documentation -and inspection of grouting to validate the analysis assumptions on the ability of penetrations to resist the applied loads.

f

24. Cumulative Effect of Generic Items

References:

None Summary: Small unconservatisms may usually be neglected in design.

                                    - Since most of the conduit supports are designed to maximum capacity, the cumulative effect of many unconservatisms may be significant. 'The following items may have cumulative effects .on the conduit Jmpport designs:

• Combination of dead weight and earthquake loads '

                                           .(Item 3).
                                     *    ' Support self weight (Item 7). .

Texas utilities Generating Company ,

           .L      [ ;i a       Comanche Peak Steam Electric Station                     .

1 Immmmmmmimm Independent Assessment Program -- All Phases l 1 Job No. 84056 6

a  ! 3/28/85 Revision 0 Page 19

                                                                     ' CONDUIT SUPPORTS Review. Issues List

• Substitution of heavier structural members (Item 17).
• Variance in Thermolag cross-section (Item 21).

Status: Discussion with Gibbs & Hill is required. L 6 4 Texas Utilities-Generating Company L i..[jg3 Comanche Peak Steam Electric Station

           . litilitilliimmmitilisill:. Independent Assessment Program - All Phases t

Job No. 840%

   ;s. . .-

l 3/28/85  ! Revision 0 , Page 1 ELECTRICAL

                                                                .(Power and I&C)
                                                             - Review . Items List

1. Instrumentation Pressure / Temperature Ratings

References:

-1.       N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984
                                             .2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 Summary:      ~Two instances were noted by Cygna where the pressure tem-perature ratings for instruments installed in the Component Cooling Water System (CCW) were lower than the maximum pres-sure or temperature of the system as indicated in the Gibbs
                                              & Hill analyses. The instruments in question were later shown to be qualified for the higher design conditions or protected by interlocks. Cygna reviewed a total of 24 CCW instruments and these were the only two pressure-temperature discrepancies noted.

_. Status: Gibbs A H111/TUGC0 should provide evidence _that when design and operating data is revised, all existing system components are reviewed to ensure that they meet the new operating conditions. Statistically, two instances out of 20 may indicate the need for further review.- 4

2. Cable Tray Thermolag Fire Protection

References:

1. N.H. Williams (Cygna) letter to J.B. George  ;

(TUGCO). 84056.010, dated July 30, 1984

2. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984

3. N.H. Williams (Cygna) letter to J.B. George (TUGCD),84056.024, dated August.21, 1984

4. L.M. Popplewell (TUGCD) letter to N.LMilliams

                                                    -(Cygna) dated September 4,1984

5. Comunications Report between J. Van-Amerongen (TUGCO) and R. Ness (Cygna), dated 9/11/84, i 11:00 a.m.

i Texas utilities Generating Company '

                 . h.i [            i a   Comanche Peak Steam Electric Station
                 . namtlurmuumnmm         Independent Assessment Program - All Phases
                                        . Job Mo. 84056

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    .                       ,                                                                                                                                  Revision 0 Page 2 m                                                                                  . ELECTRICAL
                                                                                 -(Power and I&C)

Review Items List Summary: _During the Cygna walkdown of July 16-20, 1984, it was noted that cable tray section T130ACA43 was not covered with Ther- '

                                                              -molag fire protection material. Cygna reinspected the area in- August / September and the proper material' was installed.

1 However, the documentation supplied by TUGC0 for the removal and reinstallation of- the fire lag insulation indicates that the work was completed and signed off on 7/14/84. This is prior to the 'Cygna walkdown. While the reinspection showed the' tray:to be properly covered, the documentation is not ', - consistent with the noted sequence of events. Stiatus: 'Open for internal Cygna ' discussion. ' :3.- Temperature Indicator X-TI-4837 Not Installed

References:

1. Cygna Phase 1 and 2 Final Report TR-83090-01, Revision 0, Observation.WD-07-02 Summary: 1)uring the walkdown of the ' Spent'Fue17ool Cooling System, it was noted that-a temperature indicator was not in-stalled. Further investigation revealed that some instru-

, mentation is not installed by construction in order to j: . prevent-it from being damaged by additional construction

activities. When the system is turned over for operation, a s'et, of instruments is provided for final. installation. '

Status: Closed. .

4. Incorrect Cable Identification Number l

References:

1. Cygna Phase 1 and 2 Final Report,'TR-83090-01, F Revision 0,. Observation WD-07-03 i- t l Summary: . One of six cable identification tags checked during the '

l .: walkdown had an: incorrect unit. identification number on the L  : tag.. An additional-32 safety related cable identification t t  : tags were checked and found to be correct. Since the only

                                                           - discrepancy was in the unit number, no safety. impact was
                                                      . ' involved and-the observation was closed as an isolated          -
                                                        . error.
                                    . Status:              ' Closed.
                                  .                 Texas Utilities Generating Company-e                          n.il a t           a. Comanche Peak Steam Electric Station '

! i*io . ' Independent Assessment Program ' All Phases-l tJob No.-84056 - X e ,er, -

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   ,L-3/28/85            4 Revision 0          )

Page 1 ELECTRICAL l

                                                                              -(Power and'I&C)                                                                          l Review Items List

1. Instrumentation-Pressure / Temperature Ratings )

I

References:

1. N.H. Williams (Cygna) letter to J.B. George l

                                                                 .(TUGCO),84056.010, dated July 30, 1984

2. L.E Poppelwell (TUGCO) letter.to N.E Williams (Cygna) dated August 11, 1984 Suasaary: Two instances were noted by Cygna where the pressure tem-perature ratings for instruments installed in the Component Cooling Water System (CCW) were lower than the maximum pres-

                                                           .sure or temperature of. the system as indicated in the Gibbs
                                                            & Hill analyses. - The instrumerts in question were later shov:n to. be qualified for. the higher design conditions or protected by interlocks. Cygna reviewed a total of 24 CCW j                                                        . instruments and* these' were the. only two pressure-temperature discrepancies noted.

Status: s Gibbs A Hill /TUGC0 should provide evidence that when design and operating data is revised, all existing system

                                                        ' components are . reviewed to ensure that- they meet the new operating conditions. Statistically, two instances out of 20 may indicate the need for further review.

2. Cable Tray Thermolag Fire Protection

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), 84056.010,- dated July 30,-1984

2. L.NfPopplewell (TUGCO) letter to M.E Williams

, (Cygna) dated August 11,1984

                                                       .3.        N.E Williams (Cygna) letter to J.B. George (TUGCD),84056.024, dated August 21. 1984
                                                               ~

l ' 4. - L.N Popplewell (TUGCD) letter .to .N.H. - Williams - l -(Cygna) dated September 4,1984 l

                                                      . 5. - Communications. Report between J. Van Amerongen j
                                    ,                            '(TUGCO) and R. Hess (Cygna), ~ dated 9/11/84,

! 11:00 a.m.

                                                 , Texas Utilities Generating Company                                                                                   l
                      .L I.             6         Comanche Peak Steam Electric Station

_ lulmilliumillitillnialiIndependent Assessment Program - All-Phases l Job Mo. 84056

                                                  .. . . .                .           .         ......q.           . . -. . ..... .. a w -      ..,      . . .          . .. ... - ..
                                                                                                                                                                                     ~
                                                                                             =-

3/28/85 Revision D Page 2 ELECTRICAL (Power and I&C) Review . Items List Sumary: 'I)uring the Cygna walkdown of July 16-20, 1984, it was noted that cable tray section T130ACA43 was not covered with Ther-molag fire protection material. . Cygna reinspected the area in August / September and:the proper material was installed.

                                                                                            -However, the documentation supplied by -TUGC0 for the removal and reinstallation.of the fi.re lag insulation indicates that the work was completed and signed off on 7/14/84. This is prior to the Cygna walkdown. While the reinspection showed the tray to be properly covered, tne documentation is not consistent with the noted sequence of events.
                                                                       . Status:              Open -for internal Cygnacdiscussion.

1

3. Temperature Indicator X-71-4837 Not Installed

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation k'D-07-02 s Summary: During the walkdown of 1;he Spent Fuel Pool Cooling System, it was noted that a temperature indicator was not in-stalled. - Further investigation revealed that some .instru-inentation is not installed by construction in order to prevent it from being damaged by additional construction activities. ' When the system is turned over for operation, a set of instruments is provided for final installation. '

Status: Closed.

4. - Incorrect Cable Identification Number

References:

1. Cygna Phase 1 and 2 Final Report, 'TR-B3090-01, Revision 0, Observation MD-07-03 Summary: One of six cable identification tags checked during the walkdown had an incorrect unit identification number on the tag. An' additional 32 safety related cable identification tags were checked and found to be correct. Since the only

                                                                                          , discrepancy was in the unit number, no safety impact was -

11nvolved and the observation was closed as an isolated error.

                                                                       ~ Status:            Closed.

Texas Utilities Generating Company

                                                            - Li ( .: L         a. Comanche Peak Steam Electric Station                                                                         .'

mmmmmimmumm Independent Assessment Program - All Phases Job No. 84056

                                                                                                                                              ~
                        . . . . . . . . -.-.                                .--    .-       .     . -~
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                 .4'

.....;.  !.1 .

c-3/28/85 Revision 0 Page 1 IECHANICAL SYSTEMS Review Items List 11;: Component' Cooling Water (CCW) System Maximum Temperature

References:

~1. ~~Cygna-Phase-4~ Final Rhport, TR-84056-01, Revision 0, Observation MS-01-01 (not yet issued) 2.'     N.H. Williams (Cygna) letter to J.B. George (TUGCO). 84056.010, dated July 30, 1984
                                                         ~

3. -L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated August 11, 1984

, 4. .N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.023, dated August 21, 1984

5. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated April 11, 1984

6. L.M.-- Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated October 1,11984 Sunnary: .Cygna .moted distrepancies between the -Westinghouse ~ stated

maximum CCW system temperature of 120*F and (1) the CPSES

. .FSAR; (2) Gibbs & Hill calculation 233-16; and -(3) Gibbs & Hill calculation 229-14. These documents indicated maximums

of 121.8'F,135*F and '129.7'F, respectively. . TUGC0 provided j docuantation that showed the acceptability of the 135'F l- maximum temperature. cSome' of this documentation ~is dated as -

late. as 9/28/84 indicating that LTUGC0 may not have been .

                                                   ' aware of the . problem prior to the Cygna questions.

Status: Cygna Observation MS-01-01 was -closed based on the documen-

-tation which was provided by TUGCO. However, Gibbs & Hill /

' TUGC0 should demonstrate that-when design ;and operating data is revised, all existing system components are reviewed to ensure that they meet the new operating conditions.= i, 1 LTexas Utilities Generating Company, A{jg, Comanche Peak Steam. Electric Station , Independent - Assessment- Program - All Phases . ummusmann . Job No. 84056 i l < ~

                                     .      - i_ ,                           . , , . .. __., , . . . . _        . , , , . , ,a..       , , . , - .. - , _ . _ . . _

_ ,]

3. .

[ 3/28/85 .

    ' ~

Revision 0 Page 2 MECHAMICAL SYSTEMS Review Items List

2. ' .CCW Surge Tank Isolation on High Radiation Signal

References:

li Cygna Phase 4 Final Report, TR-84056-01, Revision 0, Observation MS-06-01-(not yet issued) .;

                                                         .2. M.H. Williams- (Cygna) letter to J.B. George (TUGCO), 84056.028, dated August 27, 1984

, . 3. L.M. ' Poppelwell- (TUGCO) letter to N.H. Williams (Cygna) dated September 20, 1984

                                         'Sussiary:      : The Westinghouse' functional design requirements document for
                                                       ' the CCW system required that the surge tank be isolated by closing the vent valve on receipt of a high radiation sig-nal. TUGCD/Gibbs & Hill removed this control function from the system radiation monitors to prevent spurious actuation caused by rising system temperature during -accidents. Since the change did not address the radiation release effects of the. vent-remaining open, Cygna requested verification that the; release would be acceptable ~. . TUGCO performed a calcula-tion which -verified that the release was within the limits of-10 CFR 100. No generic review was conducted of other radiation monitor control function changes at CPSES.                                  ;

Status: Cygna Observation MS-06-01 was closed based on the results of TUGC0' calculation TNE-CA-094 dated September 19,.1984.

3. Class'5 Piping

References:

1. Cygna Phase 4 Final Report, ~TR-84056-01,-

' Revision 0, Observation MS-02-01 (not yet issued) l 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO),-84056.010, dated July 30, 1984

3. . L.M. Poppelwell~ (TUGCD) letter:.to N.H.. Williams . j (Cygna) dated. August 11, 1984

                                                         -4.      M.H. Williams (Cygna) letter to J.B.. George                               *

(TUGCO),- 84056.023, -dated August 21, 1984

                                                           .5. ' L.M. Poppelwell (TUGCD) letter to N.H. Williams                                  l 4

(Cygna) - dated . September 11, 1984' 1 Texas Utilities Generating Company

                                                                   ~
                                                                                                                                              ~'.

g 3, , Comanche Peak Steam Electric Station g independent Assessment Program - All Phases.' .f Job No. 84056

              . . . _ . . _ _ . .         .       : ~ . . , . .          .. s . . : _. . .             . . _ _ . . .. , __,. ..           . . _ . _ _ _ _ . _ , ._,
          .1._".-                                                                                                                             .
                        , ,7.                                                                                                                3/28/85-

• Revision 0 Page 3 IECHANICAL SYSTEMS l Review ltens list  ;

4!  ; x 6.. L.M. Poppelwell -(TUGCO) letter to N.H. Williams t j _

                                                                   ' (Cygna) dated September 21, 1984

7. L.M. Pop

                                                                     . (Cygna)dated    pelwell     (TUGCO)

September 25, 1984 letter to,N.H. Williams  :

                                                             - 8. Communications Report between~D. Wade (TUGCO) and
                                                                     .R. Hess -(Cygna) dated 9/5/84, 3:00 p.m.

9. N.H. Williams (Cygna).~1etter to V. Noonan (11SNRC)

- -"Open Items Associated with Walsh/Doyle

                                                                     ' Allegations," .84042.022,' dated January 18, 1985 f5ummary: ,           : Per Gibbs '& Hill, Class. 5 piping is not seismically designed; it is only seismically supported to prevent it fram falling on safety related equipment. TUGC0 did provide j                                                               documentation showing .that the' specific Class 5 CCW piping that was in Cygna's rev.iew. scop'e was seismically analyzed
                                                              ;and therefore, would remain -functional as required.

Mowever, Cygna could not determine whether: any similar circumstances exist in other piping systems where Class 5

  ,                                                            piping may be required to remain functionalEduring a seismic event.

(7 ,

v. '  : Status: Observation MS-02-01 was closed for the CCW system based on the ' documentation and analyses provided. Gibbs & Hill /TUGC0 should explain the use~of-Class 5 piping in areas where-functionality is required following design. basis events.

A.. Fire Doors

References:

1. N.H. Williams (Cygna) letter to J.B. George 4

(TUGCO),84056.010, dated July 30, 1984 .

2. L.M. Poppelwell (TUGCO) letter to N.H.: Williams

                                                                    >(Cygna) dated August 11, 1984~

3. N.H." . Williams (Cygna)~ letteh to J.B. George (TtGCO),34056.023, dated August 21, 1984

                                                                                             ,v                                                                       ,
                                                             .4. .i.M..Poppelwellf (TUGCO) letter to N.H. Williams
                                                                    .(Cygna) dated. August 31, 1984                                     ,
                                                .:.                                           b t   i f-
                "j 3                                   cTexas Utilities Generatin' Company-        g
                   'm
                               .Wi       s Comanche btillistalilittelillmill  Independent- Assessment       Peak            Steam Program      - All PhasesElectric Station -
                   -$(g , ,                            .. Job No. 84056                                                          ,,

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f. . . ,

3/28/85 . Revision 0 Page 4 NECHANICAL SYSTEMS

                                                                         , Review-Items List
                                                                                                                                                         -l l

S. - Communications Report between J. Van Amerongen 1 (TUGCO) and R. Hess (Cygna), dated 9/11/84, l 11:00 a.m.-.

                                               ' 6. ' Communications Report between Mark Wells '(TUGCO)
                                                       -and R. Hess (Cygna) dated 9/13/84, 11:00 a.m.

Summary: LCygna- noted that- thel double doors between the train A & B nuclear chillers did not have a U.L. fire rating label.

                       .                       :TUGCD stated that this had been-previously noted by them and                                               '

that the proper door was being' installed. TUGC0 could not provide documentation' of. how the error was noted but did supply copies of a purchase order-for the correct door. Subsequent reinspection by Cygna verified the proper door had been installed. TUGC0 stated that an NCR or other paper work.was not initiated since the door is not safety related. - ! The' door is required to meet' Appendix R requirements.

. Status: TUGC0 should provide ' assurance that _the as-built Appendix R modifications.are in conformance with the ' Appendix R

• design requirements and specifications.

5. Single Failure --Reactor' Coolant Pump Thermal-Barrier

References:

       .1. Cygna Phase 4 Final- Report, TR-84056-01, Revjnion0,ObservationMS-02-02:(notyetissued)                                               ,

2. . Cygna Phase-4 Final Report, TR-84056-01,-Revision

                                                         'O,    Potential finding PFR-Ol'(not.yet issued)

3. N.H. Williams '(Cygna) letter to J.B. George

                                                         . (TUGCO),84056.010, dated July 30, 1984

4. Connunications Report between D.(Wade (TUSCO)' and.

R. Hess. (Cygna) dated 8/17/84..8:30 a.m..

5. L.M. Poppelwel17 (TUGCO) letter to N.H.. Williams

                                                         '(Cygna) . dated August 24,'.1984.

6. Connunications Report between D." Wade (TUGCD)' and N. Williams (Cygna) dated 8/30/84, 3:30 p.m.

l Texas' Utilities Generating Company "y ,,  ! Comanche Peak : Steam Electric Station Independent Assessment Program - All Phases.-

                 '   imimmimmmmmm 1 Job No.'84056 p

E _ L

                                                                    ~

. . -~. . .-. . - _ _ . -. -

3 -l. , 3/28/85

    ~

Revision 0 Page 5 I MECHANICAL SYSTEMS

                                                                            . Review Items.l.ist.

7.. Comunications Report between D. Wade (TUGCO) and i R. Hess (Cygna) -dated 9/5/84, 3:00 p.m.  ; B. D.H.. Wade (TUGCO) letter to N.H. Williams

                                                                   -(Cygna), CPPA-40961, dated September 18, 1984-

9. . D;H. Wade (TUGCO) letter to N.H. Williams (Cygna), CPPA-41237, dated October 3,1984 10.. N.H. Williams (Cygna) -letter to S.' Burwell (USNRC),84056.032, dated October 9,1984

                                                        '11.        Comunications Report between D. Wade (TUGCD) and N.: Williams (Cygna)' dated 10/11/84, 5:00 p.m.
                                                        .12.        N.H. Williams (Cygna) letter to S. Burwell (USNRC), 84056.035,' dated October 22, 1984

13. 'E.P. Rahe, Jr., (Westinghouse) letter to R.C.

JeYoung i (USNRC ),cKS-EPR-2938; - dated . July 13, 1984

14. T.R. Puryear (Westinghouse) . letter tol J.T. 'Merritt,

. Jr.'(TUGCO), WPT-7436, dated July 23, 1984 Summary: Cygna expressed a concern that if tile- single temperature controlled :isolationivalve on the outlet of the reactor coolant pung thermal barrier should fail to close suosequent to a rupture.of the thermal barrier, then low pressure . portions of the CCW system would be over pressurized and reactor coolant could be released outside containment. 4 Westinghouse also notified the NRC and TUGC0 of a similar problem with CCW systems they designed. - TUGC0 informed

                                                        . Cygna that they were filing ~ a 50.55E report with the NRC on                                               ,

this issue and that they would investigate the generic' implications '.of this finding.~ Cygna~ submitted two letters on this subject to the IRC. and TUGC0 in accordance with our

  .                                                      review procedures for a Definite Potential Finding.: Cygna

, Thas not received _ any 'of'the TUGCO documents which evaluate this -issue nor has-Cygna performed any : additional-investiga-

                                                        ~ tion or review on this: issue.

F l

                                                ? Texas Utilities Generating Company L

eg , Comanche Peak Steam Electric Station Independent Assessment Program -. All= Phases-Elimilmilmismaml . Jcb No. 84056

                      . . - . , .          (-   .     ,                         ,. ,        ,                           , - - - , , . -      -,    ,   ,        - , ,

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3/28/85

 - i-                                                                                                   Revision 0 Page 6 MECHANICAL SYSTEMS Review Items List Status:            : Observation MS-02-02 was upgraded to Potential Finding PFR-01. ~ Subsequentlyg- references 10 and 12 were sent to the                     '1 NRC in' accordance with Cygna's procedures for processing a                         '

' ' Definite Potential Finding.: 'TUGC0 should provide evidence that other.-systems do not possess a similiar set of attributes'which could potentially result in a common mode failure. u 4 l 4 Texas.titilities Generating Company.

Comanche Peak Steam Electric Station A{ Independent . Assessment Program - All Phases -

11mmmimilbm,im ' Job No. 84056.

                                          ~                   ~ - , -                       . - , -   -   - - , . .        .-

                                                                                                             ^                              ^
        ~ 1 -.E   - -

3/28/85 ,

    .                                                                                                   Revision 0 Page 1 1)ESIGN CONTROL                                                                        1 Review Issues List.                                                                      I 1

l

1. Review 'and' Analysis of Cumulative Effects

References:

. I'. . Cygna ~ Phase IL and 2 Final Report, TR-83090-01, Revision.0, all Sections

2. Cygna Phase 3 Final Report TR-84042-01, ,

                                              . Revision-1, all Sections

3. N. H. . Williams -(Cygna', setter to V. Noonan (USNRC), "Open Items Associated with Walsh/Doyle~

Allegations," 84042.022, dated January 18, 1985 j

4. .N. H. - Williams (Cygna) -letter to V. Noonan ,

(USNRC),~" Status of IAP. Conclusions," 84056.050, l dated January .25,1985 . 1

5. All Comun1 cations Reports and correspondence written on -all' Phases of the Independent Assess-ment Program Utilizing the' data available from all four phases of the

                                                                 ~

Summary: Cygna technical and design control reviews, a cumulative effects evaluation of all observations and potential finding reports is being performed. This review is also focusing on the cumulative effects of individually insignificant discre-pancies. Any trends identified' which indicate either strengths or weaknesses in the-CPSES design / design- control program are being evaluated. Status: Cygn_a is inthe process of extracting raw data from all i phases of the IAP performed to' date. The results of this i review will be included in the . Phase 4' Final ' Report.

                                                                   ~

2. . Adequacy of the Design Process used on CPSES

References:

    '1. Mesorandum and Order (Quality Assurance.for Design).- Texas Ut111 ties Generating Company, et                                                  i al..- Corranche Peak SteamiElectricl Station ' Units 1 and.2, dated December 28, 1983                                                                     i l

I Texas utilities Generating Company  ! 4 Ljt A. Comanche Peak Steam Electric Station 1~ Mmmtmalmmimam Independent Assessment Program - All' Phases 1 Job No. 84056 1-6. 9 1

                                           +          -                     ,,,   eNe -v ,- -     - -          -- -         --er--we-<-w-

3/28/85

                                                                                             ' Revision 0 Page 2 DESIGN CONTROL-Review Issues List

2. ' CASE's Motion .for ~Sumary Disposition, "Allega-

                                         .tions Concerning Quality Assurance Program for
                                         ' Design of Piping and Pipe Supports," dated July 3, l
                                         .1984

3. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all' Sections

4. _ Cygna Phase 3 Final Report, TR-84042-01,

                                      . Revision 1, all Sections

5. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050,

                                        - dated January 25, 1985

6. All Comunications Reports and correspondence written on all Phases of the Independent Assessment Program ,

Summary: Based on the Phase 17hrough 4 review scopes, Cygna is

                                                      ~

evaluating the adeciuacy of the process employed -in the design of Comanche Peak Steam Electric Station. This review

                                  -also inclu. des an. assessment of the resulting quality of the final design.

Status:- This evaluation is ongoing in conjunction with the cumula-tive effects review. The results of this review 'will be included in the Phase 4 Final Report. 3.- Qualification and Training of Design Engineers

References:

1. Cygna Phase .1 and 2 Final Report, 'TR-83090-01, Revision 0, all Sections

                                 .2. . Cygna Phase 3 Final Report. TR-84042-01, Revision 1, .311. Sections 3.'. N. H. Williams (Cygna) letter to V.- Noonan
                                       . (USNRC).. " Status of IAP I,onclusions,'" 84056.050,                            :

dated January 25,4985 i Texas Utilities Generating Company ' L.8.L L a Comanche Peak Steam Electric . Station BIMIMilllMMitM Independent Assessment Program- All' Phases-Job No. 84056-

         .;    s                                                -     . _ . . . _                    . . _ .           _
     ; s 3/28/85
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1 1)ESIGN CONTROL

Review Issues: List 4.4 All Communications Reports and correspondence written on all Phases of the Independent Assessment Program

                            ' Summary:

The root.cause 'of .all discrepancies and observations is being assessed to determine whether or not a trend ' exists which . indicates any weakness in -the training / qualifications of the design engineers.

Status

This: issue is being' addressed -in tonjunction with ~the cumulative effects evaluation. The results of this review will. be provided in .the Phase 4 Final Report.

                        .4.    ' Control of Design Interfaces

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections

2. Iygna Phase T Final ' Report,"TR-84D42-01, Revision 1, all Sections

3. M. M. Williams (Cygna)' letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985'

4. All Communications Reports and correspondence written on all Phases of the Independent Assessment Program Summary: The adequacy of the interf aces will be assessed as a result of trending which is being perforned on Phase 1 through 4 observations.

l

                               . Status:        This issue is being addressed in conjunction with the cumu-lative effects evaluation. The results of this review will
                                                .be:provided in the Phase 4 Final Report.                                       l I                                                                                                                              e

5. Adequacy of Procedures

References:

1. Cygna Phase 1 and 2 Final Report,7R-83090-01, Revision 0, all Sections I

                                         . Texas Utilities Generating Company                                                 ,

jt i Comanche Peak Steam Electric Station ' mitmimmmmmilmi Independent Assessment Program - All Mases

                                         .~ Job No. 84056

m e...- . . , ;_-... ) I: , - e 3/28/85 Revision 0 Page 4 DESIGN CONTROL Review Issues List

2. .Cygna Phase 3 Final Report, TR-84D42-01, Revision 1, ..all Sections

13. N. H. Williams (Cygna) letter- to V. .Noonan

                                              .(USNRC), " Status of IAP Conclusions," 84056.050 dated January .25,1985

4. All Communications Reports and correspondence written on all Phases of the Independent

                                             - Assessment Program Sunnary:      The adequacy of and each organizations' compliance with the requisite CPSES' project design related procedures is being reviewed as a result of.the initial trending of observations in Phases 1 through 4.

Status:. This issue is being addressed in conjunction with the cumulative J effects . evaluation. The results of this review will be provided in ~.the : Phase-4. Final . Report.

6. Adeq'uacy of Design Documentation

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections 2.- Cygna Phasel Final 1teport, TR-84042-01, ,

Revision 17 all Sections L 3. N. H. Williams (Cygna) letter to V. Noonan l (USNRC), " Status of IAP Conclusions," B4056.05D, dated . January .25,1985

4. All Connunications. Reports and correspondence written'on all Phases of the Independent Assessment Program Sunnary:' The~ adequacy of: design documentation is being evaluated as a

, result of the numerous undocumented assumptions and inade-l quate-references which were identified during.the IAP tech-l nical reviews. I i l

                                   =. Texas utilities Generr. ting Company h.8 . .i    L a    Comanche Peak Steam Electric Station                                                          i unWNgummmmnN       Independent Assessment: Program --All Phases                                                  '

Job No. 84056

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Revision 0 Page 5 1 , \ l UESIGN CONTROL i Review Issues List , 1

                     ~

Status: This issue is 'being-addressed in conjunction with the , cumulative effects evaluation. The results of this review l will- be.'provided in the Phase 4 Final Report. L. 7 Corrective Action' as it' Pertains to Design Related Issues Identified to Date:

Reference:

     .1.       Cygna Phase .I and 2 Final Report,7-83090-01,
,                                            Revision D, all Sections

2. Cygna Phase 3 Final Report, TR-84042-01,

                                           ' Revision' 1, all Sections

3. - N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25. 1985 -

4. . A11' Communications Reports and_ correspondence

                                         . written on all Phases of. the lndependent-l Assessment Program Sumary:            An assessment is being performed to determine whether or not the issues identified by Cygna on all phases of the IAP should have been detected by TUGC0 through the corrective action system.

Status: . This issue is being addressed in conjunction with the cumulative effects evaluation. The results of this, review vill be provided 11n the Phase _4 Final Report. '

8. Document Control

References:

- 1. . Cygna Phase 1 and 2 Final Report, TR-83090-01,
                                          ^ Revision 0, Observations DC-01-01, DC-01-02 and DC-01-03                                                            .

2. N.H. Williams (Cygna) letter to S.' Burwell (USNRC)

? ~"DCC Satellite. Review Results." 83090.013, dated June'30, 1984 4

3. ' N. H.- Williams (Cygna) letter to V. Noonan

                            .                (USNRC), " Status of IAP Conclusions," .84056.D50, dated January 25,_1985 o                              Text.. Utilities Generating Company til J i A . Comar.che Peak Steam' Electric Station l              mimumimmunmu Independent Assessment Program -- All Phases Job No. 84056-l L                                                                                      '

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                                                                                . DESIGN CONTROL ~

Review Issues List

Summary: Observations concerning the Document Control Center (DCC)

                                                      - and control of. design' documents were written in Phases -1 and                        -

2. Reference 2 was issued to document the adequacy of current DCC' practices. An assessment'is still required to evaluate'the effects of technical and design control '

deficiencies ~ which could be attributed to inadequate controls in the DCC.- Status: . This issue is- being addressed in' conjunction with the - cumulative effects evaluation.. The results of this review

. will- be provided in the Phase 4 Final Report.

                         ' 9. , Design Change Tracking Group References)- 1. : Cygna Phase 1 and 2 Final Report, TR-83090-01, i                                                                  Revision 0,~ Observation DC-01-04

2. N.H.-Williams ~ (Cygna) letter

to S. Burwell (USNRC)

                                                                   "DCTG Data Base Review Results," B3030.017, dated 1

November.6, 1984 i Summary:- The Field Design Change and Review Status Log was reviewed and Observat1on DC-01-04 was . initiated during Phases 1

and 2. The effects of inadequate controls on design changes ~

i are.being' reevaluated to determine'whether or not there was t any possible impact on the. adequacy of the design. Status: This issue is closed except for input to the cumulative effects review. ' 10. Gibbs & Hill Design Input References

References:

' .l.-             Cygna Phase 1 and 2: Final Report TR-83090-01, Revision 0, Observation DC-02-01 ;
                                                        . 2. ~     N. -H. Williams (Cygna) letter to V. Noonan
                                                                  -(USNRC), " Status of IAP Conclusions," '84056.050, dated January .25,'1985                                                                                                              :

Summary: - A Gibbs & Hill design specification required a .different '

                                                        ' edition of ASME Section III. than a computer codel IDLPIPE Version .2c) used for. piping calculations.

Texas. Utilities Generating Company $ .Numnuushauums d.( )( A LIndependent Assessm:nt Frogram --All-Phases Comanche Peak Steam Electric Station-Job No. 84056 i

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       .                                                         Review issues List Status:         LThis observation is considered closed except for input to the cumulative effects review.

i

11. Inspection Reports

References:

1. .Cygna Phase 3 Final Report,'TR-84042-01, Revision 1, Observation DC-01-01

2. . N.H. Willians (Cygna) letter to V. Noonan (USNRC), -

                                                       " Status of. IAP Conclusions," .84056.050, dated January 25, 1985 Summary:         -Three inspection ' reports had been filed in the permanent
                                             ' plant records vault prior to closure.

Status: This observation is closed except for input to the cumulative effects review. 12.TUGC0 Audits

References:

. 1. Cygna Phase 3 Final Report, TR-84042-01, - Revision 1, Observations. DC-01-02 and DC-01-03

12. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                       " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Summary:         TUGC0 Audit files did not contain corrective action responses for selected audit findings.

Status: These observations .are . closed except for input to the cumulative. effects review. i,

.13. Gibbs & Hill Internal Surveillances

References:

1. Cygna Phase 3' Final Report, TR-84D42-D1, Revision 1, Observation DC-02-01  ;

                                            .2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),                                                                            '
                                                      -" Status of IAP Conclusions," 84056.050, dated January 25, 1985 l

Texas Utilities- Generating Company ' l~ L L i Comanche Peak Steam Electric Station -

. mmimmimmmmin. Independent Assessment Program - All Phases '

! Job-No. 84056

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l 1

   '                                                                                         3/28/85 Revision 0 Page 8 DESIGN CONTRDL Review Issues List Summary:        . Documentation which verified that surveillance activities had been performed for 1973 through 1977 was not immediately obtained.

Status: This observation is closed except for input to the cumulative effects review.

14. Gibbs & Hill Management Reviews

References:

~1.       Cygna Phase 3 Final Report, TR-84042-01,
                                        - Revision 1, observation DC-02-02

2. N.H. Williams (Cygna) letter to V ' Noonan (USNRC),

                                          " Status of IAP Conclusions," B4056.050, dated January 25, 1985

Summary: ~ Bibbs & Hill Management Review Evaluation Reports were not

_ available for_1974.through.1976.

Status: This observation is closed except for input to the cumulative effects review.

15. Gibbs & Hill Audit Corrective Actions

References:

1. Cygna . Phase .3 Final Report TR-84042-01, Revision 1, Observation DC-02-03

2. . N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                          " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Suimmary:        Gibbs & Hill had renumbered an audit finding and*not closed the original finding.
                  . Status:         This is closed except forcinput to the cumulative effects review.

16. Evaluation of Gibbs & Hill Design Reviewers

References:

1. Cygna Phase 3 Final Report, TR-84042-01, j

Revision 1, Observation DC-02-04 Texas Utilities Generating Company i I L (') L A Comanche Peak Steam Electric Station " ' mmmmmmtimimm -Independent Assessment Program - All Phases

                             '. Job No. 84056

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3/2B/B5.. , )

     ,                                                                                                                                     Revision 0           '

Page 9 IIESIGN CONTRG. . Revien issues List

                                                                 .2. M.H. Williams (Cygnal letter to V. Noonan (USNRC),
                                                                         " Status of IAP Conclusions," B4056.050, dated January 25,1985 Summiary:               Gibbs & Hill design reviewers werc not evaluated on an
                                                                 . annual .hasis as required.
                                        . Status:                 This observation is . closed except for input to the cumulative effects review.

I k Texas Utilities Generating Company Li.( ;i.4 ' Comanche Peak Steam Electric Station I

                                ' "' " " " -              . Independent Assessnumt Program- All Phases
                                                        . Job Ala. 84Ei6-i
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