ML20135A016

Response to ASLB 850822 Memorandum Re Cygna Practices W/ Respect to Communications W/Comanche Peak Response Team. Related Documents & Certificate of Svc Encl

ML20135A016
Person / Time
Site:	Comanche Peak
Issue date:	09/06/1985
From:	Pigott D CYGNA ENERGY SERVICES, ORRICK, HERRINGTON & SUTCLIFFE
To:
References
CON-#385-456 OL, NUDOCS 8509090315
Download: ML20135A016 (89)

Text

{{#Wiki_filter:' 00CHfC up". CD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'O BEFORE THE ATOMIC SAFETY AND LICENSING BOAR A9,*g 50 S.C? eC In, the Matter of ) TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 () { COMPANY, --et al. ) 50-446 ) (Application for (Comanche Peak Steam ) Operating Licenses) Electric Station, Units 1 & 2 ) ) CYGNA's RESPONSE TO BOARD's MEMORANDUM (Information Concerning Cygna Independence) On August 22, 1985 the Atomic Safety and Licensing Board (" Board") in the above-captioned action issued a request to Cygna that it inform the Board concernino Cygna's practices with respect to communications between it and the Comanche Peak Resnonse Team ("CPRT"). By telephone conversation of August 30, 1985 the Board extended the period of time within which Cyana could resoond to September 6, 1985. Cygna hereby responds to the Board's Memorandum. 1 1 I i CURRENT STATUS OF CYGNA INVESTIGATIONS l i Cygna's investigations have been divided into four phases. This has occurred not as an approach to an overall investigation, but rather, in response to increases in the scope of the investiga-tion as issues arose. Such issues or concerns arose either as a result of the investigation itself or in response to questions raised l as a result of the hearing process. l l 8509090315 850906 l PDR ADOCM 05000445 PDR DSos G

r f Phases I and II. The Cygna Report was initially issued in November 5, 1983, in draft form. This Report was subject to scrutiny and cross-examination in hearings of February, April and May, 1984. An Errata was issued finalizing that report on October 12, 1984. The Phase I and II Report was a limited scope assessment of a portion of the design control process and its implementation. Phase III. This effort was directed primarily toward review of the piping and pipe support designs for selected systems. The Report was initially issued in July 16, 1984 and finalized by an Errata issued November 20, 1984. The report has not been subjected to the HCaring process but has been extensively reviewed by the NRC Staff, Applicant and Intervenors. By letter dated January 25, 1985 from N. Williams of Cygna to V. Noonan of the NRC Staff, Cygna retracted its previous conclu-sion statements pending completion of its entire review. A copy of that letter is appended as Attachment A. Phase IV. This effort is primarily a multi-disciplined l review of the design of a portion of the component cooling water i l system for Unit No. 1. A Report has not yet been issued. It is I presently contemplated that the Phase IV Report will be issued in I l two parts. The first part should be issued later this year and will contain the results of the Phase IV review in the form of checklists and observations. Part 2 of the Report will contain Cygna's overall I conclusions based on all four Phases of the investigation. It is anticipated that the Phase IV, Part 2 Report will issue in the first quarter of 1986. 2 l

r- - + II CYGNA's RELATIONSHIP TO CPRT i l Cygna has not been directly involved in formation of the CPRT's action plan for resolution of all outstanding issues. Cygna has met with the CPRT to apprise it of issues Cygna has observed during its investigation. A meeting occurred on March 14, 1985 at Cygnc's-San Francisco office. The meeting was recorded and extends 105 transcript pages. A copy of the cover page of the transcript i of that meeting, which shows the attendees is Attachment B to this Response. i' Additional communications with the CPRT on technical matters have occurred. Such communications are reflected in the I following attachments: i (C) Communications Report of March 26, 1985 i (D) Communications Report of March 29, 1985 ( ) (E) Communications Report of April 4, 1985 (F) Communications Report of June 13, 1985 I l (G) Communications Report of July 2, 1985 (H) Telefax of July 31, 1985 from Jack Redding of TUGCo to N. Williams of Cygna. (I) Letter of August 6, 1985 from Jack Redding of TUGCo to N. Williams of Cygna. (Transmits a form of Attachment H, above.) Cygna has communicated the bulk of its findings and open items to the CPRT through Review Issue Lists. These lists were sent on April 4, April 23, June 21, and August 13, 1985. Copies of the correspondence forwarding such lists are appended as Attachment J. 3

In addition to the above technical communications, there have occurred by telephone conversations and meetings, discussions between management personnel of TUGCo and Cygna to review scheduling, manpower and other management issues necessary to facilitate Cygna's investigation and to coordinate with CPRT activities. It is Cygna's understanding that the CPRT intends to include all concerns and issues raised by Cygna within the scope of CPRT activities. Cygna does not understand it will be involved in the implementation phase of the CPRT issues response plan.

However, in order to assure that all Cygna concerns are fully understood and addressed, it is contemplated that further meetings will be scheduled in the very near future between Cygna and the CPRT to insure that CPRT has not omitted any Cygna concerns nor misunderstood such concerns.

Both the NRC Staf f and Intervenors will be advised of such meetings and may attend if they so choose. Cygna understands the resolution of its issues and concerns will be based on subsequent activities of the CPRT in the course of its implementation of its Program Plan. Cygna has been advised that CPRT activities will serve as the basis for closure of both specific Cygna findings and their cumulative effects. The presence of the CPRT has, necessarily, slowed the pace of the Cygna effort. Time and resources have been expended to brief the CPRT (e.g. Review Issue Lists) and to review the response plans associated with Cygna's investigation. In dealing with CPRT, Cygna has considered it to be similarily situated to TUGCo and has communi-cated with it in the same manner as it does with TUGCo. Cygna considers such communications to be within the protocol set forth by l l the Board. 4 I I

III CYGNA WILL CONTINUE ITS INDEPENDENT REVIEW As stated above, Cygna has, and is attempting to provide the CPRT with all Cygna issues and concerns. This does not mean that Cygna in any way is abandoning its review effort or reducing the scope of that effort. As previously stated, Phase IV, Part 2 Report will contain Cygna's overall conclusions based on its entire investigation. The activities of the CPRT have in no way affected the scope or ultimate purpose of the Cygna effort. Additionally, with the exception of Cygna's input as an " external source" to the CPRT's gathering of all issues and concerns, Cygna does not currently contemplate expressing any opinion with respect to the implementation or the results of the CPRT effort. Dated: September 6, 1985 DAVID R. PIGOTT Of ORRICK, HERRINGTON & SUTCLIFFE Nll 1XW David R. Pigott,y Counsel for Cygna Energy Services, Inc. 5 l

] RFEIVED D R P d f JAN 2 01985 g r O. H. & s. ll"y,, 415 397 5600 101 Cahfornia Street. Suite 1000. San Francisco, CA 941115894 January 25, 1985 bec: L. weingart 84056.050 M. Shulman J. Minichiello G. Bjorkman C. Killough J. Rues D. i.,eong Mr. Vince Noonan W. Horstman U. S. Nuclear Regulatory Comission P. Morrill 7920 Norfolk ANC P. DiDonato Bethesda, Maryland 20814 J. oszweski S. Bush

Subject:

Status of IAP Ccnclusions R. Nickell Texas Utilities Generating Company N. williams Comanche Peak Steam Electric Station D. Smedley Independent Assessment Program, all phases 84056 Project File Job No. 84056

Reference:

N. H. Williams (Cygna) letter to V. Noonan (U.S. NRC), "Open Items Associated with Walsh/Doyle Allegations," 84042.22, dated January 18, 1985

Dear Mr. Noonan:

As follow-up to the above referenced letter statusing Cygna review open items associated with the Walsh/Doyle allegations, we are transmitting a surrnary scope of potential revisions to previously published observations and conclusions. These changes are due to: 1)information obtained through later reviews which affect the closure of earlier review observations, and 2) conclusions affected by a cumulative effects assessment across all phases of the Independent Assess-ment Program (I AP). Attachment A is an updated Observation Log for Phases 1 through 3 of the IAP. The two right columns indicate whether Cygna anticipates making revisions to either the " Probable Cause" or " Resolution" sections of previously signed-of f observations. Although an individual observation may be statused as " closed," the probable cause of that observation will be reviewed for any significant cumulative effects which indicate trends in the adequacy of the design quality assurance programs being implemented on the Comanche Peak project. Attachment B surinarizes the status of Cygna's conclusions associated with each discipline l' within the IAP review scope. Cygna proposes to provide the updated conclusions considering all phases of the IAP as part of the Phase 4 Final Report. The estimated completion date is May 3,1985, based on closure of the open items discussed in the reference letter. San Francisco Boston Ch.cago RicNano Attachment A

r e ss _ J' Mr. Vince Noonan January 25, 1985 Page 2 Conclusions dealing with areas of particular interest to the NRC rey be sched-uled for submittal prior to Phase 4 Final Report if desired. Please advise us of any priorities at your convenience. Very truly yours, %.94.'t0hhium N.H. Williams Project Manager Attachments cc: Mrs. J. Ellis Mr. S. Treby Mr. S. Burwell Mr. J. B. George Mr. D. Wade Mr. D. Pigott Mr. N. Reynolds NHW/aj b l

Observation

Dy?@jjij ATTACHMENT A Log lilllllllllllifilllllllllllill 1/25/85 Cleesilication To Be Changed Potential Probaldo PHASE 2 Valid findino Closed Ceuen Reechtun Observellon No.

Deectlption Y N Y N Y N Y N Y N DC-01-01 The CPSES Document Control Center (DCC) does not naintain an X X X X X accurate listing of design changes generated against drawings and specifications. This was suo',tantiated upon review of eighteen drawings, seven specifications and approximately 112 associated design changes. These discrepencies are as follows: Design Change Affected Document Missing from DCC Log Dwg. 2323-5-0800 DCA-12534 (Rev. 1) Dwg. 2323-El-0018-01 DCA-16858 3 Dwg. 2323-S-0801 DCA-713 Dwg. 2323-S-U825 DCA-7850 (Rev. 4) DC-01-02 The Design Change Log Books peintained by site file custodians X X X X X did not include the posting of all design changes. This was substantiated upon review of the Document Control Center list of design changes against affected documents versus the site file custodian Design Change Log Books. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 1 of 21

I Observation ??dresiv n v w p-OLa ATTACHMENT A Log 11ll1ll1111111111llll111111111 1/25/85 Claeollication To Be Changed Potential Probetdo PHASE 2 Valid Finding Closed Cause M% 01:ervation Y N Y N Y H Y N Y N No. Description AFFECTED MISSING DOCUMENT DESIGN CHANGE LOCATION SPEC MS-208.1 DCA-14781 Purchasing SPEC MS-208.1 DCA-14026 (Rev. 2) Purchasing DWG 2323-El-0018-01 DCA-9222 (Rev. 1) Electrical SPEC MS-46A DCA-11193 (Rev. 2) Purchasing SPEC MS-46A DCA-11939 (Rev.1) Purchasing SPEC MS-46A DCA-14349 (Rev. 1) Purcha sing SPEC MS-46A DCA-16383 (Rev. 1) Purchasing SPEC MS-46A DCA-17620 Purcha sing SPEC MS-46A DCA-13037 Purchasing SPEC MS-46A DCA-18073 Purchasing SPEC MS-605 DCA-10413 (Rev. 3) Purchasing SPEC MS-605 DCA-17849 Purcha sing SPEC MS-605 DCA-17852 Purcha sing DC-01-03 An initial review of fourteen drawings disclosed that one (Gibbs X X X X X & Hill drawing 2323-S-0801) was not stamped "THIS DOCUMENT AFFECTfD BY DESIGN CHANGES." A further sample of 20 drawings disclosed that four drawings lacked the required stamp. DC-01-04 The Field Design Change and Review Status Log, as maintained by X X X X X the Design Change Tracking Groups (DCTG) was reviewed for com-pliance to Procedure CP-EP-4.7 " Control of Engineering / Design Review of Field Design Changes." The review disclosed: Texas Utilities Electric Company; 83090 and 84042 Sheet 2 of 21 Independent Assessment Program, Phases 1, 2 and 3

Observation D_ _i,M_i,!S.,_ ti 3 Oda^* ATTACHMENT A Log 11111ll1ll11111ll1111111111111 1/25/85 Cla ssific ation To Be Changed Potenisel Probotse PHASE 2 Valid Finden0 Closed Cause MM Cbeervation Y N Y N Y N Y N Y N No. Description 1. The DCTG status log did not accurately reflect all out-standing design changes listed (e.g. Specification 2323-ES-100 DCA-9695; 2323-S-0800, DE/CD's, DCDDA's, FICR's ). 2. The DCTG status log does not accurately reflect the status of design change documents to be incorporated versus design changes not to be incorporated (e.g. DWG. 2323-S-0801, DCA-81 and DCA-92). 3. The DCTG status log contains design changes entered against tha incorrect af fected document. (DCA-1803 was listed (A3 f ist another specification when it should have been 1 w we a ga inst MS-208.1. ) 4. T" icd status log identifies design changes as applicable t.0 -., n documents when in fact they have been voided. DC-02-01 A review of specifications MS-13,15, 29A, and 64, and associ-X X X X X ated revisions and addenda, disclosed that several revisions of specifications MS-13 and MS-15 for safety-related mechanical equipment were apparently issued to the owner prior to perform-ance of design review and/or resolution of design review com-ments as follows: Texas Utilities Electric Company; 83090 and 84042 Sheet 3 of 21 Independent Assessment Program, Phases 1, 2 and 3

ir?s m r2 Observation rm+-+m 85! L 5 i 1 ATTACHMENT A Log

1. I lillllililllillllllllilllillit 1/25/85 Cln esific ation To Be Changed a-PHASE 2 poi.nia.

pron ni. Valid Finding Closed Cause W% Cheervatton Y N Y N Y N Y N Y N No. Description Date Resolution Date Issued Date Design P.O. of Design Spec. Rev. to TUSI Reviewed Issue Review Coments NS-13 0 2/19/75 2/14/75 N/A 2/24/78 HS-13 1 1/1/76 5/27/76 9/11/79 MS-51 ADD 1 10/30/74 12/11/75 N/A No comments tis-51 1 9/9/75 12/31/75 N/A 3/19/76 MS-51 2 11/19/75 3/23/76 3/20/75 8/2/78 DC-02-02 Gibbs & Hill Design Specification MS-200 specifies ASME III, X X X X X 1974 edition, through Summer 1974 Addenda as a design basis. However, the computer code (ADLPIPE Version 2C) used for pipe stress calculations AB-1-69 and AB-1-70 incorporates the require-ments of ASME III, 1974 edition, through Winter 1975 Addenda. DC-02-03 Pipe stress problems AB-1-69 and AB-1-70 were analyzed using the X X X X X computer program ADLPIPE Version 2C dated 4/77. However, the AOLPIPE version dated 9/72 is specified in the CPSES FSAR. PI-00-01 Gibbs and Hill does not specify any weld misnatch (6) when X X X X X determining stress intensification factors for butt welds. PI-00-02 'Gibbs. & Hill uses a 20% increase in the upset and emergency X X X X X condition allowables when considering welded attachment stresses in combination with general piping stresses. Texas Utilities Electric Company; 83090 and 84042 Sheet 4 of 21 Independent Assessment Program, Phases 1, 2 and 3

l Observation erwmzw: p2= psy4

1. $ L 'I i i ATTACHMENT A l C){l t

lillllllilllllllllllllllllllli 1/25/85 Classif 6 cation To Be Charquod PHASE 2 poi.nii. pne.u. Vaild finding Closed Cause MM Observellon Y N Y N Y N Y N Y N No. Description PI-00-03 Gibbs & Hill has no procedure for checking that an adequate X X X X X number of modes are considered in the dynamic analysis. All modes up to 33 Hz are included in the analysis. PI-01-01 The wall thickness used for the computer analysis piping seg-X X X X X ments 16"-SI-074-151R-2 and 16"-SI-073-151R-2 was 0.5 inches. The correct value is 0.375 inches. PI-02-01 The response spectra for the containment structure at elevations X X X X X 805.5' and 860.U' were not included in the analysis for problem 1-70. These are needed to envelope the attachment at penetra-tion MII-5 (elevation 820'-1-9/16"). Cygna did note that the SAM for the containment building were included in the proper a na lysis. PI-02-02 Support RH-1-064-010-S22R (previous tag number RH-1-062-001-X X X X X S22R) is modelled 14 inches downstream from its correct, as-built location on piping segment 8"-RH-1-064-601R-2. PI-02-03 In the welded attachment analysis for the restraints in Problems X X X X X l-70, the analyst used the maximum thermal expansion loads for the equation 11 check, rather than the range of the loads. PI-02-04 The reinforcing pad used in the welded attachnent analysis for X X X X X anchor SI-1-037-005-S32A was 10" long rather than the 8" shown in the latest drawing. Cygna did note that the loads used were a conservative set from a previous revision of the piping analy-sis. Texas Utilities Electric Company; 83090 and 84042 Independent Assessnent Program, Phases 1, 2 and 3 Sheet 5 of 21

Observation

F W r g e s i

c'A L *$ s ATTACHMENT A l C){} 7;q i littlillillllilllilllllilllllt 1/25/85 Cla estf acetion To Be Charged Potential Probette PHASE 2 Valid finding Closed Canae P=a'adast Cteervation Y N Y N Y N Y N Y N No. Descripflon PI-02-05 The incorrect pipe schedule (80 instead of 40) was used in cal-X X X X X culating the allowable forces and moments for the RHR heat exchanger tubeside nozzles. The correct schedule produced lower allowables. PI-03-01 In the finite element analysis for penetration MS-1, 2, 3, 4, X X X X X the geometry below the lower taper (for =2") was modeled incor-rectly, due to an error in element generation. The error resulted in an area of the model with triangular holes adjacent to triangular steel. PS-02-01 The embedment lengths shown on the drawing (6-1/2" and 3-1/2") X X X X X do not match those in the calculation (7-3/4" and 5") PS-09-01 The working range for spring hanger SI-1-042-002-S22K (i.e. top X X X X X up or bottom out) was not checked to ensure that the travel due to seismic movement was within the working range of the hanger. PS-10-01 The design input data for support RH-1-064-010-S22R contained an X X X X X error in the X displacement sign (+.395 " vs. .395"). This error appears on the form transmitted f rom the pipe stress group to the pipe support group for use in the design. PS-12-01 'The allowables for a "PUH" style U-bolt were used in the design X X X X X calculation. The bill of materials calls out a " PUS" style U-bolt. CTS-00-01 Self-weight excitation due to the weight of the support was not X X X X X considered in the tray support design. Texas Utilities Electric Company; 83090 and 84042 Sheet 6 of 21 Independent Assessment Program, Phases 1, 2 and 3 l l l

Observation pyppy;; O'"- ATTACitMENT A IOg illlllllllllilllllllllllilllli 1/25/85 Cinesification To Be Changed Potential Probaldo PHASE 2 Valid rending Closed Cause Roachman Obeoevation Y N Y N Y N Y N Y N No. Description CTS-00-02 Gibbs & Hill performed the calculation of total resultants for X X X X X component loads as follows: a. For anchor bolts, Gibbs & Hill included the dead load in the square root of the sum of the squares (SRSS) combination of component seismic forces. This resultant is 9% less than the actual combination where the dead load effects are added absolutely to the SRSS of the seismic forces. b. Combined component member loads were calculated from static and dynamic loads (i.e., dead, live and seismic) using the algebraic sumation method for the following cable tray supports: Standard Details A, Bj, Cj, and Dj (where i = 1 to 5, j depending on the number of tray levels), details A, B, C, and D of drawing no. 2323-El-0601-01-S, which are based on Standard Detail Dj, and Standard Details 4, 5 and 7. Further review has disclosed that component loads were combined to obtain the worst case loading using the algebraic sumation. Texas Utilities Electric Company; 83090 and 84042 Sheet 7 of 21 Independent Assessment Program, Phases 1, 2 and 3

Observation rm._ _str,?m 6 N L E =^*' ATTACllMENT A {Og .7 ll't!!!1ll111lII1111!I11111lll 1/25/85 Cinestlicellon To Be Changed l Potential Probatdo N2 Valid Find 6no Cause W% _Clo g, Otteervellon Y N Y N Y N Y N Y N Description No. CTS-00-03 In the review of cable tray support calculations, Cygna dis-X X X X X covered the following deficiency in the modeling assumptions for frame analyses: where i = 1 Cable tray Standard Details Aj, Bj, Cj and Dj, d Details A, to 5 depending on the number of tray levels, an B, C and D on Gibbs & Hill drawing 2323-El-0601-01-S which are based on Standard Detail Dj, are modeled as plane f ra mes. Two basic configurations are analyzed. The first configuration consists of two vertical members, called hangers, connected by horizontal members, called beams, which support the cable trays. This configuration is typical for Standard Details Aj, Bj and Cj. The second configuration consists of one vertical hanger and one to four beams which are attached to the hanger at one end and a concrete surface at the other. This second case it typical of Standard Detail Dj and the related Details A, B, C and D. All anchorage points were modeled as pinned in the plane of the frame. End connections consisting of angles anchored to concrete by either one or two bolts were modeled as hinges in the cable tray support frame analysis. The assumption of a fixed Joint is more appropriate considering the rigidity of the base angle connection. Texas Utilities Electric Company; 83090 and 84042 Sheet 8 of 21 Independent Assessment Program, Phases 1, 2 and 3 i

Observation pgg5_.,9 ____w_ y di L S i s ' ATTACHMENT A Log ^ lilllllllllllllllillllllllllll 1/25/85 CIn saltte stion To Be changed Potential Probable PHASE 2 Valid rinding Closed Cause W% Observation -r--- No. Desctlption Y N Y N Y N Y N Y N CTS-00-04 Cable tray Standard Details Aj, Bj, Cj and Dj, where i = 1 to 5, X X X X X depending on the number of tray levels, Details A, B, C and D on Gibbs & Hill drawing 2323-El-0601-01-S which are based on Standard Detail D, and and Standard Details 4, 5 and / uere i modeled as plane f rames. Frame analysis and design were based upon a single ratio of height to width, whereat the ratio varies over the range of frames installed. Tray loads were placed in various directions in an attenipt to simulate the worst case combination for the frame members. For Standard Detail Dj and Details A, B, C and D an analysis of the base plate / angle and the anchor bolts included only loads with the largest accelera-tion factors. The above analysis procedures are deficient for the following reasons: 1. Selection of height to width ratio for the frames does not provide a proper insight into the behavior of all frame members when the ratio varies over such a wide ra nge. For example, the hangers (vertical members) would be subject to larger bending stresses when the ratio is low. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 9 of 21

gweg Observation OLa a' ATTACHMENT A Log lilllilllllllllilllllllllillll 1/2S/85 Cle esifIc etion To Be Changed PHASE 2 potentini probots. Valed Finding Closed Como M% Otteetwation No. Desestption Y N Y N Y N Y N Y N 2. The use of loads with the largest acceleration values in the analysis of the base plate / angle and anchor bolt system is unconservative it precludes the possibility of vertical loads being directed upward, i.e. Opposite gra vi ty. The imposition of upward forces on one beam and downward forces on an adjacent beam coupled appropriately with other forces could result in anchor bolts with higher loads than as originally calculated. Further review disclosed that the worst case aspect ratio was used in the analysis. Also due to the magnitude of the maximum possible vertical seisnic acceleration opposite gravity (1.0 g) no vertical acceleration opposite gravity is possible. Therefore, no upward forces can exist. CTS-00-05 The anchor bolts, base plate / angle and channel of cantilever X X X X X support Detail "E" were originally designed as two-way restraints to resist axial loads on the channel and moments about its major axis. In order to use Detail "E" on a cable tray riser, where it must act as a three-way restraint, the channel section was modified to resist moments about its weak a xi s. The ability of this configuration to function as intended, i.e., to also resist moinents about the weak axis, could not be guaranteed since the anchor bolts and the base plate / angle were not evaluated f or such a load. Texas Utilities Electric Company; 83090 and 84042 Sheet 10 of 21 Independent Assessment Program, Phases 1, 2 and 3

Observation merg; F = - =r W --g di L 5 'a' ATTACHMENT A Log 1911111111ll111111lll1111111ll 1/25/85 Cla ssitac etion To Se charged Potential Proholde PHASE 2 Valid Finding Closed Cause Rossadun Obseewation Y N Y N Y N Y N Y N wo. Deectlption CTS-00-06 The analysis and design of Details A, B, C and D on Gibbs & Hill X X X X X drawing 2323-El-0601-01-S was based upon the analysis and design of Standard Detail Dj, where i = 1 to 5 depending on the number of tray levels. The orientation of the major axis of the C6 x 8.2 section, used as a hanger for both support series, differs is out of by 90 degrees. The major axis for Standard Detail Dj the plane of the frame while for Details A, B, C and D it is in the plane of the frame. As a consequence, Details A, B, C and D are more flexible than Standard Details D. This was not con-g sidered in the analysis. In addition the changes in the design of the beam connections to the hanger were not evaluated. CTS-00-07 Details A, B, C and D on Gibbs & Hill drawing 2323-El-0601-01-S X X X X X utilize base plates with concrete expansion anchor bolts to attach the beam members to vertical concrete surfaces. In the initial base plate analysis, the plate was evaluated as a pinned-pinned beam. The resulting plate stresses exceeded allowables. A second check of plate stresses was made, assuming that the plate acted as a fixed-fixed beam. The calculated stresses were then found to be acceptable. The use of a fixed-fixed assumption is not necessarily representative of the actual situation. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 11 of 21

Observation eg+sinis

u = w w.z; O L "..

ATTACHMENT A Log A liftllitillliiiiiiiiiiiiiiiiii 1/25/85 Classification To Be Changed Potential Prahaham PHASE 2 valed Finding Closed Cause Reachman Observation Y N Y N Y N Y N Y N oescription wo. CTS-00-Ot The cumulative ef fect of the following analysis techniques X X X X X (PFR-01) and/or procedures may have a potential impact on plant safety: Observation No. Description Checklist No. CT S-00-01 Neglect of self-weight CTS-11 -13, -24, excitation of Cable -25.

32. -33 Tray Support.

-34, -35, -37, -38, -39 CTS-00-02 Improper load combination All by the SRSS method CTS-00-03 Errors in computer CTS-2, -3, -lo, modeling a rigid one- -11, -13, -24, or two-bolt base angle -25, -26, -27, as a pinned rather than -28, -29, -30, a fixed connection. -32, -33, -34, -35, -36, -37, -38, -39 l CTS-00-05 Cantilever member with a CTS-6, -14 -15, two-bolt base connection -16, -17, -18, used as a three-way 20. -21, -22 restraint. CTS-00-06 Improper extraplolation CTS-II, -13, of generic design to a specific detail. CTS-00-07 Unconservative assumption CTS-11, -13 for base plate behavior. Texas Utilities Electric Company; 83090 and 84042 Sheet 12 of 21 Independent Assessment Program, Phases 1, 2 and 3

. - _ _ - _ =.-... Observation 15nikss! ?!L"* ' ' ATTACHMENT A Log =7 . 7 : 1 INHIllNMillHillllllilllit 1/25/85 Cle estlic ation To Be Changed Potentiel Probable E2 Valid Finding Closed Caine Resehden Otheeevellon Y N Y N Y N Y N Y N Deectlption No. WD-01-01 The upper locknut on the strut for pipe support SF-X-001-015-X X X X X F43R is not tightened. WD-02-01 The gap between the clamp on support SF-X-007-014-F43R and the X X X X X strut on support SF-X-003-003-F43K varies from 1/4" to 7/16". WD-02-02 The following snubbers were installed 180* from the configura-X X X X X tion shown on the support drawings:

1) SF-X-003-003-F43K

2) SF-X-003-005-F43K

3) SF-X-003-006-F43K

4) SF-X-005-017-F43K WD-03-01 The gap between the pipe and the structural steel for restraint X

X X X X SF-X-033-001-F43R is 0" and 1" in the unrestrained direction, j The support drawing indicates a required gap of 1/2" on both l sides of the pipe in that direction. X X X X X WD-07-01 The spent fuel pool cooling pump is single grounded. X X X X X WD-07-02 Temperature indicator X-TI-4837 was not installed. WD-07-03 Of the six conduits checked, one instance was found where the X X X X X Cable and Raceway Schedule identified the conduit between Spent Fuel Cooling Panel XLV-06 and T130FCZ33 as C-03015123-2. The installation and routing drawing identified this as Conduit No. C-13015123. I Texas Utilities Electric Company; 83090 and 84042 Sheet 13 of 21 Independent Assessment Program, Phases 1, 2 and 3

7:y35@ Observation 5L N ATTACHMENT A Log lillllllllilillllllilllfililll 1/25/85 Cf.esttscation To Be Changed 3 poionical probease Val 6d Finding Closed Canes Reachem Otpeervation Y N Y N Y N Y N Y N peo. Deectlption PI-00-01 The review of the pipe stress analyses identified the X X X X X following items related to Stress Intensification Factors (SIFs): 1.1 Pttin Steam Insife Containment (Stress Problems AB-1-1 through AB-1-4) 1.1.1 No SIF was input for the butt welds at the containment penetration tapered transition joints (TTJs). 1.2 Main Steam Outside Containment (Stress Problems AB-1-23A through AB-1-230) 1.2.1 In stress problems AB-1-23A and AB-1-230, an SIF of 1.0 was used at the run location of the 32 x 4 sweepolet. The correct value is 1.5. 1.2.2 The SIF at the weld end connection (Stress Problem AB-1-23C) to piece no. 9 (8" valve) was 1.4, whereas the correct value is 1.59. 1.2.3 For problem AB-1-23D, no SIF was considered at the connection between the sweepolet and 6" safety va l ve. A value of 1.5 for a TTJ is appropriate. Texas Utilities Electric Company; 83090 and 84042 Sheet 14 of 21 Independent Assessment Program, Phases 1, 2 and 3 a

Ei?vem:

Observation d_ x c a u p !

• Ni$5 ATTACHMENT A Log a

tilllllllBilllllllfilllll!!!! 1/25/85 Cla esitic ation To Be Chesquad PHASE 3 Potential ProbeMe Valid Find mg Closed Canes Raschden Otteervation wo. Description Y N Y N Y N Y N Y N 1.3 Component Cooling h ter (Stress Problem AB-1-061A) 1.3.1 The SIF input for one reducing elbow was 2.9 (using 18" sectional properties) at nodes 20-21; for an identical elbow at nodes 2-3, the SIF was 4.3 (using 24" properties). 1.3.2 The SIF for the weldolets at nodes 105 and 125 on the run pipe used a later Code than the Code of Record. There is no documentation showing the later Code is acceptable and that all related conditions have been met. PI-00-02 The stress evaluation of the break exclusion zones for the X X X X X Main Steam piping outside containment does not consider the effects of the welded attachments when comparing stresses to 0.8 x (1.2Sh + S )* a PI-00-03 The seismic analyses of the itiin Steam piping outside X X X X X Containment used response spectra curves at 2% and 3% damping for 1/2 SSE and SSE, respectively. The modal analyses for these systems show that the primary response is located in the 8" relief lines. This size piping requires the use of curves at 1% and 2% damping. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 15 of 21

s!M=dirs: Observation w = = w:. n A L5

• a ATTACHMENT A Log 1911111111lllIl11111111llll!!1 1/25/85 Cle asific etson To 8e Changed PHASE 3 Potentiel Probaldo Valid Finding Cloeod Cause Reestaan Observetton

peo, Deectlption Y

N Y N Y N Y N Y N PI-00-04 The weight of water and insulation (if applicable) was not X X X X X added to vendor supplied valve and/or flange weights before input to the stress analysis. PI-00-05 Review of the seismic analyses for the nine systems identified X X X X X (PFR-01) the following percentage of mass participation for each calculation: Prob. No. Mass Participation (1) X Y Z AB-1-1 85 63 66 AB-1-2 81 91 76 AB-1-3 85 92 82 AB-1-4 87 88 70 AB-1-23A 36 0 89 AB-1-23B SO O 80 AB-1-23C 67 4 92 AB-1-23D 29 0 83 AB-1-61A 51 18 21 G&H does not perform any additional analyses or calculations to ensure that the inclusion of additional modes does not significantly increase the response of the piping system and result in higher pipe stresses and support loads. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 16 of 21 t

Observation pagigggt i."il L $ a # ATTACHMENT A Log = -- =-n 4 litteliliitititittiltlittillit I/25/85 CIn esitic etion To Be changed Potentlei Probable PHASE 3 Ve16d Finding Closed Cause Roachann Otteeevation Y N Y N Y N Y N Y N Descripflon wo, PI-00-06 Cygna's review of the pipe support calculations for the min X X X X X steam inside containment revealed that in numerous instances the support loads used in design did not etch the values obtained by examining the computer output. PI-00-07 The Fisher Main Steam relief valves have not been qualified X X X X A (PFR-02) for the as-built loads on the snubbers attached to the actuator. PI-06-01 The review of Gibbs & Hill stress problem no. AB-1-23B X X X X X revealed that the combined effects of supports MS-1-240-001-572K and MS-1-240-002-572K were not considered in the local stress evaluation for welded attachments. Both of these supports are attached to the same trunnion. i PI-06-02 The emergency / faulted load combinations for GAH problen no. X X X X ( AB-1-23B do not include the loads and stresses due to safety valve thrust loading. PI-09-01 The review of the Component Cooling Water system revealed that X X X X X no mass point was input between two same-direction supports for two spans (nodes 10 and 6; nodes 50 and 47) in the seismic a nalyses. Texas Utilities Electric Company; 83090 and 84042 Sheet 17 of 21 Independent Assessment Program, Phases 1, 2 and 3

Observation rwgezuw r= =I

• I L 5 i a ATTACHMENT A Log L

tillittilIllllllitillillit!!11 1/25/85 Cin esific ation To Be Chasqped Potential Probotdo PHASE 3 Valid Finding Closed Cause Reechean Observation Y N Y N Y N Y N Y N No. Descripflon PS-01 The design calculation for Main Steam support ilS-1-001-006-X X X X X C72K contains the following input errors in the STRUDL computer analysis model. 1.1 The moment of inertia and section modulus for members 5 and 6 and members 8 to 11 are incorrect. Member Correct Value Input in STRUDL 5&6 Iy = 359.9 Iy = 681.5 Su = 71.9 Sy = 136.3 8 to 11 Iy = 642.7 Iy = 1213.1 Sy = 107.2 Sy = 202.1 1.2 The assumption of a fixed support at Joints 4, 8,14 and 17 is not appropriate for rotation about the vertical axis. 1.3 The input data calculations for the STRUDL model were not checked or approved. PS-02 The stability of two Main Steam supports is maintained by X X X X X providing horizontal " bumper" frame members to limit the support horizontal movement to approximately 1/8". There was no derivation of design load for these " bumper" frame members, nor were there any design calculations. The remainder of the support was designed properly. Texas Utilities Electric Company; 83090 and 84042 Sheet 18 of 21 Independent Assessment Program, Phases 1, 2 and 3

HEW!s! Observation 3 O LC 6 ATTACHMENT A (_Og i 1t!!lllllll111!!11111111111111 1/25/85 Cln esific ation To Be Chargped Potential Pechehle PNASE 3 Valid Finding Closed Co MM Y N Y N Y N Y N Y N No. Deectlption PS-03 When a pipe is rigidly attached to the trapeze beam by X X X X X cinching up a U-bolt, the designers do not consider the effects of pipe rotation. In standard designs, the U-bolt is not tightened, which permits the pipe to rotate freely. Similarly, when two trunnions or a riser clamp are used to allow installation of two snubbers or struts, the designs do not consider the rotational ef fect on load distribution. PS-04 The fillet weld size specified on the following drawings is X X X X X smaller than the minimum fillet weld size required by the ASME B&PV Code: Support CC-1-028-725-S33R, fillet weld between items 1 and 4. Support CC-1-031-009-S33R, fillet weld at support nodes 6 and 11. PS-05 In checking 3-sided welds (" [ "), the designers do not X X X X X transfer the loads on the member from its center of gravity to the center of rigidity of the weld. PS-06 The bearing connection, in which the tubesteel is both welded X X X X X to an embedded plate and bolted to the concrete, was not designed assuming the welds nust resist the total shear load. Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phases 1, 2 and 3 Sheet 19 of 21 1

Observation M ;=,nE m =- m 8i L5a a' ATTACHMENT A Log Illtililillilillllllilllliitil 1/25/85 Cie estf ec ation To Be Chesquad Potential Prohaldo PHASE 3 Valid Finding Closed Cause Roachman Observellon Y N Y N Y N Y N Y N Description No. PS-07 For certain Main Steam supports in which cover plates are X X X X X welded to structural tube steel to form a composite section, the weld design method is incorrect. In some cases where a concentrated load is applied to the composite beam (e.g., where the rear bracket is attached), the local tensile stress is not included in ti.e weld stress calculation. This local tensile stress may be a significant weld stress component. PS-08 In supports designed by the CPSES Pipe Support Engineering X X X X X (PSE) organization, loads due to friction are neglected if the piping thermal movement is less than 1/16". DC-01-01 A review of 367 unsatisfactory Inspection Reports (irs) at X X X X X Comanche Peak Steam Electric Station identified that Inspection Report Nos. BP-00258, BP-00341 and ME-25096 were filed in the Permanent Plant Record Vault (PPRV) without evidence of closure. DC-01-02 Objective evidence could not be found indicating that TUGC0 X X X X X had received corrective action responses to audit findings 2 and 3 from TUGC0 Audit TCP-47. DC-01-03 Objective evidence could not be found indicating the status of X X X X X corrective action for the audit findings reported in TUGC0 audit reports TCP-18. TCP-32, TCP-43 TCP-47 TCP-49, and TCP-70. DC-02-01 Evidence was not found indicating that G8H had performed X X X X X surveillance activities between 1973 and 1977 as required. Texas Utilities Electric Company; 83090 and 84042 Sheet 20 of 21 Independent Assessment Program, Phases 1, 2 and 3 a

1 2 fo M N X X X 1 d 2 M a uq t r Y e e h e C h e S B e N be X X l o a s T bua orC Y P X d N eso-l - CY X X X 9 n o n ll lag N o tc i X X X a in tnd i e n i ts o Y t i t e F P a in v C N r 5 d i 8 l e / o 5 V X X X sg Y 2 bo/ 1 OL dnuo f d t. e. or e iA ne b fS e i en t r. ri A o eo eg n vN wn T E N d Hg s E l 8 n rf M u Gi ee H o d wi C c t n eh A ai iC T s hF v T t t eH A r r8 o g9 G p n n 23 e i. ge 4 R to ih 0d aN st 4 n n c e 8a o it d y i di b d2 t nd d n a i u es a, u A ti 1 l e as 0 a l H na 9s v b8 gb 0e E aG i 3s l sl 8a w6 io ea h n e7 at d u

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o 1 1 i e g 11 3 it 2 3 4 td n l 0 0 0 Un l a. e p3E 1 u 1 E vo 2 2 2 sp 1 1 r 1 0 0 0 ae 1 S eN xd M L11 A 1 1 s ll H C C C en M;Jlll I1 b D D D TI l P O 1

. _ _ -. _ _ - _ = - ATTACHMENT B L'I[ i a 1111llll1111111111111111111111 1. Pipe Stress (Phase 2, 3 and 4) In the pipe stress area, Cygna has reviewed the observations and conclusions from Phases 1, 2 and 3. In addition, Cygna has considered the Phase 4 review scope (Problem AB-1-60), in which no ad-ditional issues were identified. Cygna's present assessment of overall technical adequacy assumes the successful completion of the Mass Participation / Mass Point Spacing Study. In particular, Gibbs & Hill must show that they have considered the effects on: Valve acceleration generic study Flange loads generic study e Welded attachments in break exclusion zones e Welded attachments in general e Areas with stress intensification factor errors as noted in Phase 3 Observation e PI-00-01 Functional capability for stainless steel elbows e Cygna is reassessing the probable cause and resolution for each observation as part of the cumulative The observations which are likely to be revised are shown in At-effects evaluation across all phases. In the r.ase of the pipe stress observations, only PI-00-03 (Phase 2 - Mass Participation) tachment A. and PI-09-01 (Phase 3 - Mass Point Spacing) have been opened due to our present knowledge gained from the Mass Participation Study. Otherwise, none of the technical resolutions have changed on any indi-vidual observations taken by themselves. That is, those which were closed remain closed from a tech-nical basis. Cygna is now, however, reassessing the cumulative impact of each observation for both overall quality assurance implications and overall technical adequacy of the piping. As stated above, a cumulative technical assessment must wait for the final Mass Participation / Mass Point Study re-suits. In addition, any conclusions regarding appropriate stress analysis procedures and implementa-tion of procedures must be reassessed in light of the complete Phase 1 through 4 reviews. I 4 1 Sheet 1 of 6 Texas Utilities Electric Company; 83090 and 84042 Independent Assesscent Program, Phase 1, 2 and 3

L.8 L L & ATTACic olT B 111lll111111111111111111111111 (continued) 2. Pipe Supports (Pase 2, 3 and 4) As in the pipe stress area, Cygna has reviewed the pipe support observations from Phases 1, 2 and 3 and assessed our position on each resolution. As noted in the original Phase 3 conclusions, the nature of pipe support design is such that cumulative effect of individual errors is easier to trace within each support, since each support is a design unto itself. In the support area, however, there remains a number of open issucs, identified in the Phase 3 final report, which have not been closed. These is-sues are generic in nature and consist of: Stability of support components (item "e" in Section 5.2 of the Phase 3 report) e Use of a 50/50 load split for double struts / snubbers (item "f" in Section 5.2 of the e Phase 3 report) Use of U-bolts as clamping devices (item "g" in Section 5.2 of the Phase 3 report) e In addition to the above items, Cygna realizes that the results of the Gibbs & Hill Mass Participation / Mass Point Spacing study must be considered in any reassessment of support adequacy. Also, as noted in our letter 84042.022 dated January 18, 1985, there are additional issues, such as Phase 3 Observation PS-06, which have been reopened as a result of Cygna's overall assessment of the Phase 1 through 4 re-sults. With the above in mind, Cygna has reviewed each observation in Phase I through 3 arid has deter-mined that the status of each individual observation, except Observation PS-02 and PS-06 in Phase 3, remains as shown in the current revision to the observations. That is, those which were closed remain closed. This status, however, is only for each observation taken by itself. The cumulative impact of all the observations on design quality assurance and overall adequacy can be assessed only when all open items are satisfactorily resolved. At this time, Cygna has insufficient data to nake such an assessment of the overall technical adequacy; we are beginning to assess the design quality assurance ramifications with the data we presently have from the 226 supports reviewed in Phase 2 through 4. 3. Cable Tray / Conduit Supports (Phase 2 and 4) Cygna reviewed cable tray support design as part of the Phase 2 work scope and is currently reviewing both cable tray and conduit support designs as part of the Phase 4 work scope. As a result of the Phase 4 reviews, Cygna is withdrawing all Phase 2 conclusions for both technical adequacy and design quality assurance of cable tray support design. Sheet 2 of 6 Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phase 1, 2 and 3

LT Fj t ATTACHMENT B a 111111111lllll11111111111111ll (continued) 4. Equipnent Qualification (Phase 2) As part of Phase 2 of the CPSES IAP, Cygna performed an assessment of the equipment qualification pro-cedures as implemented by Westinghouse. This review did not result in any observations. The scope of Phase 3 and 4 did not include any further reviews in this area and thus Cygna has found no cause to change any of the conclusions presented in the Phase 2 report regarding equipment qualification. 5. Electrical /I&C (Phase 2 and 4) The Phase 2 review in the electrical area assessed both the adequacy of the design documents as well as the design calculations performed by Gibbs & Hill. No observations were identified as a result of this review. As part of the Phase 4 effort, a similar review was performed for a different system. This Phase 4 review has not resulted in any additional information which would cause Cygna to alter the con-clusions presented in the Phase 2 report regarding the electrical design at CPSES. 6. Mechanical Systens (Phase 4) The scope of Phases 1, 2 and 3 of the CPSES IAP did not include any reviews in the mechanical systems An assessment of this discipline was performed as part of Phase 4 and will be discussed in the a rea. final report for that scope of work. 7. Walkdown (Phase 1 and 4) This was Cygna performed a walkdown of the Spent Fuel Pool Cooling System during the Phase 1 review. not the same system that was used in the Phase 2 design review, so Cygna could not draw conclusions concerning the match up between design calculations / assumptions and the actual construction. In Phase

4. Cygna is performing such a review on the Component Cooling Water System. However, that review has not brought out any concerns which alter the conclusions of each individual Phase 2 observation.

As with the other disciplines, Cygn3 is now assessing the cumulative impact of the Phase 2 observations along with Phase 4 and will make its findings known as part of the Phase 4 report. Sheet 3 of 6 Texas utilities tiectric company; 830 m and 64042 Independent Assessrent Program, Phase, 2 and 3

ATTAC K MT B EEE' (continued) 8. Design Change Control (Phase 1) During the Phase 1 review, Cygna assessed the design change control systems and its implementation on the Comanche Peak Project. Several problems were identified with the document control logs and the method of controlled distribution. TUGC0 has addressed these problems through their implementation of a :nore effective satellite document control system. Af ter summarizing the technical fir. dings from all phases, Cygna will assess whether any design impact pay have resulted from any breakdowr.:s in the old document control system. This judgement will be based on the adequacy of the designs within Cygna's technical review scope. 9. Design Analysis Control (Phase 2) For the Phase 2 design analysis control evaluation, Cygna focused its activities on the Gibbs & Hill design of the Residual Heat Removal System - Train B. The calculations within the review scope in-cluded two pipe stress problets, some electrical calculations and some cable tray support calcula-tions. These evaluations were performed at the Gibbs & Hill offices both in New York and at the Comanche Peak job site. Using checklists, the Cygna personnel reviewed calculations, computer programs and their references to ensure that the procedures noted in the program review had been implemented. The results of this review are documented in checklists DC-02-08 through DC-02-12. Any deficiencies found were considered to be minor with no resulting design impact or progransnatic implications. Given the considerably larger sample of Gibbs & Hill calculations reviewed in Phase 3 and 4 Cygna is as-sessing whether or not the Phase 2 conclusions are still valid for the Gibbs & Hill organization. In addition Cygna is reviewing the Phase 1 through 4 technical results to assess the effectiveness of the iterative design process at CPSES. Sheet 4 of 6 Texas Utilities Electric Company; 83090 and 84042 Independent Assessment Program, Phase 1, 2 and 3

(ot u )

10. Interface Control (Phase 1)

As part of the Phase 1 review scope Cygna performed an interface control implementation evaluation for TUGC0 and Gibbs & Hill. The interface control activities by Texas Utilities and Gibbs & Hill were found to be effective, with no observations identified. Further evidence of proper interface control was established by the Cygra technical reviews. This was exhibited by the accurate transfer of design data between groups. An example of this as found in Cygna's verification that the pipe stress analysts used the appropriate pressures and temperatures which were generated by a different disci-pline. Two Phase 3 observations PI-00-06 and PI-00-07, and some of the Phase 4 yet unpublished obser-vations may be indications of some weaknesses in TUGCO's interface control system. Cygna will evaluate i these technical findings for progransnatic ireplications and will provide the results as part of the i Phase 4 conclusions.

11. Criterion I, Organizational Control (Phase 3)

The Phase 3 reviews concluded that the ANSI M45.2.11 requirements for organizational structure, respon-sibilitt and independence were satisfactorily implemented by TUGCO, Gibbs & Hill, NPSI and ITT Grin-nell. ;ygna finds that these conclusions are still valid at this time.

12. Criterion XVI, Corrective Action (Phase 3)

As part of the Phase 3 review, Cygna performed an assessment of the Corrective Action System as it per-tains to design. Cygna did not identify any significant breakdowns in the program as a result of this review. However, whatever conclusions Cygna reaches on the effectiveness of the iterative design pro-cess say impact previous conclusions on the Corrective Action System. l

13. Design Verification Control (Phase 4) l Cygna has conducted an implementation evaluation of design verification control systems used by TUGC0 and Gibbs & Hill as part of the Phase 4 review. Cygna will comment on the effectiveness of the verifi-cation activities on the Comanche Peak Project in the Phase 4 final report.

Texas Utilities Electric Company; 83090 and 84042 Sheet 5 of 6 Independent Assessment Program, Phase 1, 2 and 3

a i ATTACISENT 8 (continued) i

14. Design Input Control (Phase 4)

Cygna has conducted an implementation evaluation of design input control systems used by TUGC0 and Gibbs & Hill as part of the Phase 4 review. Cygna will comment on the ef fectiveness of the systems established within these organizations in the Phase 4 final report. l l i 4 i i Sheet 6 of 6 Texas Utilities Electric Company {83090 and 84042

( 1 2 CERTIFIED COPY s ? Q b( M T m 4 5 N \\ 5 8 6 g. Nj, TEXAS UTILITIES CPRT MEETING k e. 7 y l iq 4, 8 I IN.$ THURSDAY, MARCH 14, 1985 9 9 9:30 A.M. T4 S 10 3 [ U 11 . fj.. g CYGNA ENERGY SERVICES I$;^$[$h 101 CALIFORNIA STREET, SUITE 1000 12 < o - g 13

4.. '

SAN FRANCISCO, CALIFORNIA 14 15 ATTENDEES: 16 HOWARD LEVIN, TERA CORP. DAVID L. SMEDLEY, CYGNA EDWARD BLACKWOOD, TERA CORP. JAMES J. OSZEWSKI, CYGNA 17 F. A. DOUGHERTY, TERA CORP. ROBERT E. NICKELL, CYGNA DOUGLAS M. WITT, TERA CORP. CONSULTANT 18 CHRIS MORTGAT, TERA CORP. ROBERT W. HESS, CYGNA j JOHN GUIBERT, TERA CORP. CRAIG KILLOUGH, CYGNA 19 i TONY GUHL, ENERGEX DICK STUART, CYGNA i TERRY G. TYLER, ENERGEX JOHN C. MINICHIELLO, CYGNA 20 l JACK REDDING, TUGC0 GORDON BJORKMAN, CYGNA i WILLIAM R. HORSTMAN, TUGC0 NANCY WILLIAMS, CYGNA ROBERT C. 10TTI, EBASCO LEE J. WEINGART, CYGNA l WILLIAM 21 VAN METER, CASE WILLIAM R. HORSTMAN, CYGNA 22 JOHN FRENCH, DELIAN CORP. DARLENE K. LEONG, CYGNA SPOTTSWOOD B. BURWELL, NRC/NRR/DL JOHN P. RUSS, CYGNA 23 ANNETTE L. VIETTI, NRC/NRR/DL SPENCER H. BUSH, REVIEW AND VINCENT S. NOONAN, NRC/ PROJECT SYNTHESIS ASSOCIATES 24 DIRECTOR ROBERT E. BALLARD, GIBBS ROBERT A. WOOLDRIDGE, C HILL, INC. 25 WORSHAM, FORSYTHE, SAMPEL & DAVID R. PIGOTT, ORRICK, WOOLDRIDGE HERRINGTON C SUTCLIFFE 26 ARLENE G. MORRIS, CITIZEN 27 3 28 Attachment B l l Q ' *, *],,*, - DOIDGE & C ARROLL ,s.%,.. I CE Riisit O SMORTM AND RF PORTE R$ 3,,,% 4 s. esi asoa DEPOSITION NOT ARiE 5

Communications A (% i Report lillllllllillllillllllllllllll Company-Texas Utilities d Conference Report o Telecon Project Comanche Peak Steam Electric Station Job No 84056 Independent Assessment Program - Phase 4 care 3/26/85 Time 2:30 p.m. suoiect Cable Tray System Dynamic Analysis Place G&H/NYC M. Vivorito, E. Bezkor, P. Huang,MarenoJ. Peir, of Gibbs & Hill Participants S. Chang. R. Ballard. J. Jan. S. C. Mortaat (phone) TERA N. Williams. J. Russ. G. Bjorkman. S. Tuminelli. Cygna M. Engelman, M. Berry, W. Horstman, D. Leong "acEoN, item comments

References:

1. Cable Tray Raceway System Dynamic Analysis Program," dated March 4,1985, Gibbs & Hill, Inc. 2. Communications Report dated March 20, 1985, " Cable Tray Analysis," R. Kissinger, R. Ballard, E. Bezkor, et al. participating In order to respond to issues raised by Cygna regarding the design of cable tray supports for CPSES, Gibbs & Hill performed an analysis of five cable tray systems. The results of this analysis effort are described in Reference 1. As noted in Reference 2, Cygna's review of the Gibbs & Hill analysis was to conclude on March 26, 1985, at which time the results of Cygna's review would be discussed. This report documents discussions between Cygna and Gibbs & Hill regarding preliminary results of Cygna's review of Gibbs & Hill's cable tray dynamic analyses. C. Mortgat of TERA participated in the conversation by telephone. Cygna stated that Case 5 analyses and designs were reviewed in detail because it is within the Cygna scope. Case 1 was selected for spotchecks of procedures and design of components. Items reviewed were briefly listed as follows: NASTRAN Modeling e Members Boundaries Dynamic Degrees of Freedom h y Attachment C /ajb 1 9 N. Willians5 J. Redding[J. van Amerongen, J. Russ, W. Horstman, D. Leong S. i D'"*"" ,o m,.

irecy, v.

uso, 3. uwi mil, Ti n I b

Communications s Atni Report lllll111111111111!l1111111Illl j Uc7oNy nem comments i NASTRAN Analysis Method e Load Application Load Cases and Combinations Design Criteria Anchor Bolts Design Calculations e Methods Procedures Spotchecks for Critical Components Cygna noted that further review of the criteria calculations, design calculations, and applicable documentation would be performed at the Cygna offices. Cygna discussed the following findings of the review in detail: 1. Use of CBAR Elements in NASTRAN Model Cygna noted that CBAR elements were used instead of CBEAM elements. CBEAM elements would have been a more appropriate choice, since CBAR elements can not model in the effects of ecentricities. Quantification of the effects of the selection could not be provided by Cygna. A more flexible system and increased torsion could be expected. The lack of torsion in the beams and weak-axis bending in the hangers is due to the inability of the rigid offsets to move the mass to a position longitudinally eccentric to the hanger-beam gridlines. Cygna stated that the mass must pass vertically through the channel flange and not the grid centerline. The support model, therefore, does not accurately reflect the eccenticities which cause bean torsion and weak-axis moments in the hangers. !!. Eccentricity of the Tray Mass for Longitudinal Supports A rigid beam element with full fixity was used to connect the tray and beam nodes. Since the rigid link maintains a right angle compatibility with the tray longitudinal axes, and the beam is torsionally weak, the tray will take out the torsional moment. Since the tray absorbs the torsional moment, only weak-axis flexure is experienced by the beam. Gibbs & Hill stated that the intent of modeling in the rigid link was to consider the eccentricity of the tray mass. Cygna stated that, had the mments been released at the tray node, the modeling would be more appropriate. Page 2 9 1020 019

r Communications g% rd ) M Report lilllilllll'!!hlilllllilllill [c7oN nem comments Cygna presented an example for a longitudinal support (Type D ) for Case 5. For this support, the torsional moment in 1 the beam was 240 in-lb. If the applied longitudinal reac-tions (788 lb) were multiplied by the vertical eccentricity of 5", the upper bound applied torsional moment would be 3940 in-lb. Cygna further determined that phasing of the longitudinal responses of the tray did not have an effect on tnese results. Gibbs & Hill suggested that the resolution of this issue may depend upon the rigidity of the tray-beam connection. III. Boundary Conditions for Truncated Tray Branches Cygna noted that boundary conditions were not applied consistently for all five tray systems analyzed. More importantly, the branch-tray end nodes were not connected to the rigid nass where response spectrum input is applied. Gibbs & Hill confirmed that support base connections were rigidly linked to the mass, while the tray end nodes were constrained in space and were not connected to the global mass. Cygna stated that the branch tray ends must be connected to the global mass, sir.ce physically, at some point, the branches are connected to a support where excitation is ' applied. Cygna provided an example for the Case 1 analysis where a tray branches off to a tee section. One support on each tee leg was modeled, with truncated ends constrained in global directions. Cygna pointed out that the support immediately before the tee branches was highly stressed, which could have been a result of the fixity of the branch ends with respect to the input motion. The calculated results for this support may be conservative. Cygna also noted that there was no available output to assess the behavior of the area in question, such as support reactions on the tee branches or mode shape plots. IV. Missing Mass Consideration (Higher Mode Response) Cygna discussed the method used by Gibbs & Hill to account for portions of the system mass which are not excited in the response spectrum analyses. The percentages of system mass participating in the dynamic analyses were calculated by Gibbs & Hill and are summarized in Table 1. Gibbs & Hill's practice of smearing the response of this missing mass uniformly over the entire system is not acceptable to Page 3 of 9

Id Communications &ai Report 11111lllll11111ll11111111ll111 Required item Comments Action By Cygna. This is due to the fact that the missing mass should be distributed only to those locations where higher mode participation, i.e., those modes greater than 33 Hz, is dominant. Since the method employed by Gibbs & Hill smears the mass over the entire structure, its use inaccurately estimates selected support loads and other responses. Gibbs & Hill suggested that the methods emoloyed to con-sider the missing mass were consistent with industry practice, and since a low participating mass in the system response was calculated for those frequencies below 33 Hz, the predominant response was rigid. Therefore, a smear technique was an acceptable approach. Cygna diagreed, stating that by having any modal response below 33 Hz, one could determine where the higher frequency responses would occur. Thus, one could employ techniques such as that described by Powell and used in the commercial programs SUPERPIPE, NUPIPE, and ADLPIPE to properly distri-bute the missing mass response. V. Design Criteria Calculations - Anchor Bolts The method by which Gibbs & Hill reduced the joint moments at the support / concrete boundaries is shown in Attachment 1. The reduced moments were used in checking the adequacy of the anchor bolts. Cygna asked Gibbs & Hill to explain the derivation of, or basis for, reducing the moments at base plate / angle connections by considering the base angle fixity ratio. Gibbs & Hill stated that the fixity ratio was the moment distribution factor required when considering the relative flexibilities of the base angles and hanger members. Cygna replied that this was the f acter for only the initial relaxation, that further redistribution of moments in the frame must be considered, and that the final moment in the base connection would be some value other than that predicted by Gibbs & Hill's method. Gibbs & Hill discussed the applicability of AISC connection design philosophy for Type 1 connections to the base-angle connection under review. Cygna stated that justification 1s required to compare and apply the AISC philosophy to the connection details under discussion. Cygna suggested that a comparison be made between the assumedly fixed boundary conditions and the actual boundary condition by performing a moment distribution on a model of the support and its connection configuration. Cygna also Page 4 of 9 1 qvwNn )

F N Communications i [4 Di2Id Report 111111111111111111111111111111 Reqwred item Comments Action By noted that, analytically and realistically, it is not appropriate to assume a model to be fixed or pinned at the base without evaluating the base connection's capacity to accept the moment from the fixed condition or addressing the ability of the base connection to deform through the calculated rotations of the pinned assumption. VI. Design Criteria Calculations - Warping Normal Stresses Cygna described the methodology used by Gibbs & Hill to determine warping normal stresses in beam members. The Gibbs & Hill method considers beam members with fixed-ends to determine a factor which was applied to the member torsion in order to calculate the warping normal stress. The length of a single beam element, which represented only a segment of the beam model (i.e., the hanger node to the tray connection node) was used in the calculation. Cygna feels that a more appropriate approach would be to consider the entire beam member length with pinned ends. The pinned ends are justifiable because the beams are connected to the hangers along the webs only. Gibbs & Hill stated that the models and assumptions used in the criteria calculations were conservative when compared to the method suggested by Cygna. Gibbs & Hill stated that the warping normal stresses were higher for short element sections with fixed ends than for an entire beam model which has pinned ends. Cygna stated that for some cases that was true, but not for all cases. Gibbs & Hill stated that a calculation was performed to show the conservatism of their method. Cygna noted that those calculations were not included in the criteria calculations. Gibbs & Hill will provide calculations to justify the warping normal stress calculations. Cygna then noted that St. Venant shear was not checked, and with consideration of additional torsion previously dis-cussed, the shear stresses may be significant. Gibbs & Hill agreed to check this. VII. Design Calculations Cygna reviewed the methodology for the design calculations and assessed the ability of the procedures to address the concerns of the Review Issues List. Cygna is addressing this portion of the dynamic analysis by review of the design calculations in Cygna's offices. Among the topics that Cygna is concerned with are: A. Consideration of Bolt Holes in Beam Channel Flanges Page 5 o' 9 l to2eein

g Communications Md t'In Report 11111111111111111111111!!11111 Requeed item Comments Action By Cygna asked how the reduction in beam channel section moduli was considered in the dynamic analysis, since the tray locations were not rigidly controlled during the initial tray support l3yout and installation. Gibbs & Hill replied that for the tray attachments within the dynamic analysis scope, the as-built, i.e., actual tray locations, were considered in the design and were found not to be critical af ter refined evaluations. B. Lateral Torsional Buckling Cygna has observed that Gibbs & Hill assumed the trays will provide bracing to the beam and hanger members in their evaluation of lateral torsional buckling (LTB). Gibbs & Hill initiated a discussion of LTB considerations for hanger members. It was agreed that the discussion on this issue would be held at a later date, since this subject is of generic concern. C. Procedure for Calculation of Interaction Ratios For the Case 1 design calculations, Cygna noted that interaction ratios (IR) for steel members were calculated as follows: (IR) Total = (IR)Deadload + (IR) Seismic The documented Gibbs & Hill calculation did not appear to consider the possibility that the following axial interaction ratio would occur: (fa)Deadioad + ( a) Seismic > 0.15 For situations where the axial interaction ratio exceeds 0.15, the total interaction ratio combination used by Gibbs & Hill would be invalidated. Cygna did not observe any cases as described above, but is concerned with the approach to documenting assumptions used by Gibbs & Hill engineers. D. Braces Cygna noted that the Gibbs & Hill calculations for brace members on longitudinal supports use axial allowables for secondary members. Cygna feels that since these brace members provide the primary restraint for longitudinal load, the allowables for Page 6 of 9 ion oth

F 3 m Communications [4M iJ Report 111111111111111111111111ll1111 Requwed item Comments Action By primary members should be used. Gibbs & Hill assumes that these members are secondary and are subject to the AISC Code provisions for such members. Cygna also noted that, since the brace members were modeled with no intermediate nodes, the NASTRAN analyses does not calculate stresses in the brace due to uniform acceleration of the member. These stresses due to gravity and seismic accelerations should be added to the displacement-induced stresses calculated by NASTRAN. Cygna calculations show stresses on the order of 3 ksi for this effect, which may be signifi-cant. Gibbs & Hill will check brace nembers for these additional stresses. E. Welds Cygna noted that no weld checks were contained in the design calculations. Gibbs & Hill is presently check-ing welds for the dynamic analysis cases. The check will be made by comparing the loads from the dynamic analysis to those in the underrun weld analyses. Cygna noted that these calculations did not account for all Cygna concerns such as weld size discrepancies. Cygna and Gibbs & Hill returned to the discussion regarding CBAR elenents and their offsets. Cygna discussed their thoughts on assessing the behavior of the members in the model. Cygna does not fully understand the formulation of the CBAR element and is not assured that the system was properly modeled. The example previously discussed in Section II of this communications report the torsion in the beam is 8k)of the maximum torsion and believes (Longitudinal Support Type D was recalled. Cygna stated that that the result is not reasonable. Additional evaluation would be required to assess the extent of any discrepancies. Cygna asked Gibbs & Hill how they ass 2ssed the rationality of the dynamic analyses results, since it was difficult for Cygna to check certain concerns due to the lack of adequate output generated in the NASTRAN analyses. Cygna discussed an example of calculations done by Cygna to check the behavior of Case 5 under longitudinal load. Since support reactions were not included in the printout, calculations using internal member forces were necessary to check whether the distribution of mass was reasonable. Cygna concluded that the proper magnitude of mass was included in the analysis, but could not ascertain whether the distribution was correct, since output for boundary areas was not provided. Cygna feels that additional of Page 7 g 10M 010

i) Communications A%i Report 1111111111111111llll1111111111 Requwed item Comments Action By output in the boundary areas is necessary to assess the perfor-mance of the dynamic model. Cygna pointed out that, if results were provided in the boundary areas in Case 5, mass distribution could be checked, and an evaluation of the effect of constraining the truncated tray ends as discussed in Section Ill of this communications repor could be performed. Gibbs & Hill stated that they decided to limit the amount of output at the onset of the analysis effort. Only quantities necessary to support the conclusions were requested. Gibbs & Hill feared that if too much output was generated, for example, at the boundaries, there would be a chance that the information could be misinterpreted since some unrealistically high stresses will appear at the boundaries. Cygna stressed that it was difficult to judge whether or not the analysis was a good one, because a line-by-line check of the input was not possible to accomplish in the limited time allowed for Cygna's review of the output. As good practice, Cygna feels that as a minimum, Gibbs & Hill should have provided reviewers with the following to assess the reasonableness of the analysis: 1. Check of reactions at artificial boundaries. 2. Assessment of expectations versus results. 3. Justification for the choice of dynamic degrees of freedom (DD0F) and verification of the system behavior with respect to the choice. This is especially important since DDOFs were chosen at the support nodes instead of at the tray nodes. 4 Mode shape plots for major modes to judge whether the behavior of the system is as expected. Cygna acknowledged that these discussions were preliminary, and that further discussion may be necessary to resolve the issues. Cygna cautioned Gibbs & Hill not to perform substantial rework of the dynamic analysis based on this discussion. Further discussions would be required with TUGC0 since Cygna is not chartered with the responsibility for authorizing work by Gibbs A

Hill, i

Page of I I muun

0 Communications ! s AL%' J Report llllll1lll11111lll111111111111 Required item Comments Action By Cygna sunied up the discussion by stressing the importance of thoughtfully and methodically resolving the concerns.

Overall, there may be a problem applying the results of the dynamic analysis to all cable tray systems at Comanche Peak.

Cygna stated that they have not yet seen the documentation for the filtering process used to select the five cases for the analysis effort. i Page of g g 1020 010

4 TABLE 1 PERCENTAGE OF MASS PARTICIPATING BELOW 33 HZ _________DIBEGI1QN_________ G95E__________!__________Y__________I__ 1 65.3 23.3 47.7 2 42.0 21.0 58.0 1 3 65.0 25.0 35.0 I 4 60.O 23.0 66.0 5 46.0 60.0 69.0 N_O_T_E_S_ 1. Table 1 was summarized from Gibbs & Hill calculation 2323-DMI-14C, Sets 4, 5, 6, 7, 8. 4 4 I i' i I i l i i .n. .... ~,. ~.

t ATTACHMENT 1 Moment distribution factor for base angle Let: K, = which reflects rotational stiffness i Moment distribution factor for support beam K = b which reflects rotational stiffness Joint moment from NASTRAN output M = Reduced joint moment MR = (M)[(K,)/(K, + K )3 = b e 1 l I 4 l

e Communications ,g% id AL Report lilillllillllllllllllifilllll! Q conference n mec n eon Texas Utilities Project Job No 84056 Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 3/29/85 Subiect-Time H 00 a.m. Conduit Support Tests Place CPSES Participants of R. Miller. R. Yow CCL E. Bezkor. P. Huang Gibbs & Hill C. Mortaat TERA R. Kissinaer S. McBee 'UGC0 N. Williams, J. Russ Cygna nequireo item Comments Action By

Reference:

Communications Report dated 3/7/85, " Conduit Review Questions," McBee, Leong and Russ participating Cygna met with Gibbs & Hill, TUGCO, CCL and TERA personnel to discuss the conduit support test program. Per the referenced communications report, TUGC0 had stated that a conduit clamp testing program may be implemented to test clamp behavior under simultaneous three-directional loading. Cygna had reviewed some test data for Unistrut and Superstrut clamps and noted that tests were performed for unidirectional loadings in each of the three directions of restraint. Cygna suggested delaying the test effort until TUGC0 was aware of industry prac-tice on clamp testing and tha use of such test results. Gibbs & Hill described the interaction equation used to determine clamp adequacy. It was noted that C708-S clamps were stronger than C708-U clamps. The tension and shear allowables for Uni-strut P2558 clamps, which are similar to C708-U clamps were used as the controlling allowable loads. Failure was assumed to be controlled by the clamp bolts. The applicable loads and the interaction fonnula are shown in Attachment 1. The safety factor of 2.0 was based on a draft paper regarding electrical compo-nents. The title was not available to Cygna. Based on the discussion of industry practice, TUGC0 was unable to describe the intent of the conduit clamp testing program. Cygna noted that they were performing a review of industry practice and would be checking on other clamp test programs and interactions formulae. !/) ( gwn /ajb 1 5 N. 'W'iillams, d. Redding, J. van Amerongen, R. Kissinger, J. Russ, D. Leong, S. D'stnbution-

Communications A L% i. Report llllllll11111111111ll111111111 [c7eNy item comments Cygna stated that the clamps will in all probability remain intact, but may be deformed to a point where positive contact with the conduit may not be maintained. If contact cannot be assured, the impact on previous responses which rely on such clamp-conduit compatibility such as those that consider a systems behavior must be reevaluated. Along these same lines, Cygna pointed out that the same clamps are used on both two-way and three-way supports. Cygna has noted that some two-way supports have the same stiffness in the longitudinal conduit direction as some three-way supports. If the same types of clamps are used, the supports designed as two-way restraints may be experiencing loads for which they were not designed. This behavior should be addressed by the test program. Cygna asked about the deformation of conduit clamps allowed upon installation. TUSCO stated that the present criteria only al-lowed gaps at the conduit. The deformations were more prevalent with the type P2550 clamps than the type C708-S since the P2558 clamps were shorter. Cygna's concern lies with the shear of the Hilti expansion anchors that attach the clamps directly to the concrete such as in CA-Sa type supports. Cygna will internally investigate the clamp defonnations. Clamp modifications were also discussed. Cygna had previously noted that some clamps were reamed to allow the use of Nelson studs and Hilti expansion anchors. TUGC0 added that C708-S clamps for 4" and 5" conduits were also modified by cutting off the end portion of the clamp ears, thus removing one bolt hole. This modification was made to meet conduit separation criteria. TUGC0 stated that the testing of the modified clamps may be required. Cygna reiterated that further study and consultations be made before embarking on a civnp testing program. Cygna asked TUGC0/Gibbs & Hill to explain the screening process used in selecting the support types for the test program. In response, Gibbs & Hill supplied Cygna with Attachment 2. A meeting was held between TUGCO, CCL and Gibbs & Hill to select i the supports to be included in the test program. In addition to the number of installations of a support type, the criteria in were applied. The first pass was to determine the support types which can be analyzed by AISI code specifications. The shapes in this pass ) would not be asyninetric or loaded in a f ashion which would not J induce torsion into the members. The criteria also specified that transverse supports using asymmetric sections would be enveloped by multi-directional supports. Page of

Communications 3 (% i. Report 111111lll11111ll11ll1111111111 OEo"n"Yy item comments The last two criteria would compare multi-directional supports so as to provide enveloping cases based on configurations and member usage. The application of these last criteria were based on " judgement calls." The entire screening process was based on a visual review of the support drawings to compare configurations, components and loads. Cygna stated that there were two approaches to answering the concerns on the torsional loading of the unsymetric sections. The first approach would be to load rate the actual component by either rigorously testing it under isolated conditions or by testing it within the support. The second method is to load rate the support to determine its capacity. If this second method is used, one must ensure that the test sample is representative and enveloping. Therefore, it is necessary that the " judgement calls" be justified and documented to allow the extrapolation of the test results to the balance of the supports. As a check on the selection process, Cygna will review the Gibbs & Hill drawing package 2323-S-0910. Cygna stated that several Review Issues will also affect the results of the conduit tests. These issues should be considered in any further work. The following issues were discussed. I 1. Dynamic Amplification Factor The effects will be considered in the determination of the final results from the test data. 2. Inertial Support Loads Inertial support loads are determined by the "EZHANG" analyses. The effect of the inertial loads will be sub-tracted from resultant test load to arrive at an effective margin over the design load. 3. Longitudinal Loads on Transverse Supports The consideration of these loads will affect the screening process and will be affected by the clamp testing program. 4. Use of Non-Rigid Conduits on CA-Type Supports l This concern would affect the screening process. TUGC0 suggested that Cygna review Gibbs & Hill specification 2323-ES-100 for the spacing requirements. TUGC0 will check for any previous calculations for support type CA-15. l Page of 3 5

Communications i A Ln u a Report l111ll11111111111ll111111lllll AcSoNy nem comments 5. Use of CA-Type Supports in LS Spans The effect of increased accelerations in transition spans between LS (i.e., flexible) and LA (i.e., rigid) spans must be considered. TUGC0 explained how the test data will be reduced to arrive at the final margins over the design loads. The previous tests have shown that the failure load is 1.6 to 1.8 times the target load. (The target load is 2.5 times the accelerated design load.) Failure has generally been at the maximum deflection of the load cell although other failures have been noted. The loads from the cells are plotted against their deflections. From these curves the effects of support inertial loads will be subtracted. Since the designs were based on an assumed material yield stress, the f ailure loads will be adjusted to account for the actual yield stress as reported in the Unistrut test reports. A margin of 2.5 times the design load is desirable since that factor is specified in the AISI specifications. TUGC0 is performing a second set of conduit tests to address Cygna's comments on the previous tests. The test specimens, drawings of which appcar in Attachment 2, and the loadings are as follows: 1. Test Specimen G-9T The specimen is similar to specimen G3T, but the loading is in the opposite direction. The localized failure of the P1001C3 is being investigated since the spot welds will be placed in tension. 2. Test Specimen G-10T This specimen uses an 8'-0" beam and a 2" conduit so the section will not be stiffened. This configuration will address the torsional capacity of the beam and the tensile capacity of the spot welds. The brace angle has been increased 60, to increase the brace length. 3. Test Specimen G-llT The configuration is identical to specimen G-10T. The intent is to test the brace member. Therefore, a 4" con-duit is used and located on the beam near the brace member. 1 Page O' 4 5

Communications A L % i. Report ll1lll1lll1111llll111111111111 [c7o"Ny item comments 4. Test Specimen G-12T The conduit is placed on the bottom of the beam and load-ings will be directed to induce tensile loads in the spot welds. TUGC0 also stated that the test data will be examined to see how the test results might be extended to qualify the Z-clip connec-tions, Detail CSD-la. Page of 5 5 m em -

h. 0-$f lib ATTACHMW T 2

l SCREENING GUIDELINES FOR TEST CONFIGURATIONS _ I A Review calculations and qualify to AISI - do not test B Not frequently used Transverse support utilizing asyninetric shapes enveloped by multi C directional support Configuration enveloped by other supports - judgement call D Members enveloped by members in other supports - judgement call E CONFIGURATIONS TO BE TESTED BY GROUPING Group 1 - Support against wall or ceiling - Multi-directional support (G1) Selection: CA-la Member size = P5000HS Conduit size = 5'O Bolt size = 3/8"O Hilti Outrigger = P5000 Group 2 - Wall or ceiling mounted - cantilever in one direction and propped-(G2) cantilever in the other direction - Multi-directional support Selection: CSM-6a - wall mounted Group 3 - Wall mounted - propped cantilever in two directions - Multi-directional (G3) support Selection: CSM-9 Group 4 - Wall or ceilir.g mounted - trapeze support with internal or external (G4) braces - Multi-directional Selection: CSM-12 Group 5 - Wall mounted "L" type support with external brace in the longitudinal (G5) direction Selection: CSM-10a Group 6 - Ceiling or floor mounted - propped-cantilever in two directions - (G6) Multi-directional support Selection: CSM-11 Group 7 - Junction box support (G7) Selection: JS-2a l l I

UNISTRUT TYPICAL SUPPORTS UNIT 1 AND COPNON ?' CONDUIT SUPPORT UTILIZING UNISTRUT MEMBERS POSSIBLY RESOLVABLE NOT RESOLVABLE BY AISI SUPPORT TYPE BY AISI ANALYTICAL METHOD ANALYTICAL METHOD-BY TEST ONLY SCREENING A CST-1 X A 2 X A 3 X A 4 X A 5 X A 6 X A 7 X A 8 X A 9 X X C 10 X C 11 C X 12 C X 13a & 13b A 14 X X C 16 17 X(if P1001 or P5001 X(if P1001C3 is used) e C is used) A 18 X A 19 X A 20 X X C 25 X C 33 C X 37 X G3 CSM-1 X G4 2 G4 X 3 X G4 4 X G4 5 G2 X 6a & 6b 8 ~ X G4 X G3 9 X G5 T0a & 10b G6 X 11 G4 X 12' G3 X T3 G4 X 19 .B 44 X 20 X B 21 B X 22 G2 X 26 X Bar 36a & 36b l l l

UNISTRUT TYPICAL SUPPORTS UNIT 1 AND COMMON _ CONDUIT SUPPORT UTILIZING UNISTRUT MEMBERS _ NOT RESOLVABLE BY AISI POSSIBLY RESOLVABLE SUPPORT TYPE BY AISI ANALYTICAL METHOD ANALYTICAL METHOD-BY TEST ONLYSCREENING a6 X SE C M-la X 2a .& v X CSF-la & lb 0#6 X B JA-1 & 2 X 086 3a & 3b X 4a y 4 --u,~. B w ,n X B 16a & b X B 17 X G7 20 X B 24 X 26 G1 X G1 4 f CA-la & b X E E&b X 4 2A X 6 e 04I 7 X 8 &A X 47 9 G7 35-i ) JS-2a G7 G7 JS-2b JS-3 G7 JS-4 G7 JS-5 G7 JS-6 G7 JS-7 G7 JS-8 G7 JS-9 6 fs-so l Support types that are underlined are proposed configurations NOTE: to be tested. l

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( \\ Communications Aim a Report lllllllll1111!I11111111!!!ll11 compaSexas Uti11 ties Xeiecon conference Report ProjectComanche Peak Steam Electric Station Job Nc 84056 U Independent Assessment Program - All Phases 4/4/85 suoiect-Time 5:30 p.m. Discussions with CPRT Place CES-SFR0 Participants F. Dougherty TERA N. Williams CES Reowred item Comments Action By F. Dougherty wanted to briefly review the major Cygna findings arid identify the key references. I provided him with the April 4,1985 (reference Cygna letter 84056.062) transmittal of the RIL and we reviewed the Cygna findings in the piping and pipe support areas, I highlighted the fact that although some of the issues have been partially addressed by Gibbs & Hill, such as mass participation, Cygna is unable to draw any conclusions relative to the cumulative effe cts of the many issues which are interrelated. signed N. Williams, J. Redding, J. van Amerongen, R. Hess, L. Weing*nt, 1 of r v m -- ei,2_ r n_____,, n__2__. rz,_ ,m_ nn, _,,,,- n m. tt c men E ICM 0's

1 l W-Communications M: TJ Report 11111llllll1111111111111111lll company. Texas Utilities Telecon conference Report Job No 84056 Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 Date 6/13/85 T'me 1:00 p.m. Thermal loads on Cable Trays & Supports Place gpg{3 gjgg Participants R.loni EBASCO J. Russ Cygna Required item Comments Action By Cygna spoke to Mr. lotti at his request. He wished to discuss thermal loads on cable trays and their supports and stated that the purpose of the discussion was not to request Cygna's accept-ante of EBASCO's methodology on the evaluation of thermal load effects on Unit 2 cable tray and supports, but to inform Cygna of their actions. I informed him that acceptance of EBASCO's metho-dology could occur only af ter review by the Cygna project review team. Mr. lotti asked what Cygna's experience was with consideration of thermal load effects on cable trays and supports. I informed him that the industry does not generally consider thermal loads on cable trays and supports located outside contaiament. I also noted that the question of thermal load effects was raised to understand Gibbs & Hill's rationale for ignoring a loading com-mitted to in the FSAR. Mr. lotti stated that he had performed calculations which showed that the thermal load ef fects were small and self-relieving. These calculations included the stiff-nesses of the longitudinal supports and showed that the maximum displacements in a 100 feot tray run was approximately 1/16 inch. I added that though these resultant loads are small, they must be considered in conjunction with any other previously identified issues so as to provide a component interaction value less than unity. As far as supports located inside containment, Mr. lotti stated that the thermal loadings were being considered. Work on the supports had proceeded to a point where several supports were identified as requiring modification. This group included several transverse type supports located around a bend from a S'9"'d U Attachment F /ajb Page 1 of 2 f* * 'v i i i i ams, v. neaoing, v. vari nuier urigesi, v. n u a s, vi.,ie r s tiiian,

v. uecng, s.

Distribution Trahv. J Ellis. S. Burwell. Proiect File ,an o, e

T g' Communications L4im rJ Report 1111ll111111111111!!!111111111 Required item Comments Action By longitudinal support. In some cases for this work, Mr. lotti stated that thermal loads were being ignored if the interaction ratios were around 50 percent. If a particular support was found to have high interaction values, the thermal load effects were added in to assure that the interaction values would still be less than unity. l 1 Page 2 2 1020 01 D

( u Communications [4 Fj;rd Report Illilllllilllllillllilllllllli company: Texas Utilities 3 Teiecon conference Report Job No 84056 Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 Date 7/2/85 T'm' 3:40 p.m. EBASCO Memo on kl/r Place SFR0 Participants R. Iotti EBASCO J. Russ Cygna Required item Comments Action By

Reference:

EBASCO Interoffice Correspondence from E. Odar to R. Iotti, dated June 17, 1985, " Comanche Peak NPS; Trapeze Type Hangers - kl/r Considerations" Cygna asked Mr. Iotti if the document referenced above was intended to apply to cable tray supports, pipe supports or both. He replied that the document was intended for use in cable tray evaluations. Mr. Iotti asked for Cygna's opinion on the document. Cygna replied that the document was being reviewed on a technical basis as well as an FSAR commitment basis. l l l I i signed Attachment G /ajb Page 1 of 1 g Distnbution "*"'"'"*""'"9'**"""""W"'"*""'"*"C""' "* " "9' Tepho. d, Ellit. S. Rurwell Proipet Filo 1020 01a

f i JUN 0 t.lCENSING-TUGC0 PAGE.01 gpsq 'I fu: it M th - i 308 B3 3

j. ppf,g DATE Rr.C'D/LOCCO M

' d %,g _? BV u A.,< interotice corr $. Af /J (" E . t0c na.: espondence //. /. /.h;< A4. M-t/fs }. % CROSS REF. FILE 0*T8 - na 17. 1985 P'LE REF v N TO R Iotti, Comanche Peak orrice tOCATaoN No Staj' N././ FAOM E Odar Q874CE LOCATION 81 WTC $UBJECT COMANCHE PEAK NPS [ TRAPEZE TTPE.EAN215'. K1, CONSIDEP.ATIONS /v M i(W.n As dircussed with you earlier today, the following approach to design evaluation of trapetes which hang down from ceilings can (and I think should) be followed fer FI./ consideratione in weak axia of the poet members. (1) AISC has lietted the KL/r for the compression aanbers (i.e. specifies 11y colu.ms in cotspression'and braces) to an essentially arbitrary limit of 200. The tables for allowable cc=pressive ettess, Fa, are prepared up to and including the 200 limit. For coepression mathers whose KI,/r is larger than Cc (about 126 for Fy = 36 kei), the allovable compressive stress Fa (' de calculated by AISC fermia 1.5-2 (page 5-17 of AIsc 7th Edition). The factor of safety beyond KL/r larger than Cc,ie 1.92 on Euler Buckling. Major international codes do go beyond KL/r of 200, se long as the cal-culated stresses are within corresponding reduced Fa values consistent with the KI./r. (See page attached from " Structural Steel Design" book by I.ehigh University). (2) By the nature of the trapeze configuration the primary purpose of the " hanging" trapezas is to resist vertical devnward loads. Therefers the posts of these trapezes can be classified as " main members in tension". AISC allous a KL/r ratio of up to 240 for chese eerbers (page 5-25 of AISC manual). Occasional setemic load vill produce temporary compression on these ce: hors due to transverse Icading and due to vertical upward leadi"E (this is much smaller. Og less than vartical downward leading). The resulting compressive streases, in combination with other applicable stresses will of course be establiehad and related to allowables. (in thf a case allevable Pa vould correspond to the reduced Fa due to higher, up to 240, KL/r value), to assure adey'uscy. l (3) The "K", which establishes the " effective" column length la identified l in AISr. for simple and clearly defined individual column cases (5.138 of ATSC manuii). The establishment of realistic "K" for compression machers (columns) of frates in the direction of plane of frame le more complex and some approximate guidelines are given in AIsc (see 5.139). The "K" for out of plane stability of frse ee le even more difficult to establish. AISC suggests that rigorous methode be utilised if warranted. l

g- ~ JUN 24 '95 16:03 LICENSING-TUGCO PAGE.02 ( 2-(3) (Cont'd) Us are performing frame stability analysis utilizing NASTRAN Code to establish effective column lengths for selected representative cases. ne results of the analysis provide acceptable "K" values for selected - eenfigurations i.e. U1, U2, ult 1. UlBl. etc. D ese values and the studies will be u.ade a part of the evaluation effort. (4) All of the above describes a rational approach to the trapere KL/r con-olderations, and if acceptable, vill reduce the need for edification of sigt:ificant nu _bar of trapazes. (5) Please investigate CYCNA.'s views on the above and inform us ASAP. ( EO:dg

Ateach,

r. A Kanskaris cc:

J P Pada11no R S Alexandru S J Chen Y Latifaoglu E Odar

JUN 24 '85 16:06 LICENSING-TUGCO PAGE.03 q h 9 - ~. r p 'gg coupetst'ow mthalts [Chep. 9 The value of 0.2.*iln L s 0.40 sud 9.51 "providee for inherent erockednese t h and uni.nown eccentricity." 3 AREA. Laustions U.48 and 4.40 are modi 6ed to be used with AS6 steel g. la the AREA Speciheationa for columna of sIcodernas mt.io leu than 130: for riveted endt: F. = 17,000 - 0.11 (in pa') (0.52) For pinned ends: F. = 17,000 - 0.43 (in pai) (0.53)

'l

.i For columns with sienderness ratio gTeater than 130 (or for L'r < 130 f, when desired), the accant formulas cf Eos 9. i4 and 0 53 are to be used: For riveted enda: F,Q z9'34y bT F,=-----.....__ 1 + 0.22. n: (0.75,2)(L/r) VIINET 82) 9 l Fer pinned enda: (9.53) F. = 1 + 0 25 sec (0 875/2)(L/r) VtlF.S.) F./f} 1 tvbere F.S - 100 for A30 steel. ]: P .'N.

2. Favor of Safety y

s Facters of safety have existed as long u the concept of the colurnn 4 curve has been used Indeed, the same contreveny existed one hundr6d ~ L years ago as now-whether the factor of safety should be constant, or .9 variable with L. r. In 1808 Barth' 8 suggested that the factor of safety be I, wheress the vatee rnost ecmmonly used eith columns then was approvimately 4. Today the value is usually around 2. The factor of safety was either I based on an ultimate strength or on an allowable stress ba6. Quite often a factor of safety tras used to estimate the imperfections of the column (end conditions, etc.) and a secoud factor of safety was u6ed on d the sljowable strees. A study of factor of safety is incomplete without an allusion to statietical re naoning. Reference 7.14 ateo givea much s informstlou on the tepic. Factor of safety has been de6ned by Eq.1.2. From the test results of Fig. 9.24. it is obvious that a scatter exists for column strength for any L/r. Indeed,if suffleient test data are avail-able, a frequency curve could be drawn for strength at any 1/r, and tbc standard deviation N of test data could be determined. Figure 9.30 shore a ek tch of a ecattar of tant eseults for a column e Y s

[, t' [S ':p ?.g LS s. ) .. a m. sty estion sPscie4cAf4cws AM. 9.* l [Oop., I6' l,okednese f ;*yd8 '6; g,r yy N, A.H1 setel

1. 444..,q%

- 'han 1:10: p (9.52) o- -y g (f).2 1./r r < IM < ho used: 3 Y (0.N; Ur Pig. 9.30 Seoner el Test Ee wfis (0.5?.) carve, as troll as a mean curve and carves for the standard deviation. For small L/r, The deviation of the neatter cf resulta is not constant. thie dnistion in due entirely to variation in material attength; and for 3Iodium large L.'r, almost entirely due to the condithn of the end finity. eclumn lengths (L/r imm 50 to.150) reflect the effect of residual strees The lower Agure shows a plot of the and initial emt-of.atra ghtuest i deviatiou. K.P & = mcan value). sgsinet the stenderness ratio. av enhtmn i The factor of safety can be band directly on the standard deviation, -> hundred or efse upon a curve whieb represents the lowest values espected (that /tont, or is, curre L in Fig 9.30). Above anch a curve would lie 90 per cent, or A constant factor of safety l @ per cent, etc., of the column strength. i.,1.eas the appears desirable for simplicity, yet such a fsetor proves too conservative -matelv 4 For this for lost L'r and high L/r, and is insafficient for medium L/r.At a design ald.

si either reann a variable facter of safety may be introduced.

is Quik the factor of safety normally would be in the form of tah?es or graphs, n, or gh, i j e usedon each a6 in the cw with the AISC Specification. ) It appears not unlikely that in the future a ratforial design of a strue. 1

e crithout ture will involve load analysis, structural analysis, and safety analyn's

.ve6 mttch The snelyais of the structure enuld be on the component elements as well .. g, g.7 as on the wl. ole, to ensare uniform economy and esfety. ..ter exista Elgure 9.31 compares the factor of safety used trit h the column formulaa are avail, The controversy mentioned above is obvious: l j ,.,nd the of AISC and ABEA (, both cons tant and variable f6etors of safety are used. s a colunm

JUN 24 '85 16: 13 L i C h. N b 1 H u - U w.o mot. a q x 3.. ( 313 Compaawaad assustet (Cris p 9 AIK u5 3 1

e. ggt r r s,c.

x i 2.0.. ~F.t = 192 }y).. d Alita r.s. = 1.69 A-s" v. > c.

1. 8 go Astu ass o t F. = 36 k&.

.h...,p O-3 y -... ~. y Fig. 9.31 Factor of safety for AtSC cad AREA i. .M The AISC Formula takes account of the greater variation in co!cmu jj.j g strength for the medimn alendernece ratios. The coastar.t values of the A ASHO and ABEA vary from 1,07 to 181, depending on the yield point. P

3. Stendemes: Ratio

.1 i Tne AISC Speci6eation provides for ege:tive slenderue=s rities whieb I take into account the end conditions of the column. (S+e Chapter 10 ) g"- The AMHO shd AREA Speci6 cations provide indirectly, in a limit +d manner, for eTective slenderness rat.ios by a!!owing diEerent allowable E '3 strevs fur either rivetn! ends at pinned endi.. that ik, the ute of Ego 9.48, 9.49, 0.&.', and W.M. The eTect of end reatreint becomes much len pronounced for ahert columnir, as in shown in FIR. 9.32. J $. h \\ 40 g - A $C ,k [" 's = = = AAl'40 'i F. agts At si,i f ie. (R = 1.e> w F, = 33 is 8 M - - Fnai sad (K e 0.8) newee P.enes i n.,rty.re,, ~ ~ $-'a a O Bo 400 150 .i. Ele r 4 Pag. 9.3 2 Effect of End Pinity e9 All0*abf e 8tte6s a .'7

fs 1 '1 L ~ 4 (Chey. 9 dd MI onioM :Ps:se c4 wows ,g i .I l 1 ' - k_ ,y by g I 3 g "3 E l{ E! Y ~ 231;"!}i]5}55$ $5 ',;; - 4 5 5 30 t j e.C. n g. N 'f ~ .f 'j i } I }E } 1 si 3 ; } ] 3 3 ! jIi". : j 'n /- ! g-I .'on in column i vafues of the i I ll- ,jJll

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4. Column Femlos Areimd the WeM 8

y .st 4 A compariwn of the AISC Formula with some of thosein most recent use in other countrica l5 8 howl) in Hg 9.33, in which the v&Iues have k been adjusted to a common strees level." 4 h The type of formula used by various countries la tabu!sted below: ((,", the I -; f,.bu n f rv Tvsn. of Fcemtala l u*. Australia (fiAA l Atistria (Onorm)) Simight hae/ Parry-Bobertson eun e of et secant i F g Belgiurn (NBN) 8tright lica f s Britain (B83 8tra ght lune /PerrpBobersarn cuore t i Canada (NBCa atraight line f b Cs +ho.tovaue (C8N) Curve ( France (P W in Paukine ( Cerrnany (lilN) Jager's curve 6 Ifc' land (TGB) Stra'ght line6 ft .M India fjell B*eant 95 [ Iss!y (NCIll Frraight !!ne etter Japan (J8 A h') Para %!a j Baritterf anet ($1A) Straight line ta (;- F. U.tl. A. t Albi.:) CNr' cun e r (5 .s Y l (a PtDEDll 4 d fi

01. lluign a t'mp'e column, Mah an unbrated length of 16 /t and a centcalload of 500 kips. The cobam is pinned at both ends and ASTM A30 s'e+ us to he used.

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f JUL 01 '.45 10:30 LICEN3tNG-TUGCO-PAGE.03 CROSS REFERENCE ~ CYGNA REVIEW ISSUES LIST TO CPRT DESIGN ADEQUACY PROGRAM }. CYGNA' Deslan Adeouoey Prog , I, ' Cable Tror $~upports, Revision 10 Action Plan No. Vill, Civij/ . Structural'DSAP Review Iseues 'l:23 Table Vill.2 (describes IAP issues) Review issues 24 (Design of - To be added to DAP- . Flexoral Members) and 25 (Coble Troy Qualificotton) Table Vill.4 (matrix of I AP issues and which tasks will address them; tasks . are contained in item Vill, pp 7-9, and described in detail in Sections Vill.o through Vill.g. 2.' Conduit Supports, Revision i Actioa Plan No. Vlil, Civil /Structual DSAP Review issues 1-24 Table Vill.3 (desc!rbes I AP issues) Tcble Vill.5 (matrix of IAP !ssues and which tasks will address them; tasks are contcIned In item Vill, pp 7-9, and . g,7; g,, g,.pg,,,;,,,.,y g;, c =_ through Vill.g. 3. Electrical /l&C, Revision i to Appendix A instrumentation Pressure / Action Plan XI, Section 3.1.2, pp.7-9 . Temperature Ratings Wo To be transferred to Guality of C'oble Troy Ttiermolag Fire Construction,OA'/QC Adequacy Pr.ogram Protection (these ora not related to desigd - Temperature Indicator not ' nstalled i . Incorrect cobre ID number - 4. lr.dounical Systerps, Revison ! ' .Af tochinent 3 tq' Appendix A. Review leeves 1 Action Plan X, Section 3.0, pp. 2-3 describes each issue CCW System Maxirnum Temperature Action Plan X.4.'l.5.2.2, p.8 Single Failure /FMEA Action Plan X.4.1.5.6, p.10 I

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CYGNA Class $ Piping Action Plan X.4.1.5.9.3, pp. I l-12 't Surge Tonl(IsaiaYlon oo High. '- - Action Plan X.4.2, p.14 Radtation Sivavi. ~ '~ 5; 'desian Control. Revision I

• Review issues 1-16 do not lend themselves to crose-referencing to the DAP hesswee-they org-stW4elegatio M6ef 4s*m4eth-ef. fee 4.4%e-!A4%. toe-4 and do not now have any conclusions. Phase 4. conclusions will be processed os Externo! Source Issues within the DAP.

~ 6. Ploe Stress and Ploe Suoports' A cross-reference document for review lesues In Pipe Streu and Pips Supports was developed by SWEC and teiecopled to Mr. Jdhn'#.15FiNTTt.7CCC, on J017 d, 1985. The DAP is reviewing this Information to make avre that SWEC's program encompasses all CYCNA issues in these disciplines. t s g i g i

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Aew y-re TEXAS UTILITIES GENERATING COMPANY h KY WAY TOW E N. 400 NORTH OLIV E MTHE ET. L.H. At. DALL4h. TEX Ah 15 308 e p.lo:/R m August 6, 1985 --m CYGNA L Mrs. N. H. Williams es ( '- / Project Manager c JOB NO : Cygna Energy Services y 101 California Street, Suite 100: ' DATE REC'D/t0GGED: M/N/S! ( San Francisco, CA 94111-5894 j 7, 2 /l b CA' l yItEs CROSS REF. FILE

Dear Mrs. Williams:

Attached please find a cross reference of Cygna's Review Issues List to the CPRT Design Adequacy Program. This cross reference document should serve as a road map in facilitating your review and concurrence that all Cygna issues are sufficiently addressed. N The additional cross reference document developed by Stone and Webster on pipe stress and pipe supports discussed in Item 6 of the attachment will be sent to you shortly. Should you have any questions regarding this matter, please don't hesitate to call. Sincerely, C Jdek D. Redding JDR: tic Attachment c - W. A. Horin J. W. Beck A E98 9 8%itb% tb9' 1E A A m C *TILS Tl9:n kl.9:t'TNit' t 0 60t*4 % I Attachment I

I CROSS REFERENCE CYGNA REVIEW ISSUES LIST TO CPRT DESIGN ADEQUACY PROGRAM i CYGNA Design Adequacy Program I. Cable Tray Supports, Revision 10 Action Plan No. Vill, Civil / Structural DS AP Review Issues 1-23 Table Vill.2 (describes I AP issues) Review issues 24 (Design of To be added to DAP Flexoral Members) and 25 (Cable Troy Ovalification) Table Vill.4 (matrix of IAP issues and which tasks will address them; tasks are contained in item Vill, pp 7-9, and described in detail in Sections Vill.a through Vill.g. 2. Conduit Supports, Revision I Action Plan No. Vill, Civil /Structual DSAP Review issues I-24 Table Vill.3 (descirbes I AP issues) Table Vill.5 (matrix of IAP issues and which tasks will address them; tasks are contained in item Vill, pp 7-9, and described in detail in Sections Vill.a through Vill.g. 3. Electrical /l&C, Revision I to Appendix A Instrumentation Pressure / Action Plan XI, Section 3.1.2, pp.7-9 Temperature Ratings Walkdown items: To be transferred to Quality of - Cable Troy Thermolog Fire Construction OA/OC Adequacy Program Protection (these are not related to design) - Temperature Indicator not installed - Incorrect cable ID number 4. Mechanical Systems, Revison 1 to Appendix A Review issues I-5 Action Plan X, Section 3.0, pp. 2-3 describes each issue CCW System Maximum Temperature Action Plan X.4.l.5.2.2, p.8 Single Failure /FME A Action Plan X.4.l.5.6, p.10 I TENERA h CORIORATK)N

CYCNA Design Adequacy Program Class S Piping Action Plan X.4.l.5.9.3, pp. I l-12 Surge Tank Isolation or High Action Plan X.4.2, p.14 Radiation Signal S. Desian Control, Revision I Review issues I-16 do not lend themselves to cross-referencing to the DAP because they are still being evaluated for cumulative effects in the LAP Phase 4 and do not now have any conclusions. Phase 4 conclusions will be processed as External Source issues within the DAP. 6. Pipe Stress and Pipe Supports A cross-reference document for review issues in Pipe Stress and Pipe Supports was developed by SWEC and telecopied to Mr. John W. Beck, TUGCO, on July iI, 1985. The DAP is reviewing this information to make sure that SWEC's program encompasses all CYGNA issues in these disciplines. 2 TENElu h CORIUIMTION

r*. Q '.' P.7.T G. E M.*d )f.k7 k b 5. -"rs imme 101 California Street. Suite 1000. San Francisco. CA 9411f.5894 April 4, 1985 84056.062 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 summarizes 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 Revision 0 Pipe Supports Revision 0 Mechanical Systems Revision 0 Cable Tray Supports Revision 8 Design Control Revision 0 Conduit Supports Revision 0 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, %V.1dd%-c N.H. Williams Project Manager NHW/dco Attachments cc: Mr. V. Noonan (USNRC) w/ attachments Mr. S. Burwell (USNRC) w/ attachments Mr.S.Treby(USNRC)w/ attachments Mr. W. Horin (Bishop, Liberman, et al.) w/ attachments Mr. J. Redding (TUGCO) w/ attachments Ms.J.yanAmerongen(TUGCO/EBASCO)w/ attachments Ms.J.Ellis(CASE)w/ attachments Mr. D. Pigott (Orrick, Herrington & Sutcliffe) w/ attachments Mr. F. Dougherty (TENERA) w/ attachments l Mr. R. Ballard (Gibbs & Hill) w/ attachments Mr.R.Kissinger(TUGCO)w/ attachments san Francisco Boston Ch.cago R.cNa no

T (?.'Y $L f.? {.' ? l'.ii r L if a dL a ammess 101 Cahfornia S9eet Suite 1000. San Francisco. CA 941115894 415 3D $630 April 23, 1985 84056.064 Mr. J.W. Beck Manager - Licensing Texas Utilities Generating Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 i

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 1 Electrical /I&C Revision 1 Pipe Supports Revision 1 Mechanical Systems Revision 1 Cable Tray Supports Revision 9 Design Control Revision 0 Conduit Supports Revision 1 All significant changes or additions are noted by a revision bar in the right margin. These lists are still being reviewed by Cygna personnel on a weekly basis and will to be reissued as necessary. If there are any questions, please do not hesitate to call. Very truly yours, f 4 M.H. Williams Project Manager NHW/dco Attachments cc: Mr. V. Noonan (USNRC) w/ attachments Mr. S. Burwell (USNRC) w/ attachments Mr. S. Treby (USNRC) w/ attachments Mr. W. Horin (Bishop, Libeman, et al.) w/ attachments Mr.J.Redding(TUGCO)w/ attachments Ms. J. van Amerongen (TUGC0/EBASCO) w/ attachments Ms. J. Ellis (CASE) w/ attachments Mr. D. Pigott (Orrick, Herrington & Sutcliffe) w/ attachments Mr. F. Dougherty (TENERA) w/ attachments 1 Mr. R. Ballard (Gibbs & Hill) w/ attachments Mr.R.Kissinger(TUGCO)w/ attachments l sen Francisco Boston Ch4ago R.cniend

m.. vg c iia 4l}} Lu 101 Cahfornia Street, Suite 1000, San Francisco. CA 941115894 415 397-5600 June 21, 1985 84056.072 Mr. J.W. Beck Maneger - 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

Reference:

N.H. Williams (Cygna) letter to J.W. Beck (TUGCO), " Review Issues List Transmittal," 84056.064, dated April 23, 1985

Dear Mr. Beck:

Enclosed are the latest revisions to the Cable Tray Support and Design Control Review Issues Lists (RIL). These lists summarize all the findings and open items identified to date. The current RIL revisions for other disciplines remain as transmitted by the above referenced letter. The enclosed RIL revisions are as follows: o Cable Tray Supports, Revision 10 o Design Control, Revision 1 All significant changes or additions are noted by a revision bar in the right margin. These lists are still being reviewed by Cygna personnel on a weekly basis and will to be reissued as necessary. If there are any questions, please do not hesitate to call. Very trul yours. Vf, bo 4L4t% N.H. Williams Project Manager NHW/ajb Attachments cc: Mr.V.Noonan(USNRC)w/ attachments Mr. S. Burwell (USNRC) w/ attachments Mr.S.Treby(USNRC)w/ attachments Mr. W. Horin (Bishop Libennan, et al.) w/ attachments Mr.J.Redding(TUGCO)w/ attachments Ms. J. yan Amerongen (TUGC0/EBASCO) w/ attachments Ms. J. Ellis (CASE) w/ attachments Mr. D. Pigott (Orrick Herrington & Sutcliffe) w/ attachments Mr. F. Dougherty (TENERA) w/ attachments Mr. R. Ballard (Gibbs & Hill) w/ attachments Mr. R. Kissinger (TUGCO) w/ attachments San Francisco Boston Chicago Rechland

[ p Pi1EaP 4t f =-- aseverts 101 Cahfornia Street. Suite 1000. San Francisco, CA 941115894 415 397 5600 August 13, 1985 84056.080 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 (RIL) Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - All Phases

Reference:

1. N.H. Williams (Cygna) letter to J. W. Beck (TUGCO), " Review Issues List Transmittal," 84056.064, dated April 23, 1985 ? N.H. Williams (Cygna) letter to J.W. Beck (TUGCO), " Review Issues List Transmittal," 86056.072, dated June 21, 1985

Dear Mr. Beck:

Enclosed are revisions to the mechanical systems, electrical /I&C, cable tray supports and conduit support Review Issues Lists (RIL's). All significant changes are noted by a revision bar in the right margin. The cable tray and conduit support revisions were primarily made to clarify Cygna's concerns. This is partly true for the mechanical systems and electrical /I&C RIL's however, some new items have been added. These additions have resulted from Cygna Project and Senior Review Team meetings held to finalize the phase 4 review checklists. At this time we do not anticipate any further significant additions to the RIL. We will however, continue to maintain the RIL until we issue the final report. l San Franc.sco Boston Chicago R.chfand

] =- IdevCES,_ Mr. J. W. Beck August 13, 1985 Page 2 The current revisions to each discipline RIL is as follows: Discipline Revisions Cygna letter reference Pipe Stress 1 84056. 064 Pipe Supports 1 84056. 064 Cable Tray Supports 11 84056. 080 Conduit Supports 2 84056. 080 Mechanical Systems 2 84056. 080 Electrical / I&C 2 84056. 080 Design Control 1 84056. 072 If there are any questions please call at your convenience. Very trul yours, .k, N.H. Williams Project Manager Attachments cc: Mr. V. Noonan (USNRC) w/ attachments Mr. S. Burwell (USNRC) w/ attachments Mr. S. Treby (USNRC) w/ attachments Mr. W. Horin (Bishop, Liberman, et al.) w/ attachments Mr. J. Redding (TUGCO) w/ attachments Ms. J. van Amerongen (TUGC0/EBASCO) w/ attachments Ms. J. Ellis (CASE) w/ attachments Mr. D. Pigott (Orrick, Herrington & Sutcliffe) w/ attachments Mr. F. Dougherty (TENERA) w/ attachments Mr. R. Ballard (Gibbs & Hill) w/ attachments Mr. R. Kissinger (TUGCO) w/ attachments l l

e i i i 'YNhf UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOA 'M kitfUCRt,,:, a RM NCH 'il-i In the Matter of ) l TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 I COMPANY, et al. ) 50-446 i ) (Application for i (Comanche Peak Steam ) Operating Licenses) i Electric Station, Units 1 & 2 ) } } 1 l CET,'T.FICATE OF SERVICE i I hereby certify that copies of CYGNA's RESPONSE TO j BOARD's " MEMORANDUM (Information Concerning Cygna Independence)" i in the above captioned matter were served upon the following ] persons by overnight delivery (*), or deposited in the United l States mail, first class, postage prepaid, this 6th day of r September, 1985. j SEE ATTACHED LISTS. I 1, j-b/A nW / 7 < p gaaiena M. Cruz e I I I I i 4 1 i t i k (

f Comanche Peak - Service List Administrative Judge Peter B. Bloch Mr. Robert Martin U. S. Nuclear Regulatory Commission Regional Administrator, Region IV 4350 East / West Highway, 4th Floor U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Judge Elizabeth B. Johnson Oak Ridge National Laboratory Lanny A. Sinkin P. O. Box X, Building 3500 3022 Porter St., N. W.,

1. 304 Oak Ridge, Tennessee 37830 Washington, D. C.

20008 Dr. Kenneth A. McCollom Dr. David H. Boltz c/o Neal McCollom 2012 S. Polk 4851 Winesanker Way Dallas, Texas 75224 Fort Worth, Texas 76133 William Counsil, Vice President Dr. Walter H. Jordan Texas Utilities Generating Company 881 W. Outer Drive Skyway Tower Oak Ridge, Tennessee 37830 400 North Olive St., L.B. 81 Dallas, Texas 75201 Administrative Judge Herbert Grossman U. S. Nuclear Regulatory Commission Docketing and Service Section 4350 East / West Hignway, 4th Floor (3 copies) Bsthesda, Maryland 20814 Of fice of the Secretary U. S. Nuclear Regulatory Commission Nicholas S. Reynolds, Esq. Washington, D. C. 20555 William A. Horin Bishop, Liberman, Cook, Purcell Ms. Billie P. Gardo & Reynolds Government Accountability Project 120 0 - 17 th S t., N. W. 1901 Que Street, N. W. Washington, D. C. 20036 Washington, D. C. 20009 Geary S. Mizuno, Esq. Thomas G. Dignan, Jr., Esq. Office of Executive Legal Director Ropes & Gray U. S. Nuc1 car Regulatory Commission 225 Franklin Street Maryland National Bank Bldg. Boston, Massachusetts 02110 - Room 10105 7735 Old Georgetown Road Mark D. Nozette, Counselor at Law B3thesda, Maryland 20814 Heron, Durchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, N. W., Chairman, Atomic Safety and Licensing Suite 700 Board Panel Washington, D. C. 20007 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Stuart A. Treby, Esq. Richard G. Bachmann, Esq. Chairman Office of the Executive Atomic Safety and Licensing Appeal Legal Director Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 I I --y-n - - - +

I -x i Comanche Peak - Service List (Cont ' d. ) Mrs. Juanita Ellis j President, CASE 7 1426 S. Polk Street i Dallas, Texas 75224 1 Renea Hicks, Esq. i Assistant Attorney General i j Environmental Protection Division j Supreme Court Building Austin, Texas 78711 ~ i Anthony Z. Roisman, Esq. j Trial Lawyers for Public Justice ) 2000 P Street, N. W., Suite 611 l Washington, D. C. 20036 j i j Mr. Owen S. Merrill Staff Engineer Advisory Committee for Reactor j Safeguards (MS H-1016) U. S. Nuclear Regulatory Commission 1 Washington, D. C. 20555 Robert A. Wooldridge, Esq. Worsham, Forsythe, Sampols & Wooldridge 2001 Bryan Tower, Suite 2500 l Dallas, Texas 75201 i I 1 i 1 1 i I t l I - - -.. - - -.. -. ~ -. - - - - -... -. - - -}}