ML20147C309

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Forwards Transcript of Util 871217 & 18 Meetings W/Case Re Continuation of Discussions That Started in Mar 1987 on Pipe Supports.Presentation Matl Also Encl
ML20147C309
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/07/1988
From: Malloy M
NRC OFFICE OF SPECIAL PROJECTS
To:
NRC OFFICE OF SPECIAL PROJECTS
References
NUDOCS 8801190165
Download: ML20147C309 (434)


Text

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January 7, 1988 Docket Nos. 50-445 and 50-446 NOTE T0: File FROM: Melinda Malloy, Project Manager Comanche Peak Project Division Office of Special Projects

SUBJECT:

PUBLIC MEETING BETWEEN TV ELECTRIC AND CASE ON DECEMBER 17 AND 18, 1987 On December 17 and 18, 1987, Texas Utilities Electric Company (TV Electric),

applicant for the Comanche Peak Steam Electric Station, Units 1 and 2, met withrepresentativesoftheCitizensAssociationforSoundEnergy(CASE)to continue discussions that started in March 1987 on pipe supporth flepre-sentatives from NRC's Comanche Peak Project Division. Office of special Projects and the Office of General Counsel attended this meeting as observers.

Enclosed for the record is a copy of the transcript of this meeting. Since the NRC staff did not participate in this meeting, it is the staff's position that any determination as to whether the Atomic Safety and Licensing Board should be informed of this meeting should be made by the applicant or intervenor.

(original signed by)

~

Melinda Malloy, Project Manager Comanche Peak Project Division ,

Office of Special Projects l

Enclosure:

MeetingTranscript(2 volumes) and Presentation Material ,

cc: w/o enclosure: See next page

. DISTRIBUTION (w/ enclosure): DISTRIBUTION (w/o encl):

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Docket Nos. 50-445  !

and 50-446

, NOTE T0: File FROM: Melinda Malloy, Project Manager i Comanche Peak Project Division Office of Special Projects -

SUBJECT:

PilBLIC MEETING BETWEEN TV ELECTRIC AND CASE ON DECEMBER 17 AND 18, 1987 On December 17 and 18, 1987 Texas Utilities Electric Company (TV Electric),

applicant for the Comanche Peak Steam Electric Station, Units 1 and 2, met with representatives of the Citizens Association for Sound Energy (CASE) to continue discussions that started in March 1987 on pipe supports. Repre-sentatives frem NP.C's Comanche Peak Project Division, Office of Special Projects and the Office of General Counsel attended this meeting as observers.

Enclosed for the record is a copy of the transcript of this meetin Since the NRC staff did not participate in this meeting, it is the staffg.s position that any determination as to whether the Atomic Safety and Licensing Board should be informed of this meeting should b made by the applicant or intervenor.

~

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at Melinda a loy, Project Man r Comanche Peak Project Divis n Office of Special Projects

Enclosure:

Meeting Transcript (2 volumes) and Presentation Material cc: w/o innelosure: See next page i

A. J

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i j ENCLOSURE l 4

i i PUBLIC MEETING BETWEEN TV ELECTRIC and CASE DECEMBER 17-18, 1987 .

i Meeting Transcript and Presentatien Material i

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10 PRESENTATION MATERIAL 11 FROM 12 TU ELECTRIC PUBLIC MEETING 13 14 15 December 18, 1987 16 17 18 19 20 22 RECDVED g , DEC 2 31987 24 MLLIAM G. COUNSIL 25 Carmen Gooden, CSR, RPR, Metro 429-5532

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CAP ORGANIZATION l

0 THREE (3) CONTRACTORS 0 ELEVEN (11) SCOPES OF WORK j l

0 WORK PERFORMED UNDER CAP REPORTED IN ELEVEN (11) PROJECT STATUS REPORTS (PSRs) l l

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PROJECT STATUS REPORTS LARGE BORE PIPE SUPPORTS SWEC PSAS SMALL BORE PIPE SUPPORTS SWEC PSAS MECHANICAL SWEC SYSTEM INTERACTION EBASCO FIRE PROTECTION IMPELL CIvrt/ STRUCTURAL SWEC ELECTRICAL SWEC I&C SWEC HVAC EBASCO Ecu2PMENT QUALIFICATIONS IMPELL CABLE TRAY HANGERS EBASC0/IMPELL CONDUIT SUPPORTS TRAINS EBASCO A, B, AND C > 2" CONDUIT SUPPORTS TRAIN C < 2" IMPELL

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CORRECTIVE ACTION PROGRAM (CAP)

O MISSION DEMONSTRATE THAT THE DESIGN OF SYSTEMS, STRUCTURES AND COMPONENTS COMPLIES WITH LICENSING COMMITMENTS DEMONSTRATE EXISTING SYSTEMS, STRUCTURES AND COMPONENTS ARE IN COMPLIANCE WITH DESIGN OR DEVELOP MODIFICATIONS WHICH WILL RRING SYSTEMS, STRUCTURES AND COMPONENTS INTO COMPLIANCE WITH DESIGN j -

DEVELOP PROCEDURES, ORGANIZATIONAL PLAN AND DOCUMENTATION TO MAINTAIN COMPLIANCE TO LICENSING COMMITMENTS THROUGH THE LIFE OF COMANCHE PEAK e

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CORRECTIVE ACTION PROGRAM (CAP) l 10ENTIFY LICENSING G FSAR  !

COMMITMENTS q - OTHER LICENSING 00CUMENTS I DEVELOP DESIGN 8 ASIS DOCUMENTS (080'$)

p PERFORM DES 10N 4 CPRT (DAP & QOC)

VALICATloN 4 EXTERNAL ISSUES NRC (SRT, SIT, TRT, CAT)

CYGNA (IAP)

CASE f ASLS NRC INSPECTION REPORTS IS VF2 MODIFICATION y DES!CN REQUIRED MODIFICATIONS

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HARDWARE VAll0ATION 4 BUILD / INSPECT PROGRAM (PCHyP) M00lFICA TION l

Y FINAL DESIGN RECONCILIATION i

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IS yES A00lT10NAL VAUDATION REQUIRE 0

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) NO ,

l FINAL 00CUMENTATION j (CESIGN YAll0 AT10N P ACK AGES) i 4 i 9

PROJECT STATUS REPORT (PSR)

O REPORT ON HOW OBJECTIVES OF CAP WERE MET 0

REPORT ON HOW ALL ISSUES WERE RESOLVED 0

IDENTIFIES THE PREVENTATIVE ACTION TO ASSURE SIMILAR DO PROBLEMS NOT OCCUR IN THE FUTURE l

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CORRECTIVE ACTION PROGRAM WHEN COMPLETED, ASSURES THAT:

0 THE DESIGN OF SYSTEMS, STRUCTURES AND COMPONENTS, COMPLIES WITH LICENSING COMMITMENTS 0 SYSTEMS, STRUCTURES AND COMPONENTS ARE INSTALLED IN ACCORDANCE WITH DESIGN O ALL IS$uES ARE RESOLVED 0

DESIGN DOCUMENTATION IS ACCEPTABLE AND CONTROLLED 4

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e CORRECTIVE ACTION PROGRAM CIVIL / STRUCTURAL MECHANICAL ELECTRICAL INSTRUMENT AND CONTROLS

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0 SWEC SCOPES OF WORK '

6 0F 11 SCOPES.ARE SWEC RESPONSIBILITY

, O PREVIOUSLY DISCUSSED:

LAnoE BORE PIPE SUPPORTS l

SMALL BORE PIPE SUPPORTS i

0 DISCUSSED HERE:

CIVIL / STRUCTURAL ELECTRICAL I INSTRUMENT AND CONTROLS l MECHANICAL

  • MECHANICAL SCOPE OF WORK INCLUDES SYSTEM INTERACTION (EBASCO)

FIRE PROTECTION (IMPELL)

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O SWEC DESIGN VALIDATION ACTIVITIES ARE DIVIDED INTO THE FOLLOWING  !

DESIGN VALIDATION PACKAGES (DVPs) 1

- i CIv!L/ STRUCTURAL DVPS 1 i

CONTAINMENT CONCRETE i

CONTAINMENT CONCRETE INTERNALS I FUEL BUILDING SAFEGUARDS BUILDING AUXILIARY & CONTROL BUILDING SEISMIC CAT I TANK / PIPE TUNNELS SERV!CE WATER INTAKE STRUCTURE SEISMIC CAT I STRUCTURAL STEEL PIPE WHIP RESTRAINTS CONTAINMENT LINER & PENETRATIONS OTNER LINERS / FURL TRANSFER TusE SUPPORT MISCELLANEOUS EQUIPMENT Supports CONCRETE ANCNORS TORNADO DESIGN TESTING PROGRAMS SEISMIC ANALYSIS VALIDATION (ARS)

. GENERAL CIVIL / STRUCTURAL STRUCTURAL SPECIFICATIONS GEoTF.CNNICAL/SSIDAM i

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0 SWEC DESIGN VALIDATION ACTIVITIES ARE DIVIDED INTO THE FOLLOWING DESIGN VALIDATION PACKAGES (DVPs) (CONTINUED)

ELECTRICAL DVPS PREFERRED P0wtR SYSTEMS ONSITE POWER SYSTEM 6.9 KV MEDIUM VOLT SYSTEM 480 V & 120 V L0w VOLT SYSTEM UNINTERRUPTIBLE POWER SYSTEMS DC SYSTEM ELECTRICAL PROTECTION SYSTEM CABLE SYSTEM ELECTRICAL INDEPENDENCE CALCULATIONS - 1E power ELECTRICAL INSTALLATION SAFETY-RELATED HVAC - ELECTRICAL I&C DVPS VALIDATION OF CONTROL COMPONENTS INSTRUMENT INSTALLATION & SEPARATION CONTROL ROOM DESIGN BALANCE OF PLANT ANALOG CONTROL ACCIDENT MONITORING INSTRUMENTATION INTERFACE WITN NSSS SYSTEMS SAFETY-RELATED HVAC - I&C 4

0

' SVEC DESIGN VALT.DATION ACTIVITIES ARE DIVIDED INTO THE FOLLOWING DESIGN VALIDATION PACKAGES (DVPs) (CONTINUED)

MECNANICAL DVPs MANUAL AND motor OPenATED VALVES CONTAINMENT ISOLATION PIPING DESIGN CoMausTIsLE gas control AUXILIARY FasowATER CONTAINMENT SPRAY Fual Poot COOLING AND PURIFICATION BonoM RECYCLE REACTom COOLANT SAFETY INJECTION RESIDUAL HEAT REMOVAL

CNEMICAL & VOLUME CONTROL MAIN STF.AM/ STEAM DUMP FatowATER DItstL GENERATOR Furt OIL i

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O SWEC DESIGN VALIDATION ACTIVITIES ARE DIVIDED INTO THE FOLLOWING DESIGN VALIDATION PACKAGES (DVPs) (c0NTINUED) 1 .

- i MECNANICAL DVPs (CONTINUED) '

i COMPONENT COOLING WATER l SERVICE' WATER EMERGENCY DIESEL GENERATOR I CONTROL Room HAsITAsILITY >

DEMINERALIZED / REACTOR WATER MAKEUP RADIATIoM MONITORING EQUIPMENT Dost ANAL (sis .

SouRct TERM AND RAoIATIoM SNIELDING AccIoENT ANALYSIS SuscoMPARTMENT PRESSURIZATION CONTAINMENT LOCA/MSLB i  ;

CONTAINMENT fission PRooucT REMOVAL RAoIoAcTIVE WASTE SYSTEMS CNILLEn WATER i

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SUMMARY

STATUS I

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1 FouR PROJECT STATUS REPORTS (PSRS) WITH RESULTS FROM SWEC DESIGN VALIDATION ARE SCHEDULED FOR ISSUE IN JANUARY, 1988 i

POST CONSTRUCTION HARDWARE VALIDATION PROGRTM (PCHVP)

ACTIv! TIES ARE IN-PROCESS IN ALL SWEC DISCIPLINES AND ARE SCHEDULED FOR COMPLETION IN JULY, 1988. .

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CORRECTIVE ACTION PROGRAM (CAP)

CIVIL / STRUCTURAL-MECHANICAL-ELECTRICAL-I&C IDENTIFY LICENSING 4 - FSAR COMMITMENTS ,4

. OTHER LICENSING DOCUMENTS DEVELOP DESIGN 8 ASIS DOCUMENTS (OBO's)

Y p PERFORM DESIGN ] CPRT (DAP & QOC)

VAll0ATION ,

EXTERNAL ISSUES

. NRC (SRT, SIT, TRT, CAT)

CYGNA (IAP)

CASE f ASLB

. NRC INSPECTION REPORTS IS M00lFICATl0N YE' '

OESIGN U M001FICAT10NS Y~0 y POST CONSTRUCTION -

HARDWARE VAll0ATION q BMOMSPECT PROGRAM (PCHYP) M001 FICA T10N Y

FINAL DESl0N RECCNCILIATION IS YES ADDITIONAL VAll0AT10N REQUIRED

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yNo  !

i FINAL DOCUMENTATION (CESIGN VAll0 ATION P ACK AGES) 8 4

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CORRECTIVE ACTION PROGRAM  !

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l METHODOLOGY l

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1 0 IDENTIFICATION OF LICENSING COMMITMENTS l

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- 1 REVIEWED FSAR AND OTHER DESIGN LICENSING COMMITMENTS TO )

ESTABLISH BASES FOR VALIDATION OF THE DESIGN Ev0LVING REGULATORY REQUIREMENTS WILL BE RECONCILED WITH TH '

VALIDATED DESIGN AS REQUIRED l

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O DEVELOPMENT OF DESIGN BASIS DOCUMENTS (DBDS)

DEVELOPED A SET OF DESIGN BASIS DOCUMENTS W!lICH ARE USED GY THE ENGINEERS TO ASSURE COMP .NCE WITH THE LICENSING COMMITMENTS 1

DBDS COVER SAFETY-RELATED DESIGN REQUIREMENTS AND ARE l PROCEDURALLY CONTROLLED TO ASSURE CONSISTENT APPLICATION BY ENGINEERING DISCIPLINES j CONTROLLED DBDS FORM THE BASIS FOR VALIDATION OF THE DESIGN AND HARDWARE IN THE CORRECTIVE ACTION PROGRAM AND FOR DESIGN l CHANGES FOR THE LIFE OF THE PLANT DBDS DLSCRIBE THE ENGINEERING FUNCTIONAL REQUIREMENTS FOR SYSTEMS, STRUCTURES AND COMPONENTS TO ESTABLISH THE BASES  ;

FOR TESTING, OPERATING AND MAINTENANCE PROCEDURES ASSOCIATED l

WITH THE DESIGN '

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t 0 DESIGN VALIDATION COMPARED THE EXISTING DESIGN DOCUMENTATION (CALCULATIONS, DRAWINGS AND SPECIFICATIONS) TO THE DBDS.

ORIGINAL CALCULATIONS, DRAWINGS AND SPECIFICATIONS THAT ARE REQUIRED TO VALIDATE THE DESIGN HAVE BEEN DOCUMENTED BY SWEC TO BE ACCEPTABLE TO THE DBD'S OR MODIFIED AS REQUIRED.

WHEN THE ORIGINAL DOCUMENT FILE WAS FOUND TO BE INCOMPLETE OR NOT SUITABLE TO SATISFY THE DBD'S, NEW DESIGN DOCUMENTATION WAS PREPARED BY SWEC. ORIGINAL DOCUMENTS WERE-

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VOIDED WHERE APPROPRIATE.

INITIATED DESIGN MODIFICATIONS TO BRING THE STRUCTURES, SYSTEMS AND COMPONENTS INTO COMPLIANCE WITH THz DBD'S.

ENHANCED PROCEDURES TO CONTROL THE TECHNICAL INTERFACE l REQUIREMENTS BETWEEN VARIOUS ENGINEERING DISCIPLINES.

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O SWEC DESIGN VALIDATION RESULTS

SUMMARY

(C/S ELEC, I&C, MECH)

REVIEWED APPROXI.'?ATELY:

.. o 3000 ORIGINAL CALCULATIONS o 4200 DESIGN DRAWINGS o 150 SPECIFICATIONS DEVELOPED AND ISSUED APPROXIMATELY:

o 47 DESIGN BASIS U0CUMENTS o 1200 SWEC CALCULATIONS RESOLVED AND ISSUED CORRECTIVE ACTION AS REQUIRED FOR:

o DESIGN VALIDATION EFFORT o

OvER 1900 CPRT DISCREPANCY ISSUE REPORTS (DIRS) o OVER 80 DESIGN ISSUES FROM CPRT AND EXTERNAL SOURCES i

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SPECIFIC _ ISSUES l

O CORRECTIVE ACTION PROGRAM (CAP) PROVIDES ASSURANCE THAf THE VALIDATION RESOLVES DESIGN AND HARDWARE ISSUES IDENTIFIED BY CPRT AND* EXTERNAL SOURCES AS WELL AS ISSUES RAISED FROM THE VALIDATION ACTIVITIES THEMSELVES.

O THE PSR WILL ADDRESS THE DEFINITION OF EACH ISSUE AND THE RESOLUTION OF THE ISSUES AS REQUIRED BY CAP, INCLUDING BOTH CSRRECTIVE AND PREVENTIVE ACTION.  !

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O THE FOLLOWING LIST PROVIDES CAP ISSUES IDENTIFIED TO DATE THAT l

WILL BE INCLUDED IN THE PSRS. I i

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ISSUES IN PSR FROM CPRT AND EXTERNAL SOURCES t

CIVIL / STRUCTURAL 0 CONCRETE DESIGN-CONCRETE CONTAINMENT AND CONTAINMENT

.. MATERIAL o

CONCRETE DESIGN-REACTOR BUILDING INTERNAL STRUCTURES 0

CONCRETE DESIGN-FUEL BUILDING AND Furt POOLS o STEEL DESIGN METHODS AND CRITERIA 0 PIPE WHIP RESTRAINT SUPPORT o CONTAINMENT LINER AND ATTACHMENTS o SPENT FUEL POOL AND REFUELING POOL LINERS o

SUPPORTS / ANCHORAGE DESIGN METHODS AND CRITERIA o PENETRATION SLEEVES / ANCHORAGES o FUEL TRANSFER TUBE SUPPORTS o ANCHORAGE DESIGN METHODS AND CRITERIA 0 HEAVY LOAD DROP ANALYSIS o COMPUTER CODE BENCHMARKING o STRUCTURAL EMBEDMENTS o DESIGN BASIS CONFIRMATORY TEST PROGRAMS FOR EMBEDDED STEEL ANCHORS AND WELDS 0

AS-BUILT / FINAL LOAD VERIFICATION o

SEISMIC ANALYSIS OF CATEGORY I STRUCTURES o JET IMPINGEMENT SHIELD DESIGN AND JET IMPINGEMENT ON STRUCTURAL TARGETS i

o REINFORCING STEEL IN THE REACTOR CAVITY 0

CONCRETE COMPRESSION STRENGTH l

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l l 0 ISSUES IN PSR FROM CPRT AND EXTERNAL SOURCES (c0NTINUED)

CIVIL / STRUCTURAL (CONTINUED)

O MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES O

SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS  ;

O UNAUTHORIZED CUTTING OF REBAR IN THE FUEL HANDLING l

BUILDING '

O IMPROPER SHORTENING OF ANCHOR BOLTS IN STEAM GENERATOR UPPER LATERAL SUPPORTS 0 HILTI ANCHOR BOLT INSTALLATION l 0 RICHMOND INSERT ALLOWABLES 0 PR0x!MITY VIOLATIONS BETWEEN EMBEDDED P LATES , AND STRUCTURAL ANCHORAGES 0

THROUGH-BOLTS AND CONCRETE ACCEPTABILITY EMBEDDED PLATE DESIGN O POTENTIAL EDGE DISTANCE VIOLATION (PIPE SLEEVE PENETRATION)

O HILTI BOLTS ADJACENT TO THROUGH-BOLTS 0 INSTALLATION OF EXPANSION ANCHORS IN DIAMOND CORED HOLES 0 HILTI ANCHORS NEAR CONCRETE EDGES 0 SEISMIC CATEGORY I SUPPORT INTERACTION WITH SEISMIC CATEGORY II FIRE WALL 0 PR0XIMITY VIOLATIONS BETWEEN CABLE TRAY SUPPORTS AND OTHER COMPONENTS "15 t . . _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ .-__--__ - .

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l 0 l ISSUES IN PSR FROM CPRT AND EXTERNAL SOURCES (CONTINUED) '

ELECTRICAL -

o ELECTRICAL SEPARATION

. O ELECTRICAL CALCULATIONS o HEAT SHRINKABLE CABLE INSULATION SLEEVES o AMP PRE-INSULATED ENVIRONMENTAL SEALED (PIES) BUTT SPLICES o

AGREEMENT BETWEEN DRAWINGS AND FIELD TERMINATIONS o VENDOR INSTALLED AMP TERMINAL LUGS o

CONSTRUCTION REINSPECTION / DOCUMENTATION REVIEW PLAN o SYSTEM SHORT CIRCUIT CURRENTS o AC DISTRIsuTION SYSTEM VOLTAGES O OVERCURRENT PROTECTION o

POWER CAsLE DERATING INSIDE CONTAINMENT o VOLTAGE DROP CALCULATIONS o CABLE AMPACITY CALCULATIONS I&C O

INSTRUMENT SETPOINT CALCULATIONS o ELECTRICAL SEPARATION -

INADEQUATE SENSOR / TAP SEPARATION REQUIREMENTS O

INSTRUMENT EQUIPMENT INSTALLATION O

INSTRUMENT PRESSURE / TEMPERATURE RATINGS 0

FLOW TRANSMITTER / FLOW INDICATOR MISMATCH 0

INSTRUMENT TUBING INSTALLATION O INSTRUMENT DATA SHEET INCONSISTENT WITH CALIBRATION CARD i

0 INSTRUMENT CALIBRATION CARDS DISAGREE WITH SETPOINT  !

CALCULATIONS

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ISSUES IN PSR FROM CPRT AND EXTERNAL SOURCES (CONTINUED)

MECHANICAL -

0 SEISMIC QUALIFICATION OF SEISMIC CATEGORY I 80P EQUIPMENT AND COMPONENTS O HIGH ENERGY LINE BREAKS O OVERPRESSURE PROTECTION OF SAFETY-RELATED PIPING AND EQUIPMENT 0 SPECIFICATION OF MECHANICAL COMPONENTS 0

DETERMINATION OF HEAT LOADS FOR HVAC EQUIPMENT SIZING 0 FIRE PROTECTION O CONTROL OF WELDING PROCESSES j 0 INTERNAL AND TURBINE MISSILE EVALUATIONS O SYSTEM DESIGN O LARGE BORE PIPING CONFIGURATION '

O SMALL BORE PIPING CONFIGURATION O PIPING BEND FABRICATION  ;

O PIPE WELDS / MATERIAL 0 MECHANICAL EQUIPMENT INSTALLATION O CCW SYSTEM MAXIMUM TEMPERATURE I

O CCW SURGE TANK ISOLATION OF HIGH RADIATION SIGNAL l

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O ISSUES IN PSR FROM CPRT AND EXTERNAL SOURCES (CONTINUED) l

. l MECHANICAL (CONTINUED) o SINGLE FAILURE-RCP THERMAL BARRIER s

o MISSING VALVE SIZING CALCULATIONS o

CCW SURGE TANK SIZING AND DESIGN BASIS o CCW PUMP motor SIZING o CCW SURGE TANK VENT / RELIEF o CCW VALVES HV-4572 AND HV-4573 PARTIAL OPEN POSITION SETPOINT CALCULATION I O

MECHANICAL Ecu!PMENT SEPARATION CRITERIA o

CCW PUMP DISCHARGE PRESSURE SWITCH SETPOINT BASIS l o CCW VALVES HV-4572 AND HV-4574 INLET PRESSURE AND  !

SHUT 0FF DIFFERENTIAL PRESSURE i

o FLOW BALANCING ORIFICE SIZING DATA TRANSFER o SSER 10 REVIEW 1

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,,_e.,-..-,__y -.-. _ _ _ . , - - , , - - , , - , - _ - - - . , , - - _ - , , _ _ _ , , . , , , --_ _ , _ _ _ - . , _ _ . _ - , , . .,--_.--,_.-,-,,_.,v-i ,

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ISSUES IN PSR FROM DESIGN VALIDATION CIVIL / STRUCTURAL o SDAR CP-87-131, SUsCoMPARTMCNT EFFECTS o SDAR CP-87-120, TORNADO MISSILE BARRIERS o SDAR CP-87-127, SEISMIC CATEGORY I STRUCTURAL l

STEEL PLATFORMS AND SUPPORT STRUCTURES '

o SDAR CP-87-115, MoDELING ERROR IN SEISMIC ANALYSIS FoR SERVICE WATER INTAKE STRUCTURE o SDAR CP-87-83, SERVICE WATER DISCHARGE STRUCTURE ANALYSIS l

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ISSUES IN PSR FROM DESIGN VALIDATION (CONTINUED)

ELECTRICAL .

o SDAR CP-87-03, 6.9 KV SWITCHGEAR INSTALLATION o SDAR CP-87-40, ELECTRICAL ISOLATION BETWEEN CLASS 1E AND NON-class IE EcuIPMENT o SDAR CP-87-51, 480 V CONTAINMENT ELECTRICAL PENETRATION BACKUP PROTECTION o SDAR CP-87-79, CABLE AND RACEWAY DATA SYSTEMS (CARDS)

CALCULt.TIONS o SDAR CP-87-94, UNINTERRUPTI8LE POWER SUPPLY LOADING o SDAR CP-87-101, CtAss 1E caste ARRANGEMENT "20

O ISSUES IN PSR FROM DESIGN VALIDATION (CONTINUED)

I&C

. o SDAR CP-87-44, UNIsTRur TUBING SUPPORT BOLTING o SDAR CP-87-128, MONITORING FoR Loss or CONTROL power o SDAR CP-87-110, IN09 ERA 8LE SAFEGUARDS SEQUENCER RELAY 1

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0 ISSUES IN PSR FROM DESIGN VALIDATION (CONTINUED)

MECNANICAL ,

o SDAR CP-87-101, OPERATIONS DESIGN MODIFICATION CONTROL o SDAR CP-87-015, AIR ACCUMULATORS FOR CONTROL VALVES o SDAR CP-87-025, DG FUEL OIL TANK VENT MISSILE PROTECTION L

o SDAR CP-87-050, TURBINE DRIVEN AUXILIARY FEEDWATER PUMP t

BEARING TEMPERATURE o SDAR CP-87-064, DESIGN 8 ASIS TORNADO ANALYSIS o SDAR CP-87-090, RESIDUAL HEAT REMOVAL RELIEF VALVE PIPING o SDAR CP-87-103, CRACKED GEARS IN VALVE OPERATORS l

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o SDAR CP-87-129, CONTAINMENT SPRAY SYSTEM PH o SDAR CP-87-130, SERVICE WATER SYSTEM WATER HAMMER i

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SYSTEMS INTERACTION

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CORRECTIVE ACTION PROGRAM (CAP) '

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- 1 SYSTEMS INTERACTION PROGRAM (SIP)

THE SYSTEMS INTERACTION PROGRAM INCLUDES IDENTIFICATION AND PROTECTION OF ESSENTIAL SYSTEMS, STRUCTURES AND COMPONENTS FROM THE UNACCEPTABLE INTERACTIONS RESULTING FROM THE FOLLOWING POSTULATED EVENTS:

0 BREAKS IN HIGH ENERGY AND MODERATE ENERGY PIPING SYSTEMS 0 FLOODING AND ENVIRONMENTAL EFFECTS IN SEISMIC CATEGORY I I STRUCTURES OUTSIDE CONTAIMMENT j 0 INTERNALLY GENERATED MISSILES (ROTATING . EQUIPMENT l COMPONENTS, VALVES ON HIGH ENERGY LINES, ETC.)

0 EFFECTS FROM A POSTULATED SAFE SHUTDOWN EARTHQUAKE (SSE) ON NON-SEISMIC SYSTEMS', STRUCTURES AND COMPONENTS WHICH MAY EFFECT SAFETY RELATED SYSTEMS AND COMPONENTS THE OBJECTIVE OF THE SYSTEM INTERACTION PROGRAM PORTION OF THE CORRECTIVE ACTION PROG RAM IS TO ASSURE THAT THE POSTULATED EVENTS CANNOT PREVENT SAFE SHUTDOWN OF THE REACTOR NOR PREVENT MITIGATION OF THE CONSEQUENCES OF THE EVENT.

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CORRECTIVE ACTION PROGRAM (CA'N SYSTEMS INTERACTION IDENTIFY LICENSING 4 FSAR COMMITMENTS 4 OTHER LICENSING I g' DOCUMENTS y .

DEVELOP DESIGN BASIS DOCUMENTS (DBD'S)

M PERFORM DESIGN 4 CPRT (DAP & 00C)

VALIDATION 4 EXTERNAL ISSUES NRC (SRT, SIT TRT, CAT)

CYGNA (IAP)

CASE f ASLB j NRC INSPECT 10N REPORTS

^

IS MODIFICATION YES - DESIGN REQUIRED MODIFICATIONS

?

  • Y"o y POST CONSTRUCTION

, 3p HARDWARE VALIDATION ,

p PROGRAM (PCHVP) l Y

FINAL DESIGN RECONCILIATION lf is YES 7 ADDITIONAL VALIDATION REQUIRED 7

y NO ,

FINAL DOCUMENTATION (DESIGN VAllD ATION P ACK AGES) 3 l

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1 LICENSING COMMITMENTS SYSTEMS INTERACTION LICENSING COMMITMENTS IDENTIFIED THROUGH AN EXTENSIVE REVIEW OF CPSES LICENSING DOCUMENTS WHICH INCLUDE:

0 FSAR 0 REGULATORY GUIDES '

0 SAFETY EVALUATION REPORT (SER) AND ITS SUPPLEMENTS 0 TU ELECTRIC /NRC CORRESPONDENCE APPROXIMATELY 88 LICENSING COMMITMENTS RELATED TO SYSTEMS INTERACTION PROGRAM WERE IDENTIFIED l

4

DESIGN BASIS DOCUMENTS DESIGN BASIS ESTABLISHED FROM COMMITMENTS AND DETAILED IN THE f

DESIGN BASIS DOCUMENTS (DBD 'S) '

DBD'S IDENTIFY DESIGN BASIS ESTABLISHED FOR THE DESIGN VALIDATION PROGRAM 3

SYSTEMS INTERACTION DESIGN BASIS DETAILED IN THREE DBD'S s j DBD-ME-005 SEISMIC /NoN-SEISMIC INTERACTION PROGRAM

. I DBD-ME-007 PIPE BREAK PoSTutATIoN AND EFFECTS l D20-ME-105 MISSILE POSTULATION AND EFFECTS l t

5

l' DESIGN VALIDATION PROCESS THE EBASCO SYSTEMS INTERACTION DESIGN VALIDATION PROCESS VALIDATES THAT THE DESIGN OF SYSTEMS, STRUCTURES AND COMPONENTS COMPLIES WITH THE DESIGN BASIS AND PROVIDES ASSURANCE THAT THE ESSENTIAL SYSTEMS, STRUCTURES AND COMPONENTS WILL CONTINUE TO PERFORM THEIR ESSENTIAL FUNCTIONS WHEN SUBJECTED TO SYSTEMS INTERACTIONS RESULTING FROM:

0 PIPE RUPTURE, INCLUDING HELB, MELB, ENVIRONMENTAL AND FLOODING EFFECTS O INTERNALLY GENERATED MISSILES O SAFE SHUTDOWN EARTHQUAKE (SSE)

VALIDATION PROCESS INCLUDES:

0 IDENTIFICATION OF POTENTIAL TARGETS 0 IDENTIFICATION OF INTERACTIONS 0 DETERMINATION IF DESIGN MEETS DESIGN BASIS 0 IF NOT, DEVELOPMENT OF MODIFICATIONS TO MEET DESIGN BASIS 6

DESIGN VALIDATION PROCESS (CONTINUED)

DESIGN VALIDATION IS PERFORMED BY:

0 UTILIZING EVENT DIAGRAMS (FAULT TREE DIAGRAMS) DEVELOPED TO INDICATE SYSTEMS AND COMPONENTS REQUIRED FOR SAFE SHUTDOWN >

OF REACTOR AND TO ALLEVIATE THE CONSEQUENCES OF POSTULATED EVENTS /

0 DEVELOPMENT OF CALCULATIONS TO SHOW BROKEN PIPE MOVEMENT (PIPE WHIP)AND RESULTING FLUID JET IMPINGEMENT ZONES OF INFLUENCE 0 DEVELOPMENT OF CALCULATIONS TO SHOW ENVIRONMENTAL AND FLOODING EFFECTS RESULTING FROM POSTULATED PIPE BREAKS 0

DEVELOPMENT OF CALCULATIONS TO ESTIMATE THE FAILURE ZONE FOR NONSEISMICALLY SUPPORTED COMPONENTS. THIS ZONE DEFINES MAXIMUM RANGE THE COMPONENT CAN TRAVERSE WHEN DISLODGED DURING SEISMIC EVENT (SSE).

7 1

- - - , . - , - -,n . -,.,--,,-,,.-,---,-.-,--,---~-..,,,,_,,c.. - - - - - - , . - , - - - - - - , - - , - - - - - - , , - - . - - - - - , ,.,----,--,-,,---,,,---,,,--.n--

. l SPECIFIC ISSUES '

w A NUMBER OF EXTERNAL SOURCE ISSUES RELATING TO THE SYSTEMS INTERACTION PROGRAM WERE IDENTIFIED BY THE COMANCHE PEAK RESPONSE TEAM (CPRT).

THESE INCLUDE THE FOLLOWING:

0 HIGH ENERGY LINE BREAK PROTECTION ISSUES JET IMPINGEMENT LOADS AND AREA PROJECTIONS -

PIPE WHIP ZONES OF INFLUENCE SAFETY-RELATED, TARGET IDENTIFICATION 0 MISSILE HAZARDS 0 SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS 0 FIRE PROTECTION SYSTEMS INTERACTION SEISMIC QUALIFICATION OF DELUGE VALVES DIESEL GENERATOR ROOM SPRAY SHIELDS SEISMIC SUPPORTING OF FIRE PROTECTION PIPING IN DIESEL GENERATOR ROOMS 8

1 SPECIFIC ISSUES (CONTINUED)

IN ADDITION, THERE WERE ISSUES DETERMINED TO BE REPORTABLE UNDER THE PROVISION OF 10 CFR 50.55(E) WHICH WERE IDENTIFIED DURING THE IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM. THESE WERE RELATED TO THE COMPUTER MoDELING ERRORS WHICH MAY HAVE RESULTED IN  !

MISCALCULATION OF LOADS ON PIPE WHIP RESTRAINTS AND ENVIRONMENTAL CONDITIONS DUE To HELB. '

l TECHNICAL REVIEWS, RESOLUTION AND CORRECTIVE AND PREVENTIVE ACTION FOR l THE ABOVE ISSUES WILL BE PRESENTED IN THE SUPPLEMENT A TO THE l

MECHANICAL PSR WHICH REPORTS THE SIP PORTION OF THE CAP.

l I

1 9

Wl i

1 I

i f

I FIRE PROTECTION CORRECTIVE ACTION PROGRAM (CAP) e d 0 1

l

-- -. _ - . _ _ _ _ . __ _ . . _ . _ -, ._ . - . - . - -__..,._m_ . _ . , , , - . , , , , , _ , , , _ . _ _ ,__,, -_ _ _ _ _ _ . . _ . . , . - , . , . - , , - . - - - _ - _ _ _ _ .

FIRE PROTECTION O THE OBJECTIVE OF THE FIRE PROTECTION PROGRAM IS TO DEMONSTRATE THAT THE INSTALLED FIRE PROTECTION SYSTEMS, STRUCTURES AND COMPONENTS COMPLY WITH THE LICENSING COMMITMENTS AND WILL PERFOR THEIR DESIGNED FUNCTIONS.

2

CORRECTIVE ACTION PROGRAM (CAP)

. FIRE PROTECTION

\

IDENTIFY LICENSING G FSAR COMMITMENTS 4 OTHER LICENSING DOCUMENTS DEVELOP DESIGN BASIS DOCUMENTS (DSD'S)

Y PERFORM DESIGN 4 CPRT (DAP & QOC)

VAll0ATION 4 EXTERNAL ISSUES NRC (SRT, SIT, TRT, CAT)

- CYGNA (!AP)

CASE l ASL5 NRC INSPECTION REPORTS MODIFICATION VER y DESIGN REQUIRED MODIFICATIONS

?

Y" If POST CONSTRUCTION HARDWARE VALIDATION 4 p PROGRAM (PCHYP) lf FINAL DESIGN RECONCILIATION If IS YES ADDITIONAL VALIDATION REQUIRED, l f NO ,

FINAL DOCUMENTATION (DESIGN VAllD AT10N PACK AGES)

l l

\

IDENTIFICATION OF LICENSING COM4ITNENTS

~

O FIRE PROTECTION LICENSING COMMITMENT IDENTIFIED THROUGH EXTENSIVE REVIEW OF CPSES LICENSING DOCUMENTS i i

FSAR l

SER AND ITS SUPPLEMENTS NRC REGULATORY GUIDES TU ELECTRIC /NRC CORRESPONDEMCE O APPROXIMATELY 600 FIRE PROTECTION LICENSING COMMITMENTS IDENTIFIED 0

COMMITMENTS TO THE REQUIREMENTS OF BTP-APCSB 9.5-1 APPENDIX A 0

ADDITIONAL COMMITMENTS FOR COMPARISON OF SECTIONS OF THE PROGRAM TO 10CFR 50 APPENDIX R (CURRENT DAY FIRE PROTECTION METHODOLOGY AND CRITERIA) i FIRE PROTECTION FEATURES SAFE SHUTDOWN CAPABILITY SEPA.*A72DM C7'TERIA ALTERNATIVE AND DEDICATED SHUTDr :4 CW r 74 .

EMERGENCY LIGHTING COMMUNICATIONS t

4 w _ _ - -- -- . . - - . -

DEVELOPMENT OF DESIGN BASIS DOCUMENTS O

DESIGN BASIS WAS ESTABLISHED FROM COMMITMENTS AND CONSOLIDATED IN TNE DESIGN BASIS DOCUMENTS (DBDS) 0 DBDS IDENTIFIED THE DESIGN BASIS FOR DESIGN VALIDATION EFFORT 0 FIRE PROTECTION DESIGN BASIS CONSOLIDATED IN SIx DBDS DBD-ME-001 FIRE PAZARDS ANALYSIS DBD-ME-002 PENETRATION SEALS DBD-ME-020 FIRE SAFE SNUTDOWN ANALYSIS DBD-ME-063 FIRE BARRIERS DBD-ME-104 FIRE DETECTION SYSTEM ,

DBD-ME-225 FIRE SUPPRESSION SYSTEM 0 DESIGN AND DESIGN CONTROL PROCEDURES WERE ENNANCED TO IMPLEMENT TNE DESIGN BASIS DEFINED IN TNE DBD'S 0 PROCEDURES ENCOMPASS THE FOLLOWING:

DESIGN BASIS '

RESOLUTION OF CPRT ISSUES INDUSTRY EXPERIENCE REGULATORY AND PROFESSIONAL SOCIETY OUIDANCE (APPLICABLE CODES AND STANDARDS) 4 5

i i

DESIGN VALIDATION  ;

l i

0 DEMONSTRATES THAT THE FIRE PROTECTION DESIGN OF SYSTEMS,  !

STRUCTURES AND COMPONENTS COMPLIES WITH LICENSING COMMITMENTS, j SATISFIES THE DESIGN BASIS AND WILL SATISFACTORILY PERFORM THE DESIGN FUNCTIONS 0 DESIGN VALIDATION PERFORMED BY THE FOLLOWING METHODS:

REVIEW OF ORIGINAL CALCULATIONS AND DRAWINGS l REVIEW OF FIRE TEST REPORTS PERFORMANCE OF ENGINEERING WALKDOWNS GENERATION OF ADDITIONAL DRAWINGS AND CALCULATIONS 0 FIRE PROTECTION FEATURES VALIDATED INCLUDE:

FIRE BARRIERS FIRE SUPPRESSION SYSTEM FIRE DETECTION SYSTEM COMMUNICATION SYSTEM EMERGENCY LIGHTING SYSTEM 0 FIRE PROTECTION ANALYSES VALIDATED INCLUDE:

FIRE HAZARDS ANALYSIS (FHA)

FIRE SAFE SHUTDOWN ANALYSIS (FSSA) 0 SIx DESIGN VALIDATION PACKAGES DEVELOPED FOR FIRE PROTECTION:

DVP-FP1 FIRE HAZARDS ANALYSIS DVP-FP2 PENETRATION SEALS DVP-FP3 FIRE SAFE SHUTDOWN ANALYSIS DVP-FP4 FIRE BARRIERS DVP-FP5 FIRE SUPPRESSION DVP-FP6 FIRE DETECTION 6

SPECIFIC ISSUES l

1 1

0 CORRECTIVE ACTION PROGRAM PRoVIDES ASSURANCE THAT THE VALIDATION RESOLVES DESIGN AND HARDWARE ISSUES IDENTIFIED BY CPRT, EXTERNAL sources AND CAP CPRT ISSutS wERE RESOLVED THRouGH RESOLUTION oF DIR ISSUES INCLUDING:

o FIRE EXIT ROUTES o FLAME SPREAD oF INTERIOR FINISHES o FIRE DAMPER TESTING o EIGHT Hour EMERGENCY LIGHTING UNITS o FIRE PROTECTION SYSTEMS INTERACTION o FIRE SAFE SHUTDOWN / ALTERNATE SHUTDOWN o WORK IN PROGRESS 0 hAC AUDIT oF CPSES FIRE PROTECTION PROGRAM CONDUCTED OcTosER 19 - 23, 1987 -

No DEVIATIONS oR VIOLATIONS IDENTIFIED IN THE CPSES FIRE PROTECTION PROGRAM 7

l

e4>

e e

e e *

+

9

.l EQUIPMENT QUALIFICATION CORRECTIVE ACTION PROGRAM (CAP) 1

l 1

EQUIPMENT QUALIFICATION l

=

e

  • 0 THE OBJECTIVE OF THE . EQUIPMENT QUALIFICATION PROGRAM IS TO DENONSTRATE THAT THE INSTALLED EQyIPMENT IS ARLE TO PERFORM ITS REQUIRED FUNCTION IN ACCORDANCE WITH THE LICENSING COMMITMENTS UNDER THE FOLLOWING CONDITIONS:

NORMAL SESVICE ENVIRONMENTS POSTULATED SEISMIC EVENTS ENVIRONMENTS CAUSED BY POSTULATED ACCIDENT EVENTS 4

)

4 k

l 1

j 2

CORRECTIVE ACTION PROGRAM (CAP)  !

EQUIPMENT QUALIFICATION 10ENTIFY LICENSING E8AR COMMITMENTS OTHER LICENSING DOCUMENTS lI DEVELOP DESIGN BASIS 00CUMENTS (080s) -

t U PERFORM DEslGN < CPRT (OAP & QOC)

~

VAll0ATION < EXTERNAL ISSUES NRC (SRT. SIT. TRT, C AT)

CVONA (IAP)

CASE lf ASLS NRC INSPECTION REPORTS IS MOOlFICATION

% DESIGN REQUIRED MODIFICATION

?

No If

~

POST CONSTRUCTION HARDWARE VALID ATiON D PROGR AM (PCHVP) M00lFICATIONS FINAL DESIGN .

RECONCILIATION lt YES VALIOATION EQUIRE NO ,

i 5

FINAL DOCUMENTATION (CESION VAll0 ATION PACK AGES) 3

IDENTIFICATION OF LICENSING COMITNENTS O EQUIPMENT QUALIFICATION LICENSING COMMITMENTS IDENTIFIED THROUGN AN EXTENSIVE REVIEW OF CPSES LICENSING DOCUMENTS.

FINAL SAFETY ANALYSIS REPORT (FSAR)  ;

' SAFETY EVALUATIONS AND SUPPLEMENT (SER'S & SSER'S)  :

I TU ELECTRIC /NRC CORRESPONDENCE NRC REGULATORY GUIDES O APPROXIMATELY 250 EQUIPMENT ,UALIFICATION Q LICENSING COMMITMENT IDENTIFIED.  !

i 0 INCORPORATION OF CURRENT DAY EQUIPMENT QUALIFICATION METHODOLOGY AND BASIS.

j

{

INDUSTRY CODES & STANDARDS APPLICABLE INDUSTRY EQUIPMENT QUALIFICATION EVENT REPORTS 4

1

\

i DEVELOPMENT OF DESIGN BASIS DOCUMENTS O

ASSEMBLE 'ICENSING COMNITMENTS AND QUALIFICATION BASIS INTO I DESIGN VALIDATION AREAS.

l SEISMIC EQUIPMENT QUALIFICATION

- l ENVIRONMENTAL EQUIPMENT QUALIFICATIed l

0 ASSEMBLE CPSES PLANT SPECIFIC DATA TO DEFINE QUALIFICATION PARAMETERS.

PRESSURE -

RADIATION TEMPERATURE -

FLOODING NUMIDITY -

SPRAY 0 EQUIPMENT QUALIFICATION DESIGN BASIS CONSOLIDATED IN FOUR I DBD'S.

DBD-ME-029 SEISMIC QUAL. OF EQUIP.

DBD-EE-030 ENVIR. QUAL.,0F SAFETY RELATED MECN. EQUIP.

DBD-EE-031 ENVIR. QUAL. OF SAFETY RELATED ELECT, EQUIP.

1 DBD-ME-076 POSTULATED ENVIR. FOR EQUIP. QUAL.

5

DEVELOPMENT UF DESIGN BASIS DOCUMENTS (CONT.)

O ENHANCE THE PROCEDURES TO INCLUDE ADDED DESIGN AND DESIGN CONTROL PROCEDURES TO IMPLEMENT THE 080 DESIGN BASIS.

DESIGN BASIS RESOLUTION OF CPRT ISSUES INDUSTRY EXPERIENCE 1

REGULATORY & PROFESSIONAL SOCIETY GUIDANCE i

. ~ . .

9 l

l 1

1 6

i' DESIGk VALIDATION O VALIDATE THAT THE EQUIPMENT'S SAFETY RELATED FUNCTION FOR ALL EQUIPMENT REQUIRING QUALIFICATION IS NOT IMPAIRED BY THE SEISMIC AND/OR ENVIRONMENTAL CONDITION TO WHICH TH2Y MAY BE SUBJ ECTED.

O DESIGN VALIDATION BY THd C0i4PLETION OF:

DEVELOPMENT OF THE EQUIPMENT QUALIFICATION MASTER LIST (E0ML)

ESTABLISHMENT OF ENVIRONMENTAL QUALIFICATION RECORDS AND '

DOCUMENTATION ESTABLISHMENT OF SEISMIC QUALIFICATION RECORDS AND DOCUMENTATION 4

0 7

i i

i I

1 DESIGN VALIDATION (CONT'D)

O EQUIPMENT GUAL1'ICATION MASTER L*lST (E0ML) INCLUDED:

SYSTEM IDENTIFICATION TNROUGN TNE EONL sASIS REPORT DEVELOPMENT OF EQML DESIGNt& DESIGN CONTROL PROCEDURES SYSTEMATIC CPSES DESIGN DOCUMENT REVIEW AND IDENTIF.ICATION OF APPR0XIMATELY 17000- COMPONENT AND Sus-COMPONENTS

, . . . 4: . ... .ss;s CONTROLLED LISTING OF EQUIPMENT REQUIRING QUALIFICATION INCLUDING: .

.e, .. w- .- -

0 SPECIFICATION O PLANT LOCATION O SYSTEM -s- 0i.. MFG. Si MtMr.' NO O COMPONENT TYPE O FUNCTIONAL- CAT.

l .

8 i

l

DESIGN VALIDATION (CONT'D)

O ENVIRONMENTAL EQUIA'4ENT QUALIFICATION INCLUDED:

ASSEMsLE AND, REVIEW APPROXIMATELY 100 EXISTING QUALIFICATION RECORDS FILES AND TEST DOCUMENTATION SEGREGATE EQUIPMENT INTO ENVIRONMENTAL CATEGORIES TO INCLUDE:

O CLASS 1E EQuxpMENT LOCATED IN A HARSH ENVIRONMENT 0 CJ. ASS, :1E (QuinME,NT LOCATED IN A MILD ENVIRONMENT O ACTIVE SAFETY RELATED MECHANICAL EQUIPMENT LOCATED IN A HEASH EN.VIRONMENT

)

DEVELOP .APPROXIMATELY 150 COMPREHENSIVE ENVIRONMENTAL QUALIFICATION PACKAGES THAT VALIDATE THE ENVIRONMENTAL l QUALIFICATION OF EQUIPMENT IDENTIFY ALL MAINTENANCE REQUIREMENTS WECESSARY TO MAINTAIN THE QUALIFICATION STATUS l

j .

l 9 i

DESIGN VALIDATION (CONT'D)

O SEISMIC EQUIPMENT QUALIFICATION INCLUDED:

ASSEMELE AND REVIEW APPROXIMATELY 150 EXISTING QUALIFICATION SPECIFICATION FILES AND QUALIFICATION l DOCUMENTATION DEVELOP APPR0XIMATELY 500 SEISMIC CATEGORY I QUALIFICATION PACKAGES THAT VALIDATE THE SEISMIC QUALIFICATIGN OF EQUIPMENT UPDATE SEISMIC DESIGN SPECIFICATION FOR INCLUSION INTO PROCUREMENT SPECIFICATION '

O THREE DE3IGN ' VALIDATION PACKAGES DEVELOPED FOR EQUIPMENT QUALIFICATI0K:

. ~

EQ-1 EQUIP. QUAL. MASTER I.IST (EQMU EQ-2 ENVIR. EQUIP. QUAL.

EQ-3 SEISMIC EQu!P. QUAL.

10

l' l

' SPECIFIC ISSUES O CORRECTIVE ACTION PROGRAM PROVIDES ASSURANCE THAT THE VALIDATION RESOLVES DESIGN AND HARDWARE ISSUES IDENTIFIED BY CPRT AND CAP.

CPRT ISSUES wERE RESOLVED THROUGH RESOLUTION OF DIR ISSUES INCLUDING:

O IDENTIFICATION AND CLASSIFICATION ,

O ENVIRONMENTAL CONDITIONS AND REQUIREMENTS o ENVIRONMENiAL DOCUMENTATION l

i 0 SEISHIC DOCUMENTATION

. O GENERIC REGULATORY CONC'kRNS O MAINTENANCE AND SURVEILLANCE l

! O CAaLE SLACK AND FLEXIBLE CONDUIT .

9 11 4

l

. l l

1 SPECIFIC ISSUES

. , (CONTINUED) l ISSUES IDENTIFIED DURING THE PERFORMANCE OF THE DESIGN VALIDATION THAT ,ARE CURRENTLY BEING EVALUATED FOR POTENTIAL REPORTABILITY UNDER THE PROVISIONS OF 10CFR50.55(E) INCLUDE:

0 FAN COIL UNIT N0ZZLE LOAD EVALUATION 0 HEAT EXCHANGER SUPPORT STRUCTURE & MID-LUG MODIFICATION .

O LUBE OIL UNIT PRESSURE STRAINER CLIP ANGLE MODIFICATION 0 LIMITORouE ACTUATORS l

1 I

i '12 i

f

/'

l 1

l l

HEATING, VENTILATION & AIR CONDITIONING (HVAC) i O SYSTEM VALIDATION  !

I O STRUCTURAL VALIDATION CORRECTIVE CTION PROGRAM i

)

1 i

i l

' I 1  !

I  !

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM i

THE OBJECTIVE OE THE CORRECTIVE ACTION PROGRAM IMPLEMENTED BY EBA'SCO ON HVAC STRUCTURAL COMPONENTS, AND HVAC SYSTEMS IS TO:

0 DEMONSTRATE THAT THE DESIGN OF HVAC STRUCTURAL COMPONENTS ,

AND HVAC SYSTEMS COMPLY WITH THE LICENSING COMMITMENTS, AND 0 DEMONSTRATE THAT EXISTING HVAC STRUCTURAL COMPONENTS AND HVAC SYSTEMS COMPLY WITH THE DESIGN, OR DEVELOP

)

MODIFICATIONS NECESSARY TO BRING THEM INTO COMPLIANCE WITH DESIGN.

l l

i I

i I

l 2

- - - - . - - -- - _ _A

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM (CAP)

IDENTIFY LICENSING 4 FSAR

,, COMMITMENTS C OTHER LICENSING mir DOCUMENTS y .

DEVELOP DESIGN BASIS

_ DOCUMENTS (DBD'S)

PERFORM DESIGN 4 CPRT (DAP & QOC)

VALIDATION 4 EXTERNAL ISSUES NRC (SRT, SIT. TRT. CAT)

CYGNA (IAP)

CASE lI ASLB NRC INSPECTION REPORTS IS MODIFICATION VES p DESIGN REQUIRED MODIFICATIONS

?

I f POST CONSTRUCTION HARDWARE VALIDATION 4 BUILD / INSPECT PROGR AM (PCHYP)

,p, ,g l

Y FINAL DESIGN RECONCILIATION lf IS i

YES ADDITl0NAL l VALIDATION l REQUIRED

\

i f NO FINAL DOCUMENTATION I (DESIGN VAllDATION PACK AGES) t 3 '

I l

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM 0 LICENSING COMMITMENTS THE LICENSING COMMITMENTS FOR THE HVAC STRUCTURAL COMPONE AND HVAC SYSTEMS WERE IDENTIFIED THROUGH AN EXTENSIVE REVI OF CPSES LICENSING DOCUMENTS, WHICH INCLUDED:

0 FSAR 0

SAFETY EVALUATION REPORT (SER) AND ITS SUPPLEMENTS 0 NRC REGULATORY GUIDES 0

NRC/TU ELECTRIC CORRESPONDENCE.

4

V HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM 0 DESIGN BASIS DOCUMENTS (DBD'S)

IDENTIFIED LICENSING COMMITMENTS FORMED THE BASIS FOR THE ESTABLISHMENT OF A SET OF DESIGN BASIS DOCUMENTS WHICH WERE DEVELOPED FOR HVAC STRUCTURAL COMPONENT AND HVAC SYSTEM DESIGN VALIDATION TO ASSURE COMPLIANCE WITH THE LICENSING COMMITMENTS.

ONE DBD FOR HVAC STRUCTURAL COMPONENT DESIGN VALIDATION, AND ONE EACH DBD FOR THE VALIDATION OF FOURTEEN HVAC SYSTEMS WERE DEVELOPED.

DETAILED DESIGN VALIDATION PROCEDURES WERE ALSO DEVELOPED FOR THE IMPLEMENVATION OF THE DESIGN BASIS IN THE DESIGN VALIDATION. THESE PROCEDURES INCORPO RATE THE CPRT AND EXTERNAL ISSUE RESOLUTION RESULTS, REGULATORY AND PROFESSIONAL SOCIETY GUIDANCE, INDUSTRY EXPERIENCE AND THE RESULTS OF NUMEROUS ENGINEERING STUDIES AND TESTS PERFORMED TO FORM THE BASIS FOR THE DESIGN VALIDATION PROCEDURES.

5

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM 0 DESIGN VALIDATION HVAC SYSTEMS AND HVAC STRUCTURAL COMPONENT DESIGNS ARE VALIDATED TO DEMONSTRATE CONFORMANCE TO THE DESIGN BASIS REQUIREMENTS.

HVAC SYSTEMS DESIGNS ARE VALIDATED BY THE COMPLETION OF THE AS-BUILT HEAT LOAD CALCULATIONS, AND REVIEW OF THE TECHNICAL PERFORMANCE OF HVAC EQuIsaENT TO ASSURE THAT THE INDOOR AMBIENT ENVIRONMENTAL CONDITIONS COMMITTED TO IN LICENSING DOCUMENTS ARE MET.

HVAC STRUCTURAL COMPONENT DESIGNS WHICH INCLUDE DUCTS, DUCT SUPPORTS, AIR HANDLING UNITS, PLENUMS AND EQUIPMENT SUPPORTS ARE VALIDATED TO DEMONSTRATE THE CONFORMANCE OF THE INSTALLED CONFIGURATIONS TO THE DESIGN BASIS REQUIREMENTS:

0 AS-BUILT DRAWINGS FOR DUCTS AND DUCT SUPPORTS 0

DETAILED STRUCTURAL SYSTEM ANALYSES HVAC SYSTEMS AND HVAC STRUCTURAL COMPONENTS NOT IN CONFORMANCE WITH THE DESIGN ARE IDENTIFIED AND DESIGN CHANGES ARE BEING IMPLEMENTED.

s 6

h HVAC DUCT / SUPPORT AND SYSTEMS ,

CORRECTIVE ACTION PROGRAM i

SCOPE i

0 14 HVAC SYSTEMS BEING DESIGNED VALIDATED '

b 0 APPR0x, 4000 SEISMIC CATEGORY I AND II DUCT SUPPORTS l WERE AS-BUILT AND ARE BEING DESIGN VALIDATED i

0 APPROX, 3900 DUCT SEGMENTS WERE AS-BUILT AND ARE {

BEING DESIGN VALIDATED.

O APPROX, 90 AHU'S, PLENUMS AND EcuIPMENT SUPPORTS '

ARE BEING AS-BUILT AND DESIGN VALIDATED. I i

i l

I 1

i i

. l 7

i

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM SPECIFIC ISSUES A NUMBER OF EXTERNAL SOURCE ISSUES RELATING TO THE HVAC SYSTEMS AND HVAC STRUCTURAL COMPONENTS WERE IDENTIFIED BY .HE CPRT, NRC CONSTRUCTION APPRAISAL AND NRC TECHNICAL REVIEW TEAMS, AND CASE.

THESE INCLUDE THE FOLLOWING:

0 DETERMINATION OF HEAT LOADS FOR EQUIPMENT SIZES 0 LACK OF CONSTRUCTION DETAILS FOR FABRICATION AND INSTALLATION OF DUCTS AND PLENUMS 0

INCORRECT HVAC DUCT SUPPORT DETAIL DRAHINGS AND THEIR EFFEC ON THE DUCT SUPPORT DESIGNS 0

INADEQUATE PROGRAM FOR THE INSTALLATION AND QUALITY CONTROL (QC) VERIFICATION OF HVAC DUCT SUPPORTS 0 GROOVE WELDS 1

l I

O LACK OF DOCUMENTATION FOR RECEIPT INSPECTION BY THE HVAC DUCT SUPPORT CONTRACTOR i

0 INSUFFICIENT THREAD ENGAGEMENT AND PRETENSIONING OF RICHMO INSERT BOLTS ON HVAC DUCT SUPPORTS 0 BATTERY ROOM VENTILATION 8

l l __. . _ . - -_.

I

HVAC DUCT / SUPPORT AND SYSTEMS CORRECTIVE ACTION PROGRAM 1

SPECIFIC ISSUES 3 CONT'D)

O BATTERY ROOM EXPLOSION PROOF THERMOSTATS 0

INSPECTION REPORTS DATED PRIOR TO ISSUE OF AS-BUILT DRAWING i 0 WELDER QUALIFICATION 0 NRC CAT INSPECTION RESULTS O

SEISMIC DESIGN OF HVAC SUPPORTS j

l O HVAC DUCT AXIAL RESTRAINT I 0

SEISMIC INTERACTION OF HVAC DUCT 0

CYGNA CONDUIT AND CABLE TRAY ISSUES 0 CASE /CYGNA CABLE TRAY ISSUES 0 OTHER HVAC IS$uES 0

ENVIRONMENTAL CONDITIONS AND REQUIREMENTS TECHNICAL REVIEW, RESOLUTION AND CORRECTIVE AND PREVENTATIVE ACTIONS FOR THE ABOVE SPECIFIC ISSUES WILL BE PRESENTED IN THE SUBAPPENDIX TO THE HVAC PROJECT STATUS REPORT.

J 9

3i l

l I

TU ELECTRIC I i

COMANCHE PEAK STEAM ELECTRIC STATION l

)

UNIT 1 AND COMMON i CABLE TRAYS AND CABLE TRAY HANGERS ,

l

i CORRECTIVE ACTION PROGRAM PRESENTED  !

TO CITIZENS ASSOCIATION FOR SOUND ENERGY DECEMBER,17 & 18, 1987

_ 1

e CABLE TRAYS AND CABLE TRAY HANGER _S SCOPE OF THE CORRECTIVE ACTION PROGRAM (CAP) 0 , UNIT 1 AND COMMON SEISMIO CATEGORY I AND SEISMIC CATEGORY II CABLE TRAYS AND CABLE TRAY HANGERS HAVE BEEN DESIGN VALIDATED 0 PRIMARY FEATURES OF THE CAP FOR CABLE TRAYS AND CABLE TRAY HANGERS ESTABLISHMENT OF CABLE TRAY AND CABLE TRAY HANGER DESIGN CRITERIA WHICH COMPLY WITH CPSES LICENSING COMMITMENTS DEVELOPMENT OF THE DESIGN BASIS DOCUMENT (DBD-CS-082)

IMPLEMENTATION OF DESIGN AND HARDWARE VALIDATION INCLUDING IDENTIFICATION AND IMPLEMENTATION OF NECESSARY MODIFICATIONS RESOLUTION OF DESIGN AND HARDWARE-RELATED ISSUES FOR THE CPSES CABLE TRAYS AND CABLE TRAY HANGERS COMPILATION OF VALIDATED DESIGN DOCUMENTATION TO FORM BASIS FOR CONFIGURATION CONTROL.

s II a

CABLE TRAYS AND CABLE TRAY HANGEP.S PRIMARY FEATURES OF THE CORRECTIVE ACTION P 0

IDENTIFY COMMITMENTS ,

FSAR NRC REGULATORY Gu! des AND I&E BULLETINS APPLICABLE CODES AND STANDARDS (EG. AISC) 0 ESTABLISH DESIGN VALTDATION CRITERIA AND PROCEDURES Numerous ENGINEERING STUDIES PERFORMED -

, EXTEusIvE TESTING FULL SCALE DYNAMIC tests COMPONENT tests O

PROVIDE ASSURANCE THAT ALL EXTERNAL SOURCE CONCERNS HAVE BEEN REs0LVED EXTENSIVE DAP REsuLTs REVIEW aY CPRT THIRD PARTY (TENERA) IN DO REPORTi CIVIL / STRUCTURAL CAELE TRAYS AND SUPPORTS, DAP-RR-C/S-001 0

PERFORM DESIGN VALIDATION

- COLLECTION OF As-BUILT DATA FOR EACH CABLE TRAY

- DESIGN VALIDATION OF EACH As-su1LT CABLE TRAY HANG DESIGN VALIDATION OF TRAYS AND CLAMPS 0

IMPLEMENT NECEssARY HARDWARE MODIFICATIONS.

III

e CABLE TRAYS AND CABLE TRAY HANGERS PRIMARY FEATURES OF THE CORRECTIVE ACTION PROGRAM (CAP)

(CONTINUED)

O PERFORM FINAL RECONCILIATION INCORPORATION OF PCHVP RESULTS CLOSURE OF OPEN ITEMS COMPILATION OF DESIGN VALIDATION PACKAGES IV

1 CABLE TRAY HANGERS i l

SUMMARY

FLOW CHART l DESIGN VALIDATION DBD CS 082 Y

HARDWARE VALIDATION ECE9.04-02 ECE 0.04-0 5 TE FVM CS 003 CPE FVM CS 001 CPE EB FYM CS 019 TE FVM CS 048 TE FVM CS 036 g CPE EB FYM CS 084 Y CPE EB FVM CS 098 EVALUATION OF VALIDATION RESULTS Y

ISSUE MODIFICATIONS ECE 5.01 13 Y

i CONSTRUCTION /QC MODIFICATIONS l

~

Y FINAL RECONCILIATION 1 NY MOP I

lI VAULT l

ECE 2.13 1

I i

t e

CABLE TRAY AND CABLE TRAY HANGER CORRECTIVE ACTION PROGRAM IDENTIFY LICENSING 4 FSAR COMMITMENTS 4 OTHER LICENSING

,, DOCUMENTS DEVELOP DESIGN BASIS DOCUMENTS (DBD'S)

PERFORM DESIGN C CPRT (DAP & QOC)

VALIDATION q EXTERNAL ISSUES

. NRC (SRT, SIT, TRT, C AT)

- CYONA (IAP)

CASE f .ASLB

+ NRC INSPECTION REPORTS is MODIFICATION YES m DESIGN REQUIRED MODIFICATIONS Y" y POST CONSTRUCTION H ARDWARE VALIDATION ,

p PROGR AM (PCHYP) l Y

FINAL DESIGN RECONCILIATION I f IS YES ADDITIONAL VALIDATION REQUIRED

?

f NO FINAL DOCUMENTATION (DEstGN YALIDATION PACK AGES) i

)

3

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A30 (GIR APPENDIX 30)

CABLE TRAY SYSTEM DAMPING VALUES EXTERNAL SOURCE ISSUE-CASE:

THE VALIDITY OF 4 PERCENT AND 7 PERCENT DAMPING FOR THE OBE AND SSE SEISMIC EVALUATION OF CABLE TRAY SYSTEMS HAS BEEN QUESTIONED.

ISSUE RESOLUTION / IMPLEMENTATION:

FULL SCALE DYNAMIC TESTS OF REPRE3ENTATIVE CABLE TRAY SYSTEMS (REPORT !

09-0210-0017 AND ANCO "FINAL

SUMMARY

REPORT - COMANCHE PEAK CABLE TRAY TESTS") HAVE DEMONSTRATED THE VALIDITY OF USING 4% AND 7% DAMPING IN THE EVALUATION OF OBE AND SSE SEISMIC LOADS, RESPECTIVELY.

ACTUAL DAMPING VALUES WERE DETERMINED TO BE 2 4% FOR OBE AND 2 7% FOR SSE. A i LARGER NUMBER OF CASES HAD DAMPING VALUES SUBSTANTIALLY HIGHER (OBE 7% ,

To 10%, SSE 15% To 20%). '

l l

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e CABLE TRAY AND CABLE TRAY HANGERS -

PSR SUBAPPENDIX A30 (GIR APPENDIX 30) -

CABLE TRAY SYSTEM DAMPING VAEUE

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. CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX'A31 (GIR APPENDIX 31)

,- MODELING 0F BOUNDARY CONDITIONS EXTERNAL SOURCE ISSUE-CASE:

CONCERNS WERE RAISED REGARDING ANCHORAGE EOUNDARY CONDITIONS, INCLUDING THE EFFECTS OF OVERSIZED BOLT HOLES, AND THE TECHNIQUES USED TO REPRESENT ANCHORAGE BEHAVIOR IN ANALYTICAL MODELS.

ISSUE RESOLUTION / IMPLEMENTATION:

DESICN VALIDATION INCLUDES ANCHOR BOLT STIFFNESS AND BASE PLATE FLEXIBILITY IN MODELINA BOUNDARY CONDITIONS OF SUPPORT ANCHORAGES AS DETERMINED BY VOLUME 1, BOOK 12 AND CALCULATION M-04.

THE EFFECT OF BOLT HOLE SIZE ON ANCHORAGE BEHAVIOR IS NOT EXPLICITLY CONSIDERED IN DESIGN VALIDATION (SEE SuBAPPENDIx A14). THE CABLE TRAY SYSTEM DYNAMIC TESTS HAVE SHOWN THAT DINAMIC RESPONSE OF ATRAY CABLE SYSTEM IS NOT SENSITIVE TO MINOR VARIATIONS IN THE ANCHORAGE (ANCO "FINAL

SUMMARY

REPORT - COMANCHE PEAK CABLE TRAY TEST").

A31-1 w, - - - - , , -, , _ n , - - - . , . - . . - _

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A1 (GIR APPENDIX 1)

CONTROLLING LOAD CASE FOR DESIGN EXTERNAL SOURCE ISSUE:

THE ORIGINAL DESIGN OF CABLE TRAY HANGER SYSTEMS MAY NOT HAVE PROPERLY CONSIDERED BOTH OBE AND SSE LOAD COMBINATIONS BY ASSUMING THAT A 60%

INCREASE IN SSE ALLOWABLES WAS APPLICABLE TO ALL HANGER COMPONENTS.

/

ISSQLRESOLUTION/IMFi.EMENTATION:

CABLE TRAY HANGERS HAVE BEEN DESIGN VALIDATED FOR THE EFFECTS OF OBE AND SSE LOADS SEPARATELY IN'ACCORDANCE WITH THE DESIGN VALIDATION PROCEDURES PI-02, PI-03, PI-07, SAG.CP3, SAG.CP4, SAG.CP11, AND SAG.CP34. APPROPRIATE OBE AND SSE ALLOWABLES WERE USED FOR CABLE TRAY HANGER SYSTEM COMPONENTS INCLUDING STRUCTURAL STEEL, WELDS, '

ANCHORAGES, RICHMOND INSERTS AND HILTI KWIK-BOLTS. CABLE TRAYS AND ,

CABLE TRAY CLAMPS ARE DESIGN VALIDATED IN ACCORDANCE WITH DESIGN s VALIDATION PROCEDURES PI-06, SAG.CP18 AND SAG.CP19 BY THE CGMPARISON 0F THE HIGHER SSE L0t.DS TO THE FACTORED COMPONENT ULTIMATE STRENGTH. ;

THE FACTORS WHICH HAVE BEEN USED ARE APPROPRIATE FOR BOTH THE OBE AND '

SSE LEVEL OF EARTHQUAKE. ,

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CABLE TRAYS AND CABLE TRAY HANGERS

. PSR SUBAPPENDIX A2 (GIR APPENDIX 21

.- SEISMIC RESPONSE COMBINATION METHOD EXTERNAL SOURCE ISSilE:

THE ORIGINAL DESIGN, DID NOT PROPERLY COMBINE SEISMIC RESPONSES IN THE EVALUATION CF CABLE TRAY HANGERS FOR:

A. CLOSELY SPACED MODES AS REQUIRED BY CPSES FSAR AND NRC REGULATORY GUIDE 1.92.

4 B. THE DEADWEIGHT LOAD WITH THE SEISMIC LOADING USING THE SQUARE ROOT SUM OF THE SQUARES (SRSS) METHOD.

ISSUE RESOLUTION / IMPLEMENTATION:

THE DESIGN VALIDATION PROCEDURES PI-02, SAG.CP3, SAG.CP4, SAG.CP11 AND SAG.CP34 REQUIRE THAT:

A. THE RESPONSE SPECTRA ANALYSES' COMBINE RESPONSES CONSIDERING CLOSELY SPACED MODES IN ACCORDANCE WITH THE CPSES FSAR AND ,

NRC REGULATORY Gu!DE 1.92.

B. DEAD LOAD NOT BE INCLUDED WITHIN THE SRSS OF THE SEISMIC LOADS BUT ADDED SEPARATELY TO THE RESULTANT SEISMIC LOAD.

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b A2-1 I

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CABLE ' TRAY AND CABLE TRAY HANGERS -

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PSR SUBAPPENDIX A2  !

~

IGIR APPENDIX 2)

SEISMIC RESPONSE COMBINATION METHOD l ORIGINAL DESIGN: '

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i i

(1.0G DEAD LOAD + VERTICAL)2 + (NORTH-SOUTH)2 i

PRESENT DESIGN VALIDATION METHOD: '

(DEAD LOAD)+

(VERTICAL)2 + (NORTH-SOUTH)2 + (EAST-WEST)2 1

4 FIGURE FOR A2.8

6 CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A3 (GIR APPENDIX 3)

ANCHOR BOLT DESIGN EXTERNAL SOURCE ISSUE:

THIS ISSUE WAS THAT INCORRECT ASSUMPTIONS AND INCONSISTENT DESIGN CRITERIA MAY HAVE BEEN USED IN THE ORIGINAL DESIGN OF THE CABLE TRAY HANGER ANCHORAGES. SPECIFICALLY:

i i

0 BASE ANGLE / BASE PLATE GEOMETRY WAS NOT EVAL,UATLC TO DETERMINE APPROPRIATE ANCHORAGE STIFFNESS, ECCENTRICITIES l AND PRYING ACTION FACTORS.

0 OBE WAS CONSIDERED AS THE GOVERNING LOAD CASE FOR ANCHORAGE DESIGN WITHOUT SUFFICIENT JUSTIFICATION.

O ANCHORAGE DESIGNS DID NOT ADEQUATELY CONSIDER AS-BUILT CONDITIONS (I.E., ANCHOR SUBSTITUTIONS AND INSTALLATION TOLERANCES).

O ANCHORAGE DESIGNS MAY HAVE USED INAPPROPRIATE ANCHOR BOLT DESIGN ALLOWABLES.

O INCONSISTENT USE OF THE ACI 349-76 APPENDIX B DESIGN SPECIFICATION.

1 1

A3-1 L . _ _ _ _ _ _ - . _ - - . . -_. - --- - -- - - - - . . - - - - - - - - - -

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A3 (GIR APPENDIX 3)

ANCHOR BOLT DESIGN ISSUE RESOLUTION /IMPLEMENTATl03:

l THIS ISSUE HAS BEEN RESOLVED BY THE FOLLOWING:

l l

THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, PI-02 AND i PI-07 REQUIRE THAT CABLE TRAY HANGER ANCHORAGES BE EVALUATED CONSIDERING ANCHORAGE STIFFNESS, ECCENTRICITIES, AND THE ADDITIONAL {

ANCHOR BOLT TENSION RESULTING FA0M PRYING. THE ANCHORAGE STIFFNESS AND PRYING ACTION FACTORS INCORPORATED IN THE PROCEDURES WERE DEVELOPED IN ENGINEERING STUDIES M-04, M-25, VOLUME I, BOOKS 3, 11 AND 12 WHICH CONSIDERED AS-BUILT BASE ANGLE / BASE PLATE GEOMETRIES.

THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34 AND PI-02 REQUIRE THE EVALUATION OF CABLE TRAY ANCHORAGES FOR THF, EFFECTS OF OBE AND SSE LOADS SEPARATELY. DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4 AND PI-07 CONTAIN THE OBE AND SSE DESIGN ALLOWABLES USED FOR DESIGN VALIDATION OF ANCHOR BOLTS (HILTI EXPANSION ANCHORS AND RICHMOND INSERTS).

THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, PI-02, AND PI-07 REQUIRE THE USE OF AS-BUILT DATA FOR THE DESIGN VALIDATION OF CABLE TRAY HANGER ANCHORAGES.

A3-2

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A3(GIR APPENDIX 3)

ANCH0d'BOLTDESIGNISSUERESOLUTION/ IMPLEMENTATION:

(CONTINUED)

THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, AND PI-07 REQUIRE THE USE OF ANCHOR BOLT DESIGN ALLOWABLES AS PROVIDED IN THE CONCRETE EMBEDMENT DESIGN SPECIFICATION 2323-55-30. THE REQUIREMENTS FOR THE DESIGN OF CONCRETE ANCHOR BOLTS ARE BASED ON CAPACITIES DETERMINED FROM TESTS AND UTILIZE APPROPRIATE FACTORS OF SAFETY.

THESE ALLOWABLEM ARE BEING VALIDATED IN THE CIVIL / STRUCTURAL l CORRECTIVE ACTION PROGRAM. l

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A3-3

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CABLE TRAY AND CABli TRAY HANGERS PSR SUBAPPENDIX A3 (GIR APPENDIX 3)

ANCHOR BOLT DESIGN Jl 3 6 nd o e iy

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Labedmont Plates TYPICAL CABLE TRAY HANGER ANCHORAGE CONFIGURATIONS

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. 1 CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS EXTERNAL SOURCE ISSUE:

A.

THE ORIGINAL DESIGN CALCULATIONS USED IMPROPER MEMBER LENGTHS AND END CONDITIONS FOR DETERMINING THE SLENDERNESS RATIO OF CHANNEL P

SECTION COMPRESSION MEMBERS IN TRAPEZE TYPE HANGERS.

ISSUE RESOLUTION / IMPLEMENTATION:

A. DESIGN VALIDATION PROCEDURES SAG.CP9, SAG.CP34, PI-03 AND PI-11 PROVIDE REQUIREMENTS FOR THE APPROPRIATE UNSUPPORTED LENGTHS OF CABLE TRAY HANGER MEMBERS TO BE USED TO CALCULATE COMPRESSION MEMBER SLENDERNESS RATIOS (KL/R). ENGINEERING STUDIES HAVE BEEN PERFORMED TO ESTABLISH EFFECTIVE LENGTH FACTORS FOR THE INSTALLED {

CABLE TRAY HANGER DESIGNS. THESE STUDIES ARE DOCUMENTED IN VOLUME I-800K 6, REPORT 01-0210-1470 AND CALCULATION B-04.

EFFECTIVE LENGTH FACTORS HAVE BEEN USED WITH APPROPRIATE UNSUPPORTED MEMBER LENGTHS TO CALCULATE THE SLENDERNESS RATIOS OF COMPRESSION MEMBERS.

l 0

A4-1

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_ CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4

=-

-(GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS uw aw I  !

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l Vertical Load Distribution PARAMETERS WHICH INFLUENCE EFFECTIVE L.ENGTH FACTORS

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I CABLE TRAY AND CABLE TRAY HANGERS -

PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS l

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1 Rotational Stiffness I

PARAMETERS WHICH INFLUENCE EFFECTIVE LENGTH FACTORS (CONT'D) l l

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CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS JM 99 l

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Longitudinal Restraint i

PARAMETERS WHICH INFLUENCE EFFECTIVE LENGTH FACT 0'RS (CONT'D)

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l CABLETRAYANDCABLEk'RAYHANGERS PSR SUBAPPENDIX A4

.- -(GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS

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i Transverse Load PARAMETERS WHICH INFLUENCE EFFECTIVE LENGTH FACTORS (CONT'D)

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1 CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 I (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS (CONTINUED)

EXTERNAL SOURCE ISSUE:

l B. l THE ORIGINAL DESIGN CALCULATIONS FOR DETERMINING THESLENDERNESS '

RATIO OF COMPRESSION MEMBERS IN TRAPEZE HANGERS DID NOT VERIFY THE EFFECTIVENESS OF IN-PLANE SIDESWAY RESTRAINT FOR VARIOUS l DESIGNS.

ISSUE RESOLUTION / IMPLEMENTATION:

B. ENGINEERING STUDIES VOLUME I, BOOK 6, REPORT 01-0210-1470 AND CALCULATION B-04 HAVE BEEN PERFORMED TO DEVELOP EFFECTIVE LENGTH FACTORS FOR THE INSTALLED CABLE TRAY HANGERS. THESE STUDIES (

INCLUDE CONSIDERATION OF SIDESWAY RESTRAINT FOR BOTH TRANSVERSE AND LONGITUDINAL TRAPEZE TYPE HANGERS. THESE EFFECTIVE LENGTH FACTORS ARE USED IN CABLE TRAY HANGER VALIDATION IN ACCORDANCE  !

WITH DESIGN VALIDATION PROCEDURES SAG.CP9, SAG.CP34, PI-03 AND PI-11.

4 A4-2

1 l

\

l CABLE TRAYS AND CABLE TRAY HANGERS j 1

. PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS (CONT'D) ,

EXTERNAL SOURCE ISSUE:

C. THE ORIGINAL DESIGN CALCULATIONS FOR CANTILEVER HANGERS USED A DISTAi!CE FROM THE CONCRETE FACE TO THE TRAY CENTERLINE FOR CANTILEVER LENGTH, INSTEAD OF THE DISTANCE TO THE OUTSIDE CLAMP.

ADDITIONALLY, ORIGINAL DESIGN CALCULATIONS FOR DETERMINING THE SLENDERNESS RATIO OF MEMBERS IN CANTILEVER HANGERS ASSUMED THE CABLE TRAY PROVIDED LATERAL BRACING AT THE TRAY CLAMP LOCATION WITHOUT PROPER JUSTIFICATION.

ISSUE RESOLUTION / IMPLEMENTATION:

C. DESIGN VALIDATION PROCEDURES SAG.CP9, SAG.CP34, PI-03 AND PI-11 PROVIDE REQUIREMENTS FOR THE APPROPRIATE UNSUPPORTED LENGTH OF CANTILEVER HANGER MEMBERS TO BE USED TO CALCULATE COMPRESSION MEMBER SLENDERNESS RATIOS. ENGINEERING STUDIES (REPORT 01-210-1470 AND CALCULATION B-04) HAVE DEMONSTRATED THAT CABLE TRAYS PROVIDE SUFFICIENT LATERAL BRACING AND DEVELOPED EFFECTIVE LENGTH FACTORS FOR INSTALLED CABLE TRAY CANTILEVER HANGER DESIGNS. THESE EFFECTIVE LENGTH FACTORS ARE USED IN CABLE TRAY HANGER VALIDATION IN ACCORDANCE WITH DESIGN VALIDATION PROCEDURES SAG.CP9, SAG.CP34, PI-03 AND PI-11. .

A4-3 1 _ - - . .-_ . .

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_ CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 (GIR APPENDIX A4)

DESIGN OF COMPRESSIO_N MEMBERS ORIGINAL DESIGN:

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PRESENT DESIGN:

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CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

<- DESIGN OF COMPRESSION MEMBERS (c0NTINUED)

EXTERNAL SOURCE ISSUE:

)

i D. THE ORIGINAL DESIGN CALCULATIONS DID NOT CONSIDER A R'; DUCTION IN 1 SECTION PROPERTIES DUE TO WELD UNDERCUT AT IN-PLANE BRACE ATTACHMENT POINTS.

E. INSTALLATION SPECIFICATIONS ALLOW A TOLERANCE ON PLUMBNESS OF VERTICAL MEMBERS. THE ORIGINAL DESIGN DID NOT CONSIDER THE EFFECT OF OUT-OF-PLUMBNESS ON COMPRESSIVE ALLOWABLES.

ISSUE RESOLUTION / IMPLEMENTATION:

D. THE CABLE TRAY HANGERS HAVE BEEN INSPECTED AS SPECIFIED IN NOA-3.09-10.01. AN ENGINEERING STUDY (VOLUME I, BOOK 20) OF THE BASE METAL DEFECTS IDENTIFIED BY THESE QC INSPECTIONS HAS BEEN PERFORMED AND CONCLUDED THAT THE EFFECTS OF WELD UNDERCUT ON CABLE TP.AY HANGER CAPACITY ARE NOT SIGNIFICANT AND NEED NOT BE EXPLICITLY CONSIDERED.

E. TESTS AND STUDIES (VOLUME I, BOOK 16 AND REPORT 09-0210-0017)

DEMONSTRATE THAT THE TWO (2) DEGREE OUT-OF-PLUMBNESS TOLERANCE FOR CABLE TRAY HANGERS HAS NO EFFECT ON DESIGN ADEQUACY. I OuT-OF-PLUMBNESS GREATER THAN TWO (2) DEGREES IS NOTED ON AS-BUILT HANGER DRAWINGS AS REQUIRED BY WALKDOWN PROCEDURES CPE-FVM-CS-001, TE-FVM-CS-003 AND TE-FVM-CS-036 AND IS CONSIDERED I

IN DESIGN VALIDATION AS REQUIRED BY DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-02.

A4-4

- . . .. z- ___ _ _ _ . - .

\

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A4 (GIR APPENDIX 4)

DESIGN OF COMPRESSION MEMBERS (CONTINUED)

EXTERNAL SOURCE ISSUE:

F. IN THE ORIGINAL WORKING POINT DEVIATION STUDY, A REDUCED UNSUPPORTED LENGTH FOR TRAPEZE HANGERS WAS USED BASED ON AN INVALID ASSUMPTION OF RIGIDITY OF THE BASE ANGLE LEG RELATIVE TO THE HANGER.

G. THE ORIGINAL DESIGN CALCULATIONS FOR BRACES IN COMPRESSION CONSIDERED THE HIGHEST LOAD AS A FUNCTION OF BRACE SLOPE, AND CHECKED FOR THIS SLOPE WITHOUT CONSIDERING CASES WITH LOWER LOADS WHERE CAPACITY IS REDUCED DUE TO LONGER MEMBER LENGTH.

ISSUE RESOLUTION / IMPLEMENTATION:

F. IN DESIGN VALIDATION, THE APPROPRIATE LENGTH INCLUDING THE OUTSTANDING BASE ANGLE LEG WAS USED AS REQUIRED IN SAG.CP34, PI-02 AND PI-03. THE EFFECTIVE LENGTH FACTORS DOCUMENTED IN VOLUME I,-800K 6, REPORT 01-0210-1470, AND CALCULATION B-04 CONSIDER THE EFFECTS OF ANCHORAGE FLEXIBILITY, i

l G. DESIGN VALIDATION IS NOT BASED ON THE ORIGINAL DESIGN CALCULATION. {

THE DESIGN VALIDATION OF BR' '"9 MEMBERS HAS BEEN PERFORMED USING AS-BUILT ItJFORMATION IN .4CCORDANCE WITH DESIGN VALIDATION PROCEDURES SAG.CP11, SAG.CP34, PI-02 AND PI-03.

1 A4-5

l CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A5 (GIR APPENDIX 5) l VERTICAL AND TRANSVERSE l i

LOADING ON LONGITUDINAL TYPE SUPPORTS l l

EXTERNAL SOURCE ISSUE:

THE ORIGINAL DESIGN FOR LONGITUDINAL TRAPEZE TYPE CABLE TRAY HANGERS (I.E, SUPPORTS) DID NOT INCLUDE THE VERTICAL AND TRANSVERSE SEISMIC CABLE TRAY LOADS.

ISSUE RESOLUTION / IMPLEMENTATION:

DESIGN VALIDATION PROCEDURES SAG.CP11, SAG.CP34 AND PI-02 REQUIRE THE SIMULTANEOUS APPLICATION OF SEISMICALLY INDUCED LOADS IN THREE l

ORTHOGONAL DIRECTIONS ON ALL CABLE TRAY HANGERS.

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CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A5 IGIR APPENDIX A51 VERTICAL AND TRANSVERSE 1

LOADING ON LONGITUDINAL SUPPORTS l ORIGINAL DESIGN: =

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PRESENT DESIGN:

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FIGURE FOR A5

1 l

l CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A6 IGIR APPENDIX 6) r-SUPPORT FRAME DEAD AND INERTIAL LOADS '

1 EXTERNAL SOURCE ISSUE:  !

A. THE ORIGINAL DESIGN DID NOT CONSIDER THE OUT-OF-PLANE INERTIAL

{

LOADS (I.E., LOADS PARALLEL TO THE CABLE TRAY) ON TRANSVERSE TYPE CABLE TRAY HANGERS. THIS ISSUE WAS ALSO THAT OUT-OF-PLANE LOADS TRANSMITTED FROM TRANSVERSE TYPE CABLE TRAY HANGERS THROUGH CABLE TRAYS WERE NOT CONSIDERED IN MEMBER AND ANCHORAGE DESIGN FOR l LONGITUDINAL CABLE TRAY HANGERS.

B. THE ORIGINAL DESIGN DID NOT PROPERLY CONSIDER THE CONTRIBUTION OF THE WEIGHT OF THE CABLE TRAY HANGER MEMBERS.

ISSUE RESOLUTION / IMPLEMENTATION:

A. OuT-OF-PLANE INERTIAL LOADS DUE TO CABLE TRAY HANGER DEAD WEIGHT HAS BEEN CONSIDERED IN THE DESIGN VALIDATION OF ALL CABLE TRAY HANGERS AS SPECIFIED IN THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34 AND PI-02. FURTHER DISCUSSIONS ARE CONTAINED IN ISSUE A18 REGARDING THE DISTRIBUTION OF, LOAD BETWEEN HANGERS.

I 1

B. THE ENTIRE CABLE TRAY HANGER DEAD WEIGHT HAS BEEN EXPLICITLY AND CONSISTENTLY CONSIDERED IN DESIGN VALIDATION AS SPECIFIED IN THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34 AND PI-02.

A6-1

s l

CABLE TRAYS AND CABLE TkAY HANGERS PSR SUBAPPENDIX A7 l

(GIR APPENDIX 7) ,

DESIGN OF ANGLE BRACES NEGLECTING LOADING ECC!

EXTERNAL SOURCE ISSUE:

A. IN THE ORIGINAL DESIGN, THE INDUCED BENDING STRESSES IN DOUBLE ANGLE BRACES DUE TO ECCENTRIC END CONNECTIONS WERE NOT CONSIDERED, AND DOUBLE ANGLE BRACES WITHOUT FILLER PLATES WERE INCORRECTLY CONSIDERED AS COMPOSITE MEMBERS.

B. IN THE ORIGINAL DESIGN, THE INDUCED BENDING STRESSES IN SINGLE ANGLE BRACES DUE TO ECCENTRIC END CONNECTIONS WERE NOT CONSIDERED, AND DESIGN CALCULATIONS DID NOT EVALUATE THE STRESS CONSIDERING THE PRINCIPAL AXES SECTION MODULI.

ISSUE RESOLUTION / IMPLEMENTATION:

A.

DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-03 AND ENGINEERING STUDY M-12 CONSIDER ECCENTRIC HEMBER END CONNECTIONS ON ALL HANGER MEMBERS.

DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-02 ALLOW DOUBLE ANGLE BRACES TO BE ANALYZED AS COMPOSITE MEMBERS ONLY IF THE REQUIREMENTS OF AISC SPECIFICATION SECTION 1.18.2.4 REGARDING INTERMITTENT FILLER PLATES ARE SATISFIED.

B. IN ADDITION TO THE RESOLUTION DISCUSSED IN ITEM A ABOVE, THE DESIGN VALIDATION PROCEDURES REQUIRE THAT PRINCIPAL STRESS BE ACCOUNTED FOR IN CHECKING MEMBER STRESSES.

A7-1

s 1.

CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A7

. \

(GIR APPENDIX A7)

DESIGN OF ANGLE BRACES NEGLECTING

-LOADING ECCENTRICITY i FILLER PLATE

/'

0/- -[/

[ WELDS v/.[/

DOUBLE ANGLE BRACES WITH FILLER PLATES FIGURE FOR A7.A l

s CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A7 (GIR APPENDIX 7)

DESIGN OF ANGLE BRACES NEGLECTING LOADING ECCENTRICITY (CONTINUED)

EXTERNAL SOURCE ISSUE:

C. IN THE ORIGINAL DESIGN, THE POTENTIAL FOR TWIST BUCKLING WAS NOT EVALUATED FOR SINGLE ANGLE BRACES WHERE MEMBERS ATTACH TO OPPOSITE LEGS AT EACH END.

ISSUE RESOLUTION / IMPLEMENTATION:

C. DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-02 AND ENGINEERING STUDY M-12 REQUIRE THE EVALUATION OF THE POTENTIAL FOR FLEXURAL BUCKLING, TORSIONAL BUCKLING, AND COMBINED TORSIONAL-FLEXURAL BUCKLING RESULTING FROM ECCENTRICALLY APPLIED AXIAL LOADS. THESE REQUIREMENTS INCLUDE THE CONSIDERATION OF THE DESIGN CONDITION DESCRIBED IN THE ORIGINAL DESIGN.

A7-2

_ _ _ _ _ y _ . . , , _ _ - _ _, , _ , _ _ - , _ _ _ _ . - , . . _ . , ._

CABLE TRAY AND CABLE TRAY HANGERS

.- PSR SUBAPPENDIX A7 (GIR APPENDIX A7)

. DESIGN OF ANGLE BRACES NEGLECTING LOADING ECCENTRICITY r m_

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I 9

+

?!GURE FOR A7.C

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CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A8 (GIR APPENDIX 8)

,. DYNAMIC AMPLIFICATION FACTORS (DAF)

TRIBUTARY TRAY SUPPORT REACTIONS AND MISSING MASS EFFECTS EXTERNAL SOURCE ISSUE:

A. IN THE ORIGINAL CABLE TRAY HANGER DESIGN WHICH USED THE EQUIVALENT STATIC METHOD, THE SEISMIC LOAD WAS NOT INCREASED TO ACCOUNT FOR A DYNAMIC AMPLIFICATION FACTOR (DAF) NOR WERE THE ADDITIONAL SYSTEM kFFECTS CONSIDERED.

ISSUE RESOLUTION / IMPLEMENTATION:

A. DESIGN VALIDATION PROCEDURES, SAG.CP3, SAG.CP4, SAG.CP28, AND SAG.CP34. REQUIRE THE USE OF AT LEAST A 1.25 MULTIMODE RESPONSE MULTIPLIER (MRM), WHEN THE EQUIVALENT STATIC METHOD IS USED, TO ACCOUNT FOR DYNAMIC AMPLIFICATION EFFECTS AND CONTINUOUS SYSTEM LOAD DISTRIBUTION EFFECTS. THESE DESIGN VALIDATION PROCEDURES ASSURE THE PROPER USE OF THIS MULTIPLIER IN CONJUNCTION WITH SPECTRAL ACCELERATIONS, TRIBUTARY CABLE TRAY SPAN AND HANGER DEAD WEIGHT. THE VALIDITY OF THIS MULTIPLIER HAS BEEN ESTABLISHED BY ENGINEERING STUDIES DOCUMENTED IN VOLUME I, BOOKS 9, 10, 15, AND 23.

DESIGN VALIDATION ~

PROCEDURES SAG.CP28 AND SAG.CP34 WERE DEVELOPED TO PROPERLY ANALYZE THE CASLE TRAY SYSTEM CONFIGURATIONS FOR WHICH THE ENGINEERING STUDIES HAVE SHOWN THAT THE 1.25 MRM IS NOT SUFFICIENT TO ACCOUNT FOR THE LOAD DISTRIBUTION EFFECTS IN ADDITION TO THE MULTIPLE MODE EFFECTS.

A8-1

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CABLE TRAYS AND CABLE TRAY NANGERS PSR SUBAPPENDIX A8 (GIR APPENDIX 8)

.. DYNAMIC AMPLIFICATION FACTORS (DAF)

TRIBUTARY TRAY SUPPORT REACTIONS AND MISSING MASS EFFECTS (CONTINUED)

EXTERNAL SOURCE ISSUE:

B. THE ORIGINAL DESIGN DID NOT INCLUDE THE EFFECTS OF THE "MISSING MASS" FOR THE HIGHER FREQUENCY RESPONSE. /

ISSUE RESOLUTION / IMPLEMENTATION:

B. DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP11 AND PI-02, REQUIRE A MISSING MASS CORRECTION FOR RESPONSE SPECTRA

/.NALYSES PERFORMED FOR CABLE TRI.Y HANGER DESIGN VALIDATION.

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e A8-2

CABLE TRAYS AND CABLE TRAY HANGERS  :

PSR SUBAPPENDIX A9 (GIR APPENDIX 9) '

REDUCTION IN CHANNEL SECTION PROPERTIES ,

DUE-T0 CLAMP BOLT HOLES EXTERNAL SOURCE ISSUE:

ThE ORIGINAL DESIGN FOR CHANNELS DID NOT PROPERLY CONSIDER THE REDUCTION IN MOMENT OF INERTIA DUE TO BOLT HOLES, AS REQUIRED BY THE AISC SPECIFICATION. I i

ISSUE RESOLUTION / IMPLEMENTATION:

l REDUCED MEMBER SECTION PROPERTIES RESULTING FROM BOLT HCLES WERE DEVELOPED PER ENGINEERING STUDIES VOLUME I-BOOK 25 AND M-65 IN l

ACCORDANCE WITH THE AISC SPECIFICATION. THE SIZE OF THE BOLT H'O L ES  !

CONSIDERED WAs 3/4 IN; BASED ON A STATISTICAL EVALUATION OF AS-BUILT l CABLE TRAY HANGERS. THE DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-11 REQUIRE THE USE OF THESE REDUCED PROPERTIES IN THE DESIGN 1 VALIDATION OF CABLE TRAY HANGER TIERS TO ACCOUNT FOR THE PRESENCE OF BOTH USED AND UNUSED BOLT HOLES.

A9-1 t i

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CABLE TRAYS AND CABLE TRAY HANGERS  !

'PSR SUBAPPENDIX A10 i (GIR APPENDIX 10) l SYSTEM CONCEPT  !

_ i EXTERNAL SOURCE ISSUE:

l A. THE "$YSTEM CONCEPT," WHICH WAS USED TO JUSTIFY THE ORIGINAL  !

DESIGN, ASSUMED THE MOMENTS RESULTING FROM THE BEAM TO HANGER

, CONNECTION ECCENTRICITIES IN THE CABLE TRAY AND THE CABLE TRAY HANGER WERE BALANCED BY LOAD COUPLES BETWEEN ADJACENT CABLE TRAY HANGERS. THIS BEHAVIOR REQUIRES COMPATIBILITY BETWEEN TRAYS AND HANGERS VIA THE TRAY CLAMPS. SUFFICIENT JUSTIFICATION FOR THIS I ASSUMPTION WAS NOT PROVIDED.

i f

ISSUE RESOLUTION /IMFLEMENTATIQR:  !

1

! A. COMPATIBILITY BETWEEN TRAYS AND HANGERS HAS BEEN USED IN DESIGN i VALIDATION. THE STUDY USED TO JUSTIFY THE ORIGINAL DESIGN WAS l NOT USED IN DESIGN VALIDATION. THE DESIGN VALIDATION OF CABLE .

l TRAY HANGERS WAS PERFORMED CONSIDERING THE LOADING ECCENTRICITIES 4

SPECIFIED IN THE DESIGN VALIDATION DOCUMENTS SAG.CP3, SAG.CP4, SAG.CP9, SAG.CP11, SAG.CP34, PI-02 AND PI-07. ENGINEERING STUDIES VOLUME I - BOOKS 2 AND 7, M-12, AND REPORT 09-0210-0017 JUSTIFY THE MODELING TECHNIQUES CONTAINED IN THESE PROCEDURES.

BEHAVIOR OF CABLE TRAY CLAMPS IS DISCUSSED IN PSR SuBAPPENDIX A18.

l A10-1 i

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CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A10 l (GIR APPENDIX 10)

SYSTEM CONCEPT (CONTINUED) l EXTERNAL SOURCE ISSUE:

I B. THE "$YSTEM CONCEPT," USED TO JUSTIFY THE ORIGINAL DESIGN ASSUMED l CABLE TRAYS PROVIDED LATERAL BRACING FOR THE CABLE TRAY HANGERS WITHOUT JUSTIFICATION.

ISSUE RESOLUTION / IMPLEMENTATION:

B. JUSTIFICATION HAS BEEN PROVIDED FOR THE ASSUMPTION THAT CABLE TRAYS PROVIDE LATERAL BRACING FOR THE CABLE TRAY HANGERS. )

DETAILED ENGINEERING STUDIES DEVELOPED EFFECTIVE LENGTH FACTORS AND ESTABLISHED THE EFFECTIVENESS OF BRACING PROVIDED BY THE CABLE TRAYS TO THE CABLE TRAY HANGERS. THESE STUDIES ARE I DOCUMENTED IN REPORT 01-0210-1470, 09-0210-0017 AND VOLUME I-BOOK 6. DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-03 INCORPORATED l

THE RESULTS OF THE' ENGINEERING STUDIES. THE EFFECTIVENESS OF BRACING PROVIDED BY CABLE TRAYS WAS ALSO l DEMONSTRATED IN A FULL SCALE DYNAMIC TEST PROGRAM. ,

A10-2

. CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A10 (GIR APPENDIX 10)

SYSTEM CONCEPT (CONTINUED)

LXTERNAL SOURCE ISSUE:

C. IN THE ORIGINAL DESIGN OF LONGITUDINAL TRAPEZE TYPE CABLE TRAY HANGERS, TRANSVERSE AND VERTICAL LOADS WERE NOT CONSIDERED.

ISSUE RESOLUTION / IMPLEMENTATION:

C. ALL CABLE TRAY HANGERS WERE DESIGN VALIDATED CONSIDERING THE SIMULTANEOUS APPLICATION OF ALL SEISMICALLY INDUCED LOADS (THREE (3) ORTHOGONAL DIRECTIONS) ON EACH HANGER AS DESCRIBED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAE,CP9, SAG.CP11, SAG.CP34 AND PI-02.

e A10-3

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CABLE TRAYS AND CABLE TRAY HANGERS 1

PSR SUBAPPENDIX A10 '

1 (GIR APPENDIX 10)

,. SYSTEM CONCEPT (CONTINUED)

EXTERNAL SOURCE ISSUE:

D. IN THE ORIGINAL DESIGN, ADDITIONAL TENSILE FORCES IN ANCHOR BOLTS DUE TO THE ROTATION OF BASE ANGLES ABOUT THE BOLT PATTERN AXIS WERE ASSUMED TO BE MINIMIZED BY THE ATTACHED CABLE TRAY.  !

ISSUE RESOLUTION / IMPLEMENTATION:

D. INE EFFECTIVENESS OF BRACING PROVIDED BY CABLE TRAYS WAS DEMONSTRATED IN A FULL SCALE DYNAMIC TEST PROGRAM.

9 DETAILED ENGINEERING STUDIES, VOLUME I-BOOK 3 AND M-25, DEVELOPED PRYING ACTION FACTORS BY CONSERVATIVELY NOT ACCOUNTING FOR TRAY RESISTANCE. MODELING PROCEDURES TO EFFECTIVELY ACCOUNT FOR ANCHORAGE ECCENTRICITIES AND ADDITIONAL TENSILE FORCES CAUSED BY  !

ANCHORAGE ROTATION HAVE BEEN INCORPORATED INTO THE DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-07.

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CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A10 .

(GIR APPENDIX 10)

.. SYSTEM CONCEPT (CONTINUED)

EXTERNAL SOURCE ISSUE:  ;

I E. THE ORIGINAL LONGITUDINAL CABLE TRAY HANGER DESIGN DID NOT CONSIDER OUT-OF-PLANE SEISMIC INERTIAL LOADS FOR TRAPEZE TYPE  ;

CABLE TRAY HANGERS.

ISSUE RESOLUTION / IMPLEMENTATION:

l l

E. ALL CAsLE TRAY HANGERS WERE DESIGN VALIDATED CONSIDERING THE )

SIMULTANEOUS APPLICATION OF ALL SEISMICALLY INDUCED LOADS (THREE (3) ORTHOGONAL DIRECTIONS) ON EACH HANGER AS DESCRIBED IN THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP9, SAG.CP11, SAG.CP34 AND PI-02.

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A10-5 m - - - . . __ _ _ , -- __,.__._.v-

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A10

_(GIR APPENDIX 10)

SYSTEM CONCEPT (CONTINUED)

EXTERNAL SOURCE ISSUE:

F. THE ORIGINAL CABLE TRAY HANGER DESIGN DID NOT ADEQUATELY ADDRESS ADDITIONAL MOMENTS INTRODUCED BY THE ECCENTRICITY BETWEEN THE NEUTRAL AXES OF CABLE TRAY HANGER TIER MEMBERS AND POST MEMBERS JOINED IN LAP JOINT CONNECTIONS. '

ISSUE RESOLUTION / IMPLEMENTATION: l

)

F.

CABLE TRAY HANGER DESIGN VALIDATION WAS PERFORMED CONSIDERING THE HANGER JOINT ECCENTRICITIES SPECIFIED IN THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP9, SAG.CP11, SAG.CP34, PI-02 l AND PI-07. THE ECCENTRICITY BETWEEN THE NEUTRAL AXES OF CABLE TRAY HANGER TIER MEMBERS AND POST MEMBER IS ONE OF THE ECCENTRICITIES CONSIDERED. ENGINEERING STUDIES VOLUME I, BOOKS 2 AND 7, REPORT 09-0210-017, AND CALCULATION M-12 JUSTIFY THE i MODELING TECHNIQUES IN THE DESIGN VALIDATION PROCEDURES SAG.CP9, I SAG.CP11, SAG.CP34, AND PI-02.

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Structural Detaih/ l45 f 9.15 Fillet Weld Details stresses, including those due to the eccentricity from the center of gravity of the angle, shall not exceed those a 9.15.1 Fillet welds which support a tensile force that is permitted by this Code.  !

not parallel to the axis of the weld shall not terminate at  !

' corners of parts or members, except as allowed by 9.21.5.2(2), but shall be returned continuously, full size, 9.17 Connections or Splices-Tension t around the corner for a length equal to twice the weld k

size where such return can be made in tne same plane. and Compression Meniders Boxing shallte indicated on design and detail drawings.

" Connections or splices of tension or compression mem-9.15.2 Fillet welds deposited on the opposite sides of a bets made by groove welds shall have complete joint common plane of contact between two parts shall be penetration welds. Connections or splices made with

, interterrupted at a corner common to both welds (see fillet or plug welds, except as noted in 9.18, shall be Fig. 9.15.2). designed for an average of the calculated stress and the Do not tie welds k

toptur ure strength of the member; or if there is repeated applica-tion ofload, the maximum stress or stress range in such connection or splice shall not exceed the fatigue stress g' ss permitted by the applicable general specification, s' s

' ' s' 's N '

9.18 Connections or Splices in

's Compression Members with

's Milled Joints If members subject to compression only are spliced and full-milled beanng is provided, the splice material and its g welding shall be arranged, unless otherwise stipulated by r / the applicable general speciGcations, to hold all parts in

/ alignment and shall be proportioned to carry 50<~c of the computed stress in the member. Where such members are in' full milled bearing on base plates, there shall be sufficient welding to hold all parts securely in place.

/

Fig,9.15,2-Fillet welds on opposite sides 9.19 Connections of Components of of a common plane of contact Built up Members When a member is built up of two or more pieces, the pieces 9.16 Eccentricity of Connections shall be connected along their longitudinaljoints by suf-ficient continuous welds to make the pieces act in unison.

9.16.1 Eccentricity between intersecting parts and mem- I bers shall be asoided insofar as practicable.

9.16.2 in designing welded joints, adequate prosision 9.20 Transition of Thicknesses or shall be made for Nnding stresses due to eccentncity,if ,idths at Butt Jo.mts any, in the disposition and section of base metal parts and in the location and types of welded joints. 9.20.1 Butt joints between parts having unequal thick-nesses and subject to tensile stress shall hase a smooth 9.16.3 For members having symmetrical cross sections, transition between the offset surfaces at a slope of no the connection welds shall be arranged symmetrically more than I in 21/2 with the surface of either part. The about the axis of the member, or proper allowance shall transition may be accomplished by sloping wdd sur-be made for unsymmetrical distnbution of stresses. faces, by chamfenng the thicker part, or by a combina-9.16.4 For axially stressed angle members, the center of . ti n of the two methods (see Fig. 9.20.1).

gravity of the connecting welds shalllie between the line 9.20.2 in buttjoints between parts of unequalinickness of the center of grasity of the angle's cross section and the that are subject only to shear or compressise stress, center line of the connected leg. If the center of gravity of transition of thickness shall be acco nplished as specified the connecting weld lies outside of this zone, the total in 9.20.1 when offset between surfaces at either side of

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CABLE TRAYS AND CABLE TRAY HANGERS i

.PSR SUBAPPENDIX All (GIR APPENDIX 11)

.. VALIDITY OF NASTRAN MODELS EXTERNAL SOURCE ISSUE:

NASTRAN MODELS USED IN SUPPORT OF THE ORIGINAL DESIGN MAY NOT HAVE INCLUDED SUFFICIENT VARIATION (IN HANGER TYPE AND TRAY SPAN) TO I REPRESENT AS-BUILT CONDITIONS.

ISSUE RESOLUTION / IMPLEMENTATION:

THE NASTRAN MODELS DISCUSSED ABOVE WERE NOT USED IN THE CABLE TRAY AND CABLE TRAY HANGER DESIGN VALIDATION.

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CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A12 (GIR APPENDIX 12)

WORKING POINT DEVIATION STUDY I

EXTERNAL SOURCE ISSUE: ,

1 THE "WORKING POINT DEVIATION STUDY" WHICH WAS INTENDED TO PROVIDE ALLOWABLE TOLERANCES ON THE WORKING POINT LOCATIONS FOR THE ORIGINAL CABLE TRAY HANGER DESIGNS (I.E., ACCOUNT FOR ECCENTRICITIES AT CONNECTIONS WHICH WERE NOT CONSIDERED IN THE ORIGINAL DESIGN) MAY NOT HAVE INCLUDED SUFFICIENT VARIATION (INCLUDING HANGER TYPE, TRAY TYPE,  ;

NUMBER OF TRAYS) TO REPRESENT THE AS-BUILT CON FI'GU RATION . I ADDITIONALLY, SUFFICIEMT JUSTIFICATION WAS NOT PROVIDED IN THE STUDY FOR MODELING ASSUMPTIONS (SUCH AS TRAY AND HANGER BOUNDARY CONDITIONS I AND TRAY / HANGER CONNECTIVITY) OR FOR SELECTION OF PARTICULAR HANGER  !

CONFIGURATIONS OR COMPONENTS TO DEVELOP GENERAL WORKING POINT LOCATION TOLERANCES.

l ISSUE RESOLUTION / IMPLEMENTATION: l i

RESULTS OF THE "WORKING POINT DEVIATION STUDY" ARE NOT USED IN THE DESIGN VALIDATION OF CABLE TRAY HANGERS. THE CABLE TRAY HANGERS HAVE BEEN DESIGN VALIDATED USING AS-BUILT INFORMATION.

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CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A13 l (GIR APPENDIX 13)

REDUCED SPECTRAL ACCELERATIONS EXTERNAL SOURCE ISSUE: l l

REDUCED SEISMIC ACCELERATIONS WERE USED IN THE ORIGINAL DESIGN BASED ON CALCULATED FREQUENCIES OF CABLE TRAY SYSTEM MODELS WHICH WERE NOT REPRESENTATIVE OF THE AS-8UILT CONFIGURATIONS.

ISSUE RESOLUTION / IMPLEMENTATION: j i

RESULTS OF THE ORIGINAL DESIGN CALCULATIONS WHICH USED REDUCED SPECTRAL ACCELERATIONS ARE NOT USED IN DESIGN VALIDATION. AS-su!LT i DATA IS USED TO DEVELOP CABLE TRAY HANGER FREQUENCIES AS SPECIFIED IN I SAG.CP34 AND PI-02.

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e A13-1

CABLETRAYSANDCABLEiRAYHANGERS

.PSR SUBAPPENDIX A14 (GIR APPENDIX 14)

NON-CONFORMANCE WITH AISC SPECIFICATIONS EXTERNAL SOURCE ISSUE:

A. THERE WAS A CONCERN WITH THE SLENDERNESS LIMIT USED FOR CABLE TRAY HANGER COMPRESSION MEMBERS. '

ISSUE RESOLUTION / IMPLEMENTATION:

A. THE PROVISIONS OF SECTION 1.8.4 0F THz AISC SPECIFICATION HAVE BEEN APPLIED IN THE FOLLOWING MANNER:

1) CLASSIFICATION OF A VERTICAL POST MEMBER IN A CABLE TRAY HANGER AS A COMPRESSION OR TENSION MEMBER IS BASED UPON THE MAGNITUDE OF THE AXIAL LOAD COMPONENT. IN PARTICULAR, IF THERE IS ANY STATIC COMPRESSIVE FORCE OR IF THE COMBINED STATIC PLUS DYNAMIC LOAD EXCEEDS 50% OF THE DESIGN COMPRESSIVE STRENGTH, THE MEMBER IS CLASSIFIED AS A COMPRESSION MEMBER. A MAXIMUM SLENDERNESS RATIO (KL/R)

LIMIT OF 200 IS APPLIED TO THESE MEMBERS.

2)

IF VERTICAL POST MEMBER IS SUBJECT TO STATIC TENSION, AND IF THE COMBINED STATIC PLUS DYNAMIC LOAD DOES NOT RESULT IN A COMPRESSIVE FORCE GREATER THAN 50% OF THE DESIGN COMPRESSIVE STRENGTH, THE MEMBER IS CLASSIFIED AS A TENSION MEMBER. THE MAXIMUM SLENDERNESS RATIO (L/R) LIMIT OF 300 IS APPLIED TO  ;

THESE MEMBERS.

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CABLE TRAYS AND CABLE TRAY HANGERS

,PSR SUBAPPENDIX A14

.(GIR APPENDIX 14)

NON-CONFORMANCE WITH AISC SPECi/ICATIONS

. (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

(CONTINUED) 3)

REGARDLESS OF THE MEMBER CLASSIFICATION OR THE NATURE OF THE LOAD, A FULL COMPRESSIVE STRESS CHECK IS PERFORMED IN ,

ACCORDANCE WITH THE AISC SPECIFICATION FOR MEMBERS SUBJECT TO A COMPRESSIVE LOAD.

A MORE DETAILED DISer.lSION OF THE SLENDERNESS RATIO LIMITS AS APPLIED TO THE (75ES CABLE TRAY HANGERS IS PROVIDED IN SAG.CP34 AND REPORT 09-0210-0018. ,

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A14-2 1

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A14 (GIR APPENDIX 14)

. NON-CONFORMANCE WITH AISC SPECIFICATIONS .

(CONTINUED)

EXTERNAL SOURCE ISSUE:

B. AISC EQUATION 1.5-7 FOR DETERMINING BENDING STRESS ALLOWABLES IN CHANNELS WAS NOT CONSIDERED OR WAS IMPROPERLY USED.

I C. REDUCTIONS IN SECTION PROPERTIES OF BEAMS DUE TO BOLT HOLES IN FLANGES WERE NOT CONSIDERED.

ISSUE RESOLUTION / IMPLEMENTATION: l I

B. THE DESIGN VALIDATION PROCEDURES SAG.CP34, PI-03 AND PI-11  !

REQUIRE THE USE OF AISC EQUATION 1.5-7 FOR VALIDATION OF CABLE TRAY HANGER CHANNEL MEMBERS AND PROVIDE DIRECTION FOR ITS PROPER APPLICATION.

l C.

REDUCED MEMBER SECTION PROPERTIES RESULTING FROM BOLT WERE HOLES DEVELOPED PER ENGINEERING STUDIES VOLUME I-BOOK 25 AND M-65 IN  !

ACCORDANCE WITH THE AISC SPECIFICATION. THE SIZE OF THE BOLT HOLES CONSIDERED WAS 3/4 IN; BASED ON A STATISTICAL EVALUATION OF AS-BUILT CABLE TRAY HANGERS. THE DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-11 REQUIRE THE USE OF THESE REDUCED PROPERTIES IN THE DESIGN VALIDATION OF CABLE TRAY HANGER TIERS TG ACCOUNT FOR THE PRESENCE OF BOTH USED AND UNUSED BOLT HOLES.

A14-3 1

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUDAPPEND1X A14 (GIR APPENDIX 14)

NON-CONFORMANCE WITH ATSC SPECIFICATIONS (CONTINUED) '

EXTERNAL SOURCE ISSUE:

D. DOUBLE ANGLE BRACES WERE DESIGNED AS COMPOSITE MEMBERS, BUT ADEQUATE FILLER PLATES WERE NOT PROVIDED.

E. DESIGN OF CABLE TRAY HANGERS USING SINGLE ANGLE BRACES DID NOT !

CONSIDER CONNECTION ECCENTRICITIES.

I ISSUE RESOLUTION / IMPLEMENTATION:

D.

THE DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-02 ALLOW DOUBLE ANGLE BRACES TO BE ANALYZED AS COMPOSITE MEMBERS ONLY IF THE REQUIREMENTS OF AISC SPECIFICATION SECTION 1.18.2.4 REGARDING INTERMITTENT FILLER PLATES ARE SATISFIED.

E.

SINGLE ANGLE BRACE CONNECTION ECCENTRICITIES HAVE BEEN CONSIDERE AS SPECIFIED IN THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, PI-02 AND ENGINEERING STUDY H-12.

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CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A14

-(GIR APPENDIX 14)

NON-CONFORMANCE WITH AISC SPECIFICATIONS  :

. (CONTINUED)

EXTERNAL SOURCE ISSUE:

F. OVERSIZED BOLT HOLES WERE USED FOR ANCHOR BOLTS AND TRAY CLAMPS WITHOUT ADEQUATE JUSTIFICATION.

ISSUE RESOLUTION / IMPLEMENTATION:

F. FOR STEEL TO CONCRETE CONNECTIONS, AISC BOLT HOLE R Q'IREMENTS ARE NOT APPLICABLE (AISC LETTER TO L. D. NACE DATED AUGUST 24, 1986). THE EFFECTS OF BOLT HOLE SIZES WERE EVALUATED THROUGH t ANALYTICAL STUDIES (EBASCO POSITION PAPER "EFFECTS OF BOLT HOLE OVERSIZE IN CTH SYSTEM AND CONDUIT SYSTEM ADEQUACY VOLUME I, BOOK

22. STEEL TO CONCRETE CONNECTIONS WITH THE EXISTING HOLES WERE CONCLUDED TO BE ACCEPTABLE.

FOR CLAMP CONNECTIONS, WHICH INCLUDE COLD FORMED COMPONENTS, THE AISI CODE IS APPLICABLE. IN ADD 1 TION, COLD FORMED STEEL COMPONENTS ARE NOT GOVERNED BY AISC. AISI ALLOWS TESTING AS A MEANS OF ESTABLISHING CAPACITIES /ALLOWABLES. CABLE TRAY CLAMP CONNECTION CAPACITIES WERE ESTABLISHED BASED ON TESTS WHICH INCLUDED APPROPRIATE CONSIDERATION OF HOLE SIZE (CCL REPORT NOS.

A-717-86, A-721-86 AND A-743-87).

FOR CONNECTIONS BETWEEN STRUCTURAL STEEL MEMBERS, TO ENSURE COMPLIANCE WITH AISC CODE, APPROPRIATE CORRECTIVE ACTION IS BEING

! TAKEN IN THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM.

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CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A14

-(GIR APPENDIX 14)

NON-CONFORMANCE WITH AISC SPECIFICATIONS l (CONTINUED)  !

EXTERNAL SOURCE ISSUE:

G. LONGITUDINAL BRACES MAY HAVE BEEN IMPROPERLY DESIGNED FOR COMPRESSIVE STRESS AS A SECONDARY MEMBER.

H.

CABLE TRAY HANGER MEMBERS, SUBJECTED TO AXIAL AND FLEXURAL LOADS,  !

MAY NOT HAVE BEEN PROPERLY EVALUATED IN ACCORDANCE WITH EQUATION f

1.6-1A 0F THE AISC SPECIFICATION. i ISSUE RESOLUTION / IMPLEMENTATION:

G.  !

ALL BRACING MEMBERS ARE DESIGN VALIDATED USING AISC SPECIFIC {

PRIMARY MEMBER STRESS ALLOWABLES AS SPECIFIED IN DESIGN I VALIDATION PROCEDURES SAG.CP34 AND PI-03. '

H. MEMBERS SUBJECTED TO AXIAL AND BENDING LOADS ARE EVALUATED IN ACCORDANCE WITH EQUATION 1.6-1A 0F THE AISC SPECIFICATION USING A i CONSERVATIVE COMBINATION OF COEFFICIENTS.

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CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A15

_(GIR APPENDIX 15)

MEMBER SUBSTITUTION EXTERNAL SOURCE ISSUE:

THE ORIGINAL CABLE TRAY HANGER INSTALLATION SPECIFICATION ALLOWED THE ,

SUBSTITUTION OF A STRUCTURAL MEMBER WITH LOWER SECTION MODULI THAN THE MEMBERS SPECIFIED BY THE DESIGN. DOCUMENTATION OF MEMBER SUBSTITUTIONS WAS INADEQUATE.

ISSUE RES01.UTION/ IMPLEMENTATION:

THE CABLE TRAY HANGER DESIGN VALIDATION PROCEDURES SAG.CP34 AND PI-11 REQUIRE THE USE OF AS-BUILT MEMBER SIZES FOR DESIGN VALIDATION.

MEMBER SUBSTITUTION PERMITTED BY THE ORIGINAL DESIGN WHICH MAY HAVE RESULTED IN LOWER SECTION MODULI WAS CONSIDERED IN DESIGN VALIDATION WHERE NECESSARY.

i A15-1 T

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t CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A16 (GIR APPENDIX 16)

,. WELD DESIGN AND SPECIFICATIONS EXTERNAL SOURCE ISSUE:

A. THE ORIGINAL DESIGN DRAWINGS FOR SEVERAL CABLE TRAY HANGERS DID NOT PROVIDE WELD DETAILS.

B.

WELD SIZES SHOWN ON THE ORIGINAL ASSEMBLY DRAWINGS DIFFERED FROM THOSE ON THE DESIGN DRAWINGS AND THOSE IN THE ORIGINAL WELD CALCULATIONS.

ISSUE RESOLUTION / IMPLEMENTATION A,B. THE DESIGN VALIDATION OF CABLE TRAY HANGER WELDS WAS PERFORMED USING AS-BUILT WELD DATA AS REQUIRED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, AND PI-03. AS-BUILT HANGER DRAWINGS, WHICH INCLUDE WELD DETAILS, HAVE BEEN DEVELOPED FOR EACH CABLE TRAY HANGER.

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l' CABLE TRAYS AND CABLE TRAY HANGERS  !

SUBAPPENDIX A16 s

(GIR APPENDIX 16) i

.. WELD DESIGN AND SPECIFICATIONS ',

(CONTINUED)

EXTERNAL SOURCE ISSUE:

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C. ECCENTRICITIES WERE NOT CONSIDERED IN THE ORIGINAL DESIGN OF WELDED CONNECTIONS. ,

r ISSUE RESOLUTION / IMPLEMENTATION:

1 C.

THE EFFECTS OF ECCENTRIC LOADS ON WELDS ARE CONSIDERED IN DESIGN f VALIDATION USING AS Bu!LT DATA AS REQUIRED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34 AND PI-03.

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CABLE TRAYS AND CABLE TRAY HANGERS SUBAPPENDIX A16 (GIR APPENDIX 16)

,. WELD DESIGN AND SPECIFICATIONS  !

(CONTINUED)

EXTERNAL SOURCE ISSUE: .

D. BASE METAL THICKNESS OF CONNECTED MEMBERS WAS NOT CONSIDERED IN THE. ORIGINAL WELD D' SIGNS. SPECIFIC DESIGNS MAY HAVE CONSIDERED l EXCESSIVE WELD THROAT. '

ISSUE RESOLUTION / IMPLEMENTATION:

i D. THE DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34 AND PI-03 REQUIRE THE ASSESSMENT OF THE AS-BUILT WELD AND BASE METAL  !

THICKNESS IN ACCORDANCE WITH THE AISC SPECIFICATION. I l

1 9

A16-3

l l-CABLE TRAYS AND CABLE TRAY HANGERS SUBAPPENDIX A16

_(GIR APPENDIX 16)

WELD DESIGN AND SPECIFICATIONS (CONTINUED)

EXTERNAL SOURCE ISSUE:

E. THE ORIGINAL DESIGN CALCULATIONS ASSUMED AN INCORRECT MINIMUM WELD LENGTH FOR BEAM / HANGER BASE ANGLE CONNECTION BECAUSE THE RADIUS OF THE ANGLE LEG WAS NEGLECTED.

ISSUE RESOLUTION / IMPLEMENTATION:

E. THE DESIGN VALIDATION OF CABLE TRAY HANGER WELDS WAS PERFORMED USING AS-BUILT WELD LENGTH DATA AS REQUIRED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, AND PI-03.

l 4

A16-4 I

4

- 1 CABLE TRAYS AND CABLE TRAY HANGERS i

. SUBAPPENDIX A16

-(GIR APPENDIX 16) ,

WELD DESIGN AND SPECIFICATIONS (CONTINUED)

EXTERNAL SOURCE ISSUE:

F. SEVERAL CABLE TRAY HANGERS WERE FOUND TO HAVE WELDS WHICH VIOLATED THE MINIMUM WELD SIZE REQUIREMENT AS SPECIFIED BY THE AISC SPECIFICATION.

ISSUE RESOLUTION / IMPLEMENTATION:

F.

WELDING PROCEDURES WHICH PRODUCED THE WELDS IN QUESTION HAVE BEEN QUALIFIED IN ACCORDANCE WITH AWS D1.1 SECTION 5.2, AS DIRECTED BY AISC SECTION 1.17.2.

1 ALL WELDS WERE CHECKED FOR COMPLIANCE WITH AISC STRESS ALLOWABLE BASED ON ACTUAL LOADS AND ACTUAL WELD SIZE.

1 NO CREDIT IS TAKEN FOR STRUCTURAL FILLET WELDS LESS THAN 1/6".

1 i

i A16-5 l

l

CABLE TRAYS AND CABLE TRAY HANGERS SUBAPPENDIX A16

-(GIR APPENDIX 16)

,. WELD DESIGN AND SPECIFICATIONS (CONTINUED)

EXTERNAL SOURCE ISSUE:

G. SEVERAL CABLE TRAY HANGER DESIGNS EMPLOYED COMPOSITE SECTIONS JOINED USING INTERMITTENT FILLET WELDS WHICH WERE NOT EVALUATED IN THE ORIGINAL DESIGN CALCULATIONS.

ISSUE RESOLUTION / IMPLEMENTATION:

G. INTERMITTENT FILLET WELDS CONNECTING COMPONENTS OF A COMPOSITE SECTION, ARE DESIGN VALIDATED USING AS-BUILT WELD DATA AS SPECIFIED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34 AND PI-03.

I A16-6

CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A16 JGIR-APPENDIX A16)

WELD DESIGN AND SPECIFICATIONS 1

t' J

INTERMITTENT FILLET WELOS NOT EVALUATED IN ORIGINAL DESIGN C l

i FIGURE FOR A16.G 1

I CABLE TRAYS AND CABLE TRAY HANGERS SUBAPPENDIX A16 (GIR APPENDIX 16)

,. WELD DESIGN AND SPECIFICATIONS (CONTINUED)

EXTERNAL SOURCE ISSUE:

i H. ORIGINAL CABLE TRAY HANGER DESIGN CALCULATIONS DID NOT EVALUATE l THE. WELDS USED TO ATTACH BASE ANGLES TO EMBEDDED PLATES.

ISSUE RESOLUTION / IMPLEMENTATION:

{

H. WELDS BETWEEN BASE ANGLES AND EMBEDDED PLATES HAVE BEEN DESIGN VALIDATED USING AS-BUILT WELD DATA AS SPECIFIED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34 AND PI-03.

1 1

A16-7

. , _ _ _ -m _ - ,_ , ._

CABLE TRAYS AND CABLE TRAY HANGERS

. SUBAPPENDIX A16 (GIR APPENDIX 16)

^

WELD DESIGN AND SPECIFICATIONS (CONTINUED)

EXTERNAL SOURCE ISSUE:

I.

THE CABLE TRAY HANGER CALCULATIONS EVALUATED PARTIAL PENETRATION GROOVE WELDS USING PREQUALIFIED WELD TESTS THAT MAY NOT BE REPRESENTATIVE OF AS-BUILT CONDITIONS.

ISSUE RESOLilTION/ IMPLEMENTATION:

I. BASED ON A PHYSICAL EXAMINATION OF THE CONFIGURATION, THE PREQUALIFIED WELD TESTS USED IN THE EVALUATION OF PARTIAL PENETRATION GROOVE WELDS ARE REPRESENTATIVE OF AS-BUILT CONDITIONS.

A16-8

l l ,

CABLE TRAY AND CABLE TRAY NANGERS PSR SUBAPPENDIX A16 (GIR APPENDIX 'A16)

WELD DESIGN AND SPECIFICATIONS

-4

%- m 60 4

, O' TO N s1 g = 30 To60 l

1

,O'TOEb FIGURE FOR A16 I

l I

CABLE TRAYS AND CABLE TRAY HANGERS i

.PSR SUBAPPENDIX A17  !

(GIR APPENDIX 17)  !

EMBEDDED PLATE DESIGN  !

i i

EXTERNAL SOURCE ISSUE:

THE FOLLOWING CONCERNS WERE RAISED ON THE ORIGINAL EMBEDDED PLATE DESIGN:

0 EFFECT OF PRYING ACTION ON TENSION IN NELSON STUDS MAY NOT HAVE !

BEEN CONSIDERED.

O PIPE SUPPORT DESIGNERS AND CABLE TRAY SUPPORT DESIGNERS USED INCONSISTENT DESIGN PRACTICES ON STIFFENING OF MOMENT ATTACHMENTS  !

TO EMBEDDED PLATES. I O DESIGN CALCULATIONS FOR SUPPORTS ATTACHED TO EMBEDDED PLATES DID NOT CONSIDER CAPACITY REDUCTIONS GIVEN IN DESIGN SPECIFICATIONS FOR SPECIFIC LOCATIONS.

O INSPECTION PROCEDURES FOR SUPPORTS DID NOT REQUIRE A CHECK OF ATTACHMENT SEPARATION.

O SOME SUPPORT ANCHORAGE DETAILS MAY RESIST LOADS FROM LARGER TRIBUTARY TRAY SPANS THAN WERE ASSUMED IN DESIGN CALCULATIONS.

O DESIGN SPEC & ICATIONS DID NOT ADDRESS MINIMUM SPACING FOR HILTI j EXPANSION ANCHORS INSTALLED ON CONCRETE SURFACES PERPENDICULAR TO EMBEDDED PLATES.

A17-1

t 1 1

i. 1 I

CABLE TRAYS AND CABLE TRAY HANGERS l

.PSR SUBAPPENDIX A17 (GIR APPENDIX 17)

.. EMBEDDED PLATE DESIGN l

(CONTINUED) l l

ISSUE RESOLUTION / IMPLEMENTATION: I l

THE DESIGN ADEQUACY OF THE EMBEDDED PLATES IS BEING EVALUATED AS PART OF THE CPSES CIVIL / STRUCTURAL CORRECTIVE ACTION PROGRAM (CAP). THE CABLE TRAY HANGER LOADS ON EMBEDDED PLATES ARE BEING TRANSMITTED TO SWEC (LEAD CONTRACTOR FOR THE CIVIL / STRUCTURAL CAP) FOR VALIDATION OF THE EMBEDDED PLATES.

l l

l

~

e A17-2

l l

CABLE TRAYS AND CABLE TRAY HANGERS PSR SUBAPPENDIX A18  !

(GIR APPENDIX 18) l

.- TRAY CLAMP EXTERNAL SOURCE ISSUE:

ORIGINAL DESIGN MAY HAVE INCLUDED UNJUSTIFIED ASSUMPTIONS REGARDING ROTATIONAL AND DISPLACEMENT CONNECTIV7.TY BETWEEN TRAYS AND SUPPORTS.

SPECIFIC ASSUMPTIONS WERE THE FOLLOWING:

O CABLE TRAYS PROVIDE OUT-OF-PLANE BRACING TO CABLE TRAY HANGERS.

O CABLE TRAYS PROVIDE LATERAL BRACING TO THE HANGE3 TIER (BEAM)

COMPRF.SSION FLANGE.

O CABLE TRAYS PROVIDE MOMENT RESISTANCE CAPABILITY BETWEEN THE TRAYS AND THE TIERS. .

ISSUE RESOLUTION / IMPLEMENTATION:

0 FULL CONNECTIVITY WAS CONFIRMED THROUGH A FULL SCALE TESTING PROGRAM, DONE BY ANCO, AND ASSOCIATED ANALYTICAL CORRELATION STUDIES, REPORT 09-0210-0017 AND CALCULATION M-28.

0 ENGINEERING STUDIES, M-10 AND M-19 DEVELOPED THE METHODOLOGY FOR MODELING CABLE TRAY TO HANGER CONNECTIVITY.

0 CABLE TRAYS ARE NOT ASSUMED TO PROVIDE LATERAL BRACING TO THE HANGER TIER COMPRESSION FLANGE.

A18-1  ;

t  !

L. __. _. _ _ _ _ --

! l I

4 CABLE TRAY AND CABLE TRAY HANGERS PSR SUBAPPENDIX A18 (GIR APPENDIX 18)

TRAY CLAMP TWICAL TRAY CLAhr am its SIL753 TO TI M /

7IM

/ ,w f s

/ /

FMICT1CN TYPE CLA&P (LAOCER 80TTOW TRAYS CPLY)

Ki?'*

g = m.no

'4)

~ '

/

i -

lTr.

/ -

j LONG!TU31NAL TYPE CLA&P m., . , . . . , , - - , . ,-_-r..,,,---.,,,- - - - , -,- ,,--,,e.

,,g- ,, ,--,,,n.., _ _ , , - ,._,,,,----.,_-_,,_..,---,--._,-.,,,,.-.m,.., __,..e_,,,-

1 i

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A19 (GIR APPENDIX 19) l FSAR LOAD COMBINATIONS 1

EXTERNAL SOURCE ISSUE:

LOCA ASSOCIATED LOADS WERE NOT CONSIDERED IN THE ORIGINAL CABLE TRAY SUPPORT DESIGNS.

ISSUE RESOLUTION / IMPLEMENTATION:

LOCA PIPE WHIP AND JET IMPINGEMENT LOADS ARE ADDRESSED BY THE CPSES SYSTEM INTERACTION PORTION OF THE CORRECTIVE ACTION P ROG RAM.

ALL SAFETY RELATED CABLE TRAYS AND CABLE TRAY HANGERS IDENTIFIED AS PIPE WHIP OR JET IMPINGEMENT TARGETS HAVE EITHER BEEN RELOCATED OR SHIELDED FROM THE PIPE WHIP AND JET IMPINGEMENT LOAD.

THE EFFECTS OF ACCIDENT THERMAL LOADS WERE CONSIDERED IN A DETAILED ENGINEERING STUDY, M-27. RESULTS SHOWED THAT CABLE TRAY HANGER SYSTEMS INCLUDING THEIR ANCHORAGES ARE SUFFICIENTLY DUCTILE TO ACCOMMODATE ACCIDENT THERMAL DISPLACEMENTS WITHOUT REDUCTION IN SEISMIC LOAD RESISTANCE OR LOSS OF FUNCTION.

e A19-1

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A20 (GIR APPENDIX 20)

DIFFERENCES BETWEEN INSTALLATION AND DESIGN / CONSTRUCTION j DRAWINGS WITHOUT APPROPRIATE DOCUMENTATION i

EXTERNAL SOURCE ISSUE:

0 UNDOCUMENTED DISCREPANCIES BETWEEN AS-BUILT AND AS-DESIGNED CABLE I TRAY CONFIGURATIONS WERE IDENTIFIED.

O INSTANCES OF VIOLATION OF SEPARATION / CLEARANCE REQUIREMENTS BETWEEN CABLE TRAY SYSTEMS AND OTHER COMPONENTS WERE IDENTIFIED.

O IN CERTAIN INSTANCES, ANCHORS WERE INSTALLED IN CONCRETE WITH 2-INCH THICK TOPPING. SINCE THE TOPPING INTEGRITY CANNOT BE ASSURED, THE EFFECT OF REDUCED EMBEDMENT MUST BE CONSIDERED.

e A20-1

l .

l CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A20 (GIR APPENDIX 20)

DIFFERENCES BETWEEN INSTALLATION AND DESIGN / CONSTRUCTION DRAWINGS WITHOUT APPROPRIATE DOCUMENTATION (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION 0 CABLE TRAY AND CABLE TRAY HANGER DESIGN VALIDATION WAS BASED ON AS-BUILT INFORMATION COLLECTED PER FIELD VERIFICATION METHODS FVM-001, 003, 019, 036, 048, 050, 084, 098 AND 100: THEREFORE, THEIR UNDOCUMENTED DISCREPANCIES ARE ELIMINATED.

O CLEARANCE REQUIREMENTS BETWEEN CABLE TRAY SYSTEMS AND OTHER COMMODITIES ARE BEING ADDRESSED BY SWEC IN THE MECHANICAL CORRECTIVE ACTION PROGRAM (CAP) UNDER THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP). CLEARANCE DISCREPANCIES IDENTIFIED FOR CABLE TRAY AND CABLE TRAY HANGERS WILL BE RESOLVED BY IMPELL/EBASCO.  !

0 DESIGN VALIDATION PROCEDURE SAG.CP34 AND PI-07 REQUIRES A 2-INCH REDUCTION OF BOLT EMBEDMENT LENGTH FOR ANCHORS MOUNTED IN CONCRETE WITH TOPPING. ANCHOR BOLTS EMBEDDED ONLY'IN CONCRETE TOPPING AND THOSE THAT DO NOT MEET THE ANCHOR BOLT ACCEPTANCE CRITERIA ARE BEING REPLACED.

A20-2 n ,, ._ , _ _ _ - . _ _ _ . - -

1 CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A21 (GIR APPENDIX 21)

DESIGN CONTROL EXTERNAL SOURCE ISSUE:

A, B, C, E, I. AS-BUILT INFORMATION WAS NOT PROPERLY CONSIDERED IN THE ORIGINAL EVALUATION OF CABLE TRAY HANGERS.

ISSUE RESOLUTION / IMPLEMENTATION A, B, C, E, I. CABLE TRAY AND CABLE TRAY HANGER DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, PI-02, AND PI-03 REQUIRE THE USE OF AS-8UILT INFORMATION AS DESIGN INPUT.

l l

A21-1 l

l l

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A21 (GIR APPENDIX 21)

DESIGN CONTROL (CONTINUED)

EXTERNAL SOURCE ISSUE:

D. THE ORIGINAL EVALUATION OF CABLE TRAY HANGERS DID NOT PROPERLY CONSIDER THE RELEVANT WEIGHTS OF THERMOLAG FIRE PROTECTION, CABLE TRAY COVERS AND SIDE RAIL EXTENSIONS. /

ISSUE RESOLUTION / IMPLEMENTATION:

D. THE WEIGHT OF THERMOLAG FIRE PROTECTION MATERIAL AND CABLE TRAY COVERS ARE CONSIDERED IN THE DESIGN VALIDATION OF CABLE TRAYS AND HANGERS AS SPECIFIED IN DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, SAG.CP34, AND PI-02. THE EFFECT OF SIDERAIL EXTENSIONS HAS BEEN ADDRESSED IN SAG.CP34 AND CALCULATION M-39.

4 A21-2

CABLE TRAYS AND CABLE TRAY HANGERS

. PSR SUBAPPENDIX A21 (GIR APPENDIX 21)

DESIGN CONTROL (CONTINUED)

EXTERNAL SOURCE ISSUE:

F, G.

CERTAIN ORIGINAL CABLE TRAY HANGER DESIGN CALCULATION SETS DID NOT PROPERLY ADDRESS DESIGN CHANGE NOTICES ISSUED AGAINST THE HANGER DESIGN AND CALCULATIONS WERE NOT ADEQUATELY CONTROLLED.

ISSUE RESOLUTION / IMPLEMENTATION:

F, G.

CABLE TRAY AND CABLE TRAY HANGER DESIGN VALIDATION PROCEDURES REQUIRE THAT CALCULATIONS AND DRAWINGS BE CONTROLLED IN ACCORDANCE WITH QUALITY ASSURANCE PROCEDURES (EBASCO MANUAL OF PROCEDURES FOR COMANCHE PEAK AND IMPELL QUALITY ASSURANCE MANUAL). PROCEDURES AS CONTAINED IN THE EBASCO MANUAL OF PROCEDURES FOR COMANCHE PEAK AND IMPELL INSTRUCTION PI-12 HAVE BEEN DEVELOPED TO CONTROL DESIGN CHANGES AND TO ASSURE THAT CABLE T's!AY AND CABLE TRAY HANGER MODIFICATIONS ARE INCORPORATED IN DESIGN CALCULATIONS.

0 A21-3

CABLE TRAYS AND CABLE TRAY HANGERS i

.PSR SUBAPPENDIX A21  !

(GIR APPENDIX 21)

DESIGN CONTROL (CONTINUED)

_EllE.RNAL SOURCE ISSUE:

1 H. ORIGINAL DESIGN CRITERIA WERE INADEQUATE TO ASSURE CONSISTENCY )

AND COMPLIANCE WITH THE FSAR AND THE APPROPRIATE EDITION OF AISC.

/

ISSUE RESOLUTION / IMPLEMENTATION:

H. CABLE TRAY AND CABLE TRAY HANGER DESIGN VALIDATION CRITERIA AND PROCEDURES (SAG.CP3, SAG.CP4, SAG.CP34, PI-02, AND PI-03) ARE CONSISTENT WITH THE REQUIREMENTS OF THE FSAR AND THE AISC SPECIFICATION. THEIR REQURIED USE ASSURES COMPLIANCE WITH '

LICENSING COMMITMENTS.

I l

l A21-4

[

- 4 - - - -- , , , - - , . . , - . ~ , - - - - - - . - - .- - - - -. .- - - _,-_.._ ,. . , , . , - . . . , . - , _ , , - , . - - -

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A22 (GIR APPENDIX 22)

DESIGN OF SUPPORT NO. 3136. DETAIL "5" DRAWING 2323-S-0905 EXTERNAL SOURCE ISSUE:

IN THE ORIGINAL DESIGN OF SUPPORT NO. 3136, WHICH IS EMBEDDED IN A l FIRE WALL, THE FOLLOWING DISCREPANCIES WERE NOTED:  !

O SUPPORT IS SEISMIC CATEGORY I WHILE FIRE WALL IS SEISMIC CATEGORY II. l 0

ERRORS WERE FOUND IN FINITE ELEMENT MODEL AND CALCULATIONS.

O TORNADO DEPRESSURIZATION LOADS WERE NOT CONSIDERED.

1 ISSUE RESOLUTION / IMPLEMENTATION:

l l

I CASES OF CABLE TRAY HANGERS ATTACHED TO SEISMIC CATEGORY II STRUCTU {

WERE IDENTIFIED AND EVALUATED ON A CASE-BY-CASE BASIS.

ORIGINAL DESIGN CALCULATIONS WERE NOT CONSIDERED IN DESIGN VALIDATIO STRUCTURAL ADEQUACY OF SEISMIC CATEGORY II STRUCTURES, INCLUDING TORNADO DEPRESSURIZATION LOAD EFFECTS, IS BEING ADDRESSED BY SWEC CIVIL / STRUCTURAL CORRECTIVE ACTION PROGRAM. CRITERIA REQUIRING THAT LOADS FROM CABLE TRAYS AND CABLE TRAY HANGERS ON SEISMIC CATEGORY II STRUCTURES BE REPORTED TO SWEC HAVE BEEN ESTABLISHED IN THE CABLE TRAY AND CABLE TRAY HANGER DESIGN BASIS DOCUMENT (DBD-CS-082).

A22-1 l

l

CABLE TRAYS AND CABLE TRAY HANGERS

.PSR SUBAPPENDIX A23 (GIR APPENDIX 23)

LOADING IN STRESS MODELS EXTERNAL SOURCE ISSUE:

THE FOLLOWING CONCERNS ON THE ORIGINAL COMPUTER PROGRAM "STRESS" MODELS USED FOR STANDARD (GENERIC) CABLE TRAY HANGER DESIGNS WERE NOTED:

0 APPLICATI0M OF TRAY LOADS DID NOT REFLECT ACTUAL TRAY LOCATIONS.

O THE DESIGN LOADS DID NOT CONSIDER TRAY SPAN INSTALLATION TOLERANCES PERMITTED BY THE DESIGN DRAWINGS.

O FRAME HEIGHTS DID NOT REFLECT THE DISTANCE TO THE TIER CENTROIDAL AXES.

ISSUE RESOLUTION / IMPLEMENTATION:

CABLE TRAY HANGER DESIGN VALIDATION PROCEDURES SAG.CP3, SAG.CP4, AND PI-02 REcu!RE THE USE OF AS-8UILT INFORMATION AS DESIGN INPUT WHICH INCLUDE:

0 ACTUAL TRAY LOCATION ON THE TIER 0 ACTUAL CABLE TRAY SPAN, AND 0

ACTUAL FRAME HEIGHTS ARE MODELED TO THE TIER CENTROIDAL AXES.

A23-1

)

l I

w

1 1 1

~O 2 3

4 3' .

6 7

8 9 TU ELECTRIC PUBLIC MEETING 10 11 December 17, 1987 12 13 14 I 15 VOLUME I 0F II 16 17 18 19 20 RECER'ED 21 DEC 2 31997 23 ,

hlLLIAM G. COUNSIL 24 25 Taken by: Carmen Gooden, CSR, RPR December 17-18, 1987 Carmen Gooden, CSR, RPR, Metro __429-5532_.

2 2 1 ERQCEED1NGS. l O 2 3 MR. COUNSIL: The meeting will come to order. This 4 is a meeting between TU Electric and representatives of the 5' Citizens Association for Sound Energy to discuss various 6 topics. Today it will be a continuation of a discussion that 7 we started in March of this year on pipe supports.

8 I'd like to welcome Juanita and Jerry Ellis here and 9 obviously Jack. Good to see you again. I'm glad you made it 10 out of Boston, 11 Before we start, following the format of the last 12 meeting, I would like to give you the opportunity to make any 13 opening statement that you would like to make, and in '

14 addition, obviously at the meeting you can interrupt at any 15 time and any closing statementt you would like to make.

16 Would you like to make any opening statements?

17 MRS. ELLIS: We appreciate very much the opportunity 18 of getting together in a less formal atmosphere like this, anc l

19 I'm hoping that this will help to narrow the issuas for 20 hearings eventually so that we can come to some understanding 21 on some of the issues. And I think this is very helpful. I 22 will emphasize, though, that this isn't intended to be a time I l

23 for decision. It's a, time for understanding and learning, anc l 24 I want to be sure that you understand it in that light.

25 I want to mention one thing that you probably are not Carmen Gooden, CSR, RPR, Metro 429-5532

3 1

1 aHare of. In the Project Status Reports for the pipe supports

() 2 and the piping there were references made several times to 3 CYGNA pipe sbpport Review Issues List, Revision 4, and 4 transmittal letter number 84056.120 dated September 18, 1987.

S' I Just got a letter yesterday dated December 15th from CYGNA 6 transmitting that particular document. I'm sure it is the 7 same document, though we don't have that particular number of 8 letter, number .120, but we do now have the document. And I 9 Just wanted you to be aware that Mr. Doyle has not had a 10 chance to read it or anything like that at all. So I don't 11 know if it Hill come up during the discussion or anything 12 today, but please keep that in mind, that he hasn't had a

{} 13 14 chance yet to read it.

to him today, I made a copy and have Just given it 15 MR. COUNSIL: Thank you, Juanita. We Here made 16 aHare that evidently through the mailing somehow CYGNA got 17 crossed. It Has on December 8th, and one of our supervisors 18 called and got it squared away. That's Why it came on the 19 15th. We apologize for the lateness, 20 MRS. ELLIS: We appreciate it.

21 MR. COUNSIL: I'd 1:.ke to noH turn it over to Larry 22 Nace to set the stage for how these next two or three days 23 Hill proceed, and the,n He'll go straight into the pipe 24 supports, l 0 25 MR. NACE: I, too, Hould like to welcome you back to l l

Carmen Gooden, CSR, RPR, Metro 429-5532

r 4

1 Dallas, for Jack, and Helcome CASE to this meeting.

() 2 What He basically have set up for the next two days 3 is an opport' unity to discuss as far as we can go, given the 4 time available, all 11 of the different scopes of work that S' make up the Corrective Action Program. It Hill be broken dowr 6 into basically three different groupings, the first grouping 7 being the pipe supports. Pipe supports, as you Hill see, 8 makes the transition from our March meeting where He Here 9 discussing essentially, I believe it Hcs, the 22 CASE issues 10 associated with large bore. What we intend to do today is go 11 on and talk about the entire large bore and small bore scopes '

12 of Hork and all the issues that Here associated during that '

13 period of time. l 14 FolloHing that first section of the presentation,  !

15 however long that takes, we would then go into a middle piece 16 of these tHo days, Hhich essentially is intended to give you 17 an opportunity to take an overall view of six of the different l

18 scopes of work, specifically civil / structural, mechanical, 19 electrical, instrumentation and controls, heating, ventilating 20 and air conditioning and equipment qualification.

21 For those s1X Hhat He had planned because of the time 22 limits here is kind of an overview of the program in Just a  !

i 23 quick showing, if you, Hill, of the issues as He know them '

24 todoy, given that the PSR is not yet issued. You will have or O 25 opportunity shortly to see those reports when they're L

i Carmen Gooden, CSR, RPR, Metro 429-5532 -

i

5 1 finalized. Then He'll come back later and talk the technical O 2 issues. 1f vou Hitt.

3 FolloHing that section, He then 90 into the third 4 part of the planned presentation which involves the cable tra)

, S' hangers and the two conduit support scopes of Work, With the 6 intent c' getting as for into those on a technical basis as He 7 have time in these two days. What we don't cover now He Hill, 8 of course, cover at the next opportunity.

9 I guess Hith no further statements I'll turn the 10 meeting noH over to Stone & Webster Engineering to start the 11 presentation of piping.

12 MR. SISKIN: Good afternoon. Just for the record let 13 me start off by introducing the people we have here. My name 14 1s Ed Siskin. I'm senior vice president of Stone & Webster '

15 and responsible for all activities on this project. I 16 To my immediate left He have Ron Klause Hho is the 17 project manager for the pipe stress and support effort. He is 18 also an engineering manager in our Cherry Hill office, has 22 l 19 years experience in this area and has worked on 15 plants.

20 To my immediate right is Alan Chan Who is the 21 assistant project manager for technical efforts. Dr. Chan is 22 assistant engineering manager in our Cherry Hill office. He l 23 has 24 years of exper,1ence and has worked on 24 plants in this 24 area.

O 25 To Ron's left is Fred Ogden Hho is the assistant Carmen Gooden, CSR, RPR, Metro 429-5532

6 l

1 project engineer and working with Alan on technical issues.

() 2 He has 14 years experience and has done similar work for 11 3 plants.

4 To his left is Wyn Evans who is the section manager 5' in pipe supports. He has 11 years experience, has worked on 6 10 plants.

7 And working the slides we have lead engineer Syed 8 Ali, who has also been working on the resolution of the 9 technical questions. He has 20 years experience and has 10 worked on nine plants.

11 With that immediate background, let me make a couple 12 of comments on what we're going to cover here today. When we 13 met in March, what we tried to do was to explain what had  ;

14 happened and where we stood with respect to the 22 specific 15 issues that CASE had raised. I think we went through a .

16 considerable amount of detail at that point on those issues.

17 We very explicity did not cover issues that were valid or had ,

18 been raised by other external sources.

19 I think we're basically at the point where except for ,

20 some remaining production work we've done the effort. So in i 1

21 orde.r to try to put this to bed right now, we thought it more 22 appropriate to cover all of the areas that anybody has raised 23 a question on concern,ing pipe stresses and supports on this  ;

24 project. That would encompass the 22 that were identified O 25 originally. There are a few additional items associated with l

Carmen Gooden, CSR, RPR, Metro 429-5532 i

7 1 those that He'll bring up, and then we'll identify and discuss

() 2 the resolution of the others as well.

3 We're pretty proud of the effort that He have 4 accomplished so far, and I think you will be able to see that 5' this is as safe and conservative an engineering effective 6 design as has been done for any plant.

7 With that background, let me make one more comment.

8 If there are any specific technical questions, hopefully He 9 can answer them as He 90, but if you have brought anything 4 l 10 with you that may require some research and if He can get then' 11 today and He don't have the information or people that we neet 12 to give you a satisfactory answer today, hopefully He can have l 13 it for you by tomorrow morning. I Hould like Hhen He're done

[

14 for you to feel comfortable that everything has been 15 addressed.

16 Now, one final comment before I turn it over to Ron.

17 The Hay we have done this is'in accordance with our practices, 18 our standards, things that we feel are necessary so that He 19 can stand up and tell anyone that this is a satisfactory Job.

20 There are many, many things that Here done to meet our 21 standards that are not being addressed here today. You have 22 seen our CPPP-7 documents which covers everything that He are 23 doing. There are man,y project memoranda that you have also 24 been provided, plus we have an ongoing training and quality O 25 assurance program to make sure that what He say He're doing l

. Carmen Gooden, CSR, RPR, Metro 429-5532

8 1 is, in fact, being done. And He haVe a technical review by

() 2 the best experts that we've got to make sure that there isn't 3 something th'at's not normally covered that He're not handling 4 properly to make sure that there are no surprises someplace.

S' With that, let me turn it over to Ron.

6 MR. KLAUSE: Thank you, Ed.

7 I'd like to call your attention to the first 8 overhead. This is in Hay of a graphic to try to focus on the 9 topics that we will be covering today, and this will bring us 10 from our discussion that He had in March right up to the 11 present time, as Ed had said, to cover all the issues that 12 have been identified in pipe supports.

{} 13 If you look at the slide you Hill see that in the 14 upper left-hand corner there's the 22 issues that you had 15 raised and presented in March. We're going to be revisiting 16 five of those issues today to bring you up to date on what 17 other concerns Here r.aised on those issues by others that Here 1

18 not present at the meeting in March.

19 We do this in the form of completeness for your i l

20 understanding and for your information.

1 21 The next block encompassed in this graphic is the l 22 Generic Issues Report that Hos issued back in June, I believe.

23 Revision 1, and this . formulated our original 33 generic 24 issues. Since that time two other notable documents have beer

  • ~ issued.

25 One is our Project Status Report, I believe of Hhich Carmen Gooden, CSR, RPR, Metro 429-5532_ ._. .__

9 1 you have a copy, both large bore and small bore, and the CPRT

() 2 DSAP IX Results Report.

3 Now', independently the CPRT had cataloged all the 4 findings, if you will, through their search of docket, and S' have cataloged the issues into not only our 33, but they 6 indeed captured two others that we will also be discussing 7 today. These are really not new issues, but in their way of 8 review and documentation for a number of DIR's that they have 9 found, 10 Also you will notice the last block is one other 11 issue that we chose to add as an issue, and that's the CPRT 12 quality of construction DR's that have been found against 13 piping and supports. We have taken those and evaluated them 14 for the effect upon our Corrective Action Program as far as 15 pipe supports and piping is concerned.

16 Now, you will notice in the right-hand column I have 17 a dimension line from top to bottom that says that our PSR has 18 39 subappendices. Please don't try to add the 33 plus 2 plus 19 1 because it doesn't add up to 39. But as I said, the issues l 20 have been formalized under different headings, but they are 21 indeed covered in the 39 suboppendices.

22 So I hope I haven't confused anybody with this, but I 23 wanted to make a one ,to-one correlation with these documents 24 with our issued Project Status Report. So you can go into O 25 that report now and do this one-to-one comparison.

Carmen Gooden, CSR, RPR, Metro 429-5532

10 1 The second slide is to focus in, for the specific O 2 discussions today. on tne Appendix A of our eSR ero;ect Status  :

I 5 Report, as H' ell as Appendix B which covers the Significant  !

4 Deficiency Analysis Reports for both large bore and small 5' bore.

6 And if you notice, we have our GIR's in the first 7 block. The GIR Rev 1 Hill be the last issue of this project 8 Generic Issues Report, and the issues that were identified in 9 that document Hill noH be Captured in Appendix A of the 10 Project Status Report, so any updates that may be required for 11 those Hill be incorporated into those large bore and small 12 bore Project Status Reports.

13 Then Appendix B Hill be the second part of our 14 discussion. As I said, He'll be talking about the Significant 15 Deviation Reports that have been addrassed in the performance 16 of our Corrective Action Program for pipe supports, 17 Further, to address the coverage of today's 18 discussions and to get more specific into the title, He 19 created a matrix to shoH you Which documents -- He Created 20 this document to show you what issues Here Covered in our 21 March meeting and what issues Hill be discussed in today's 22 meeting. You Hill notice, for instance, Al and A4 as an 5

23 example have an X bot,h in the March meeting and in the 24 December meeting. This is to revisit those to bring you up tc O 25 speed on what the other findings Here for that issue.

Carmen Gooden, CSR, RPR, Metro 429-5532

11 i l

1 So without any further ado, I would like to move

() 2 right into the first one, and that is the PSR Subappendix A1.

3 The'first one is PSR Subappendix A1. This 4 corresponds to our GIR Appendix A. The subject is Richmond S' inserts. Additional source concerns have been raised and 6 there are two. The first concerns the fatigue life of a 7 threaded rod or bolt. SA-36 material used for threaded rod ir

< Richmond inserts could experience fatigue failure due to the 9 high number of load cycles.

10 The second concern centers around the allcHable 11 spaciro of Richmond inserts. The concern was that Richmond 12 insert allowables should be reduced for close soccing.

{} 13 14 The next page covers our issue resolution and the implementation for these concerns. ASME and AISC define the 15 lower bound stress cycle value for consideration of fatigue as 16 20,000 cycles. SWEC has demonstrated that the number of 17 equipment stress cycles for pipe supports at Comanche Peak is 18 less than 7,000 cycles. Therefore, fatigue is not a relevant 19 concern.

20 For spacing SWEC is performing a walkdown to identify 21 Richmond insert spacing. This is covered under our Field 22 Verification Method 075 as far as our Post Construction 23 Hardware Validation P,rogram. This actual insert spacing will 24 be used to reduce allowable loads using the methodo10gy

() 25 contained in CPPP-7, Attachment 4-5.

I 1

l Carmen Gooden, CSR, RPR, Metro 429-5532

12 1 1 We're going to continue with the next topic, so as I

() 2 said, if you have any questions any time, feel free.

3 The'next is Subappendix A4, corresponds to GIR 4 Appendix P, subject Pipe Support / System Stability.

S' Additional external source concern raised against 6 this subject concerns column-strut stability. The concern is 7 that the stability, which is the allowable axial load of the 8 strut-column assembly, may not be adequately represented by 9 the buckling capacity of each member.

10 For the issue resolution and implementation, the 11 ecuations to evaluate the strut-column assembly critical 12 buckling load are provided in Section 4.2.4 and Attachment 4-9 13 of CPPP-7.

{

14 Do you have a question?

15 MR. D0YLE: No. I Just wanted to take a look at that 16 again. I don't have a question.

17 MR. KLAUSE: We have copies of our Project Design 18 Criteria. You're certainly welcome to look at'it and ask 19 questions.

20 MR. SISKIN: Mrs. Ellis, do you have copies of the 21 latest version of CPPP-7?

22 MRS. ELLIS: I didn't bring it with me.

23 MR. COUNSIL: ,

Would you like a copy right now?

24 MR. D0YLE: It would be helpful, r

25 Carmen Gooden, CSR, RPR, Metro 429-5532

13 1 MR. COUNSIL: We have it.

'( ) 2 MR SISKIN: I think it would be most effective if 3 while these ' questions are fresh in your mind if you look at 4 the book, so I Would encourage us to take pauses Wherever 5' appropriate so that you can look.

6 Before we resume on the specific issues, it might be 7 Worthwhile to make one additional point.

8 Before this meeting He did revieH What we said back 9 in March to see if there were any technical changes to Hhat we 10 did say, and He have confirmed that what He said in March 11 still applies.

12 MR. KLAUSE: Okay. The r. ext 1* sue -- i 13 MRS. ELLIS: Excuse me. We'll Just assume that

[

14 outomatically on all the others unless you tell us otherwise. '

15 MR. KLAUSE: The next issue is PSR Subappendix A14, f

16 corresponds to GIR Appendix N. The subject is OBE/SSE damping, t 17 The concern raised additionally on this issue was ,

, 18 that the damping values used in the original analysie were .

19 higher than the values in NRC Regulatory Guide 1.61 and 20 whether the proptr damping valuet He e used in the original 21 analysis of mixed size piping systems.

22 For the issue resolution, the design criteria CPPP-7

?3 limits damping values,to those listed in Regulatory Guide 1,61 24 or Code Case N-411. Incidentally, that use of Cods Case N-411 0 25 has been approved by the NRC for use on the docket.

l' Carmen Gooden, CSR, RPR, Metro 429-5532 , ._

14 1 The mixed size piping systems are conservatively

() 2 evaluated with the lower damping values of Reg Guide 1.61 wher 3 1,61 damping'is used in the analysis of the problem.

4 Page 3, Implementation. Reg'j;otory Guide . 61 and 5' Code Case N-411 damping values are speci' led in CPPP-7, 6 Section 3.4.5.4.1.

7 The proper use of damping values is a review item in 8 the pipe stress cnolysis checklists of CPPP-6 and CPPP-9, 9 Hhich is the 1.nplenienting procedure for our design criteria.

10 Now, the next slide. The title of this issue is 6

11 Programmatic Aspects and QA Including Iterative Design, PSR 12 Suboppendix A16, corresponds to GIR Appendix P.

{ 13 The additional external source concerns are as 14 follows:

15 First, the original calculations did not follow 16 project guidelines for quality assurance. No standards were 17 specified for the qualification of personnel at different 18 levels 19 Second: Problems which were generic in nature Here 20 not resolved promptly during the original design effort.

21 Third: The original procedures for constructicn and 22 installation were inadeauate and were not updated.

23 Four: Freau,ent chcnges and lack of adequate control 24 of the original procedures resulted in many violations of the 25 procedures.

Carmen Gooden, CSR, RPR, Metro 429-5532

15 1 Finally, in random checks of original calculations,

() 2 errors were found.

3 For'our resolution of this issue and the 4 implementation, all activities of the piping and pipe support 5' Corrective Action Program are performed in accordance Hith 6 SWEC's Quality Assurance (QA) Program, 7 SWEC's OA program includes the development of 8 procedures and design criteria covering the essentials of the 9 piping and pipe support validation process. Generic problems 10 are reviewed for reportability in accordanca with SWEC 11 Engineering Assurance Procedures and CPPP-19, 12 SWEC EA, Engineering Assurance, TV Electric Technical 13 Audit Program (TAP) and SWEC's Engineering Functional

{

14 Evaluation Program, EFE, audits evaluated the technical 15 adequacy of the engineering products such as calculations,  :

16 drawings and specifications.

17 Timely and complete responses are developed for every 18 item identified throughout the audit process, and appropriate 19 corrective and preventive action are taken whenever they are 20 required.

21 The next page. The followino list of audit subjects 22 describes the depth of the auditing being performed in the 23 performance of our co,rrective action:

24 The adequacy of the SWEC p?.pe stress analysis design O 25 procedures; the adequacy of tne SWEC pipe stress cnd support Carmen Gooden, CSRo RPR Metro 429-5532

16 1 project procedures; calculations, including technical O 2 odeauacy. as He11 cs eocumentation: eocument contro1:

3 indoctrinati'on and training; personnel qualification and 4 experience verification; system inputs to pipe stress and 3' support analysis; construction support activities;, and 6 compliance with the project procedures.

7 Stone & Webster pipe stress analysis and support has 8 reviewed and validated installation specifications and 9 reviewed the resulting inspection procedures to ensure 10 consistency Hith our engineering reCuirements, 11 MR. D0YLE: Could I ask for a clarification? I 12 believe the original culculations for the project guidelines I 13 understand it was specified for the cualifications of 14 personnel, 15 Can you kind of give a brief rundoHn on the 16 qualifications required by SWEC for the pipe support designer, 17 lead engineer, checker, revieHer, et Cetera?

18 MR, KLAUSE: Having been the division manager at one

.9 time, these are points Hell taken. We are concerned Hith the 20 quality of our people at various levels, 21 The first area you mentioned Has design, 22 The qualifications of designer are a high school 23 education, years of e,xperience, and that's a range of 24 experience because dacioners, as you know, carry a ,

( 25 multi-function, including print filers right on up to senior Ca Nea Cooden. CSR, RPR, Metro u?Q-R537

17 '

1 designers which do perform some calculations.

() 2 The engineer is a college graduate, or in the case of 3 our first level industry engineers, Hould be, I believe, it's 4 10 years, and quite lengthy experience.

S' ' For our principal engineers, lead engineers, it is a 5 degreed engineer as well as a minimum of five years of 7 experience.

8 What is the other one, Jack?

9 MR. D0YLE: Reviewer.

10 MR. KLAUSE: The independent reviewer is an engineer 11 and he has to have, again, five years experience as well as 12 review and receive the in-house training required for We have a program set up that they

'{) 13 independent revieHers.

14 essentially have to attend the lectures and I believe -- Alan, i

15 correct me if I'm wrong -- they're actually tested in this 16 procedure for independent reviewer?

17 MR CHAN: As part of the training course that He i 18 give.

I can add a little bit more on this since I have been c  ;

19 division manager more recently.

20 Since, I believe, in the early '80s, He paid special 21 attention to the calculation revieHer and He, like Ron said, 22 gave them a special training course and they also had to pass 23 as part of the traini,ng class a test at the end of the class.

24 But then they are classified slightly different from the other i O 25 production engineers in the sense that He do have a list of l

i Carmen Gooden, CSR, RPR, Metro 429-5532

18 1 Hhat He Call Qualified revieHers, and only these people Who

() 2 are identified on this list are qualified to sign off as 3 independent reviewers for the calculations.

4 So it is a smaller group of people, pipe stress and 5' pipe support engineers, who Hould be doing the reviewing.

6 It's not everybody who is doing calculations.

7 MR. D0YLE: Registration is not necessary, is it?

8 MR. CHAN: No, it is not a requirement.

9 MR. SISKIN: Although most do have registrations.

10 MR. D0YLE: I would assume so, but I was just tryins 11 to get on the record a rundown of the different qualification 12 levels.

13 MR. SISKIN: Now, one phrase that we've used that's 14 probably Horth defining also is division manager. Stone a 15 Webster engineering departments are broken down by 16 disciplines, and one of the disciplines is the Engineering 17 Mechanics Group. People that are doing pipe stress and 18 support work would be in this one division, And the division ,

19 manager and his technical staff have a number of very 7

20 important responsibilities, one of which is they are the home 21 and the administrative direction for the people in that 22 discipline. More importantly, they provide the technical  :

l 23 direction, the backup, the cost of technical overview of the i

24 performance of the people in that discipline regardless of l 25 Where they are.  !

Carmen Gooden, CSR, RPR, Metro 429-5532 _

19 1 So if a person is doing engineering mechanics work

() 2 and is a member of the engineering mechanics division, then 3 that divisio'n manager and his staff retain the responsibility l 4 for the quality of his Work regardless of what project he's 5' working on. And when the decision Has made to take on this 6 Job, obviously He Here going after the most capable people He 7 could find, and it turns out that the most capable people have 8 served time as the division manager of the engineering 9 mechanics division. So He have probably four former 10 engineering mechanics division managers involved in this 11 effort, including the project manager and the assistant 12 project manager.

13 MR. D0YLE: I have one other question.

{ Does Stone a 14 Webster at Comanche Peak folloH the same procedures that they 15 had in Boston? For example, Hhere they had a separate 16 engineering group and reduced the theoretical to the 17 empirical.

18 MR. SISKIN: Yes, and that's the responsibility of 19 the engineering assurance department to make sure that the 20 theoretical analyses are reduced to such a form that the 21 engineer clearly has a minimum amount of Judgment --

22 MR. D0YLE: That's the point. Another problem He 23 have here Has that en.gineering technical use by everybody, anc 24 I tried to make the point --

0 25 COURT REPORTER: I'm sorry, sir, but I can't hear Carmen Gonden, CSR, RPR, Metro 429-5532

20 1 you.

O 2 MR. D0vu: -- Hnetner or not tne Judgment was 3 controlled.~

4 MR. SISKIN: Very much so, and I think when you read 5' through CPPP-7 you'll find that that Has the basis for a lot 6 of that work to reduce the theoretical into a set of specific 7 rules that people would follow and not to have to exercise 8 very much Judgment on these things.

9 MR. D0YLE: And in the case where engineering 10 Judgment is used, it's Justified.

11 MR. SISKIN: Yes, 12 MR. KLAUSE: And documented.

13 MR. SISKIN: And documented.

l 14 MR. KLAUSE: These things are, in fact, revieHed by 15 division as well as the project and confirmed that, in fact, 16 it is acceptable implementation.

17 The last bullet on this appendix is 5WEC pipe stress 18 and supports reviewed the validated installation 19 specifications and reviewed the resulting inspection 20 procedures to assura consistency with our engineering 21 requirements.

22 PSR Subappendix A27, GIR Appendix AA, subject is 23 Helding. The additio,nal concerns raised against this subject:

24 First, the da.ign of Helded/ bolted connections:

25 No evidence was found that Helds on base plates attached to

~

Carmen Gooden, CSR, RPR, Metro 429-5532

21 1 the structure with combination of Helds and bolts Here

() 2 originally designed for the entire shear load in accordance 3 Hith ASME Se'ction III, Paragraph XVII-2442, 4 Improper Held Calculation for Composite sections:

5' The original design of the Held betHeen the cover plates and 6 the tube steel or wide flanges in composite sections Has 7 always correct, and not all the loads were considered.

8 Linear analysis: The qualification of base plate 9 Helds to linear analysis instead of plate-and-shell 10 requirements was questioned.

11 For the resolution of these concerns.

12 Welded / bolted connections: Welded / bolted connections

(} 13 are designed in accordance Hith Paragraph XVII-2442 of ASME 14 Section III per CPPP-7.

15 Weld calculation for composite sections: Cover plate 16 Helds are designed for all appropriate loads including shear 17 floH.

18 under linear analysis, ASME Section III, Subsection 19 NF-1230, alloHs the use of either plate-and-shell or linear 20 support rules for the design of Helds connecting linear and 21 plate-and-shell elements.

22 CPPP-7 Attachment 4-2 provides design guidance for 23 pipe support Helds fo,r these above subjects.

24 NoH, that concludes the coverage of the issues that O 25 He had raiseed back in March. We'll noH move on into the 9

Carmen Gooden, CSR, RPR, Metro 429-5532

22 1

l 1 additional sources, j

() 2 MR, D0YLE: I have one question. That first bullet 3 of the resolbtion says what you're doing, Was the concern an 4 adequate concern on the -- '

S' MR. XLAUSE: Yes, because there was not consistent 6 application.

7 MR. D0YLE: It's pretty hard to tell from some of the 8 statements.

9 MR. KLAUSE: These are more spelled out in our PSR.

10 These are kind of paraphrases of what's in there.

[

11 MRS. ELLIS: And I just want to mention that that's 12 the some kind of question that I would have on several of 13 these, but I'm not going to be asking many of them because I 14 want to take advantage of Jack being here as much as possible, 15 and I can talk to you guys some other time. But that doesn't .

16 mean we won't haVe any follow-up questions on some of these.

17 MR. XLAUSE: That's' fine. As I stated, these are 18 fleshed out in more detail in our PSR subappendix.

19 MR. D0YLE: I read the answer to that one already. ,

20 It's Just that there was no reference as to whether or not the particular concern was an accurate concern.

21 In other words, 22 from the statement CPPP-7 quickly tells me they're doing the 23 same thing that they Here already doing.

l 24 MR. KLAUSE: No. CPPP-7 are Stone & Webster 25 criteria, and we implement through procedures of -6 and -9.

l l

Carmen Gooden, CSR, RPR, Metro 4 2 9 - 5 5 3 2__ ____ _____ _ _ _ l

23 i

1 So no procedures that existed in the industry are followed for h 2 any part of our Corrective Action Program. '

l 3 MR.'D0YLE: Very good, l

4 MR. KLAUSE: I'd like to now introduce Alan Chan  ;

5' to cover the next area of issues, as I said, that Here not 6 addressed in the March meeting.

7 MR. CHAN: The next subject is on the PSR Subappendi) 8 A17 and A18 corresponding to our GIR Appendix 0 and P. And i 9 the subject is on high frequency mass participation and mass 10 point spacing.

11 The external source concerns are tHo, The first one 12 is the original pipe stress seismic analyses did not include 13 sufficient modes to comply Hith the FSAR requirement that the  !

14 inclusion of additional modes does not result in more than a  !

15 10-percent increase in the system response. 3 16 The second concern is the mass point spacing in the I 17 original analyses did not always meet the original project 18 criteria. 1 19 Issue resolution and implementation.

20 Mass participation: CPPP-7, Section 3.10.6.8, 21 establishes the folloHing tHo options for the seismic analysis

{

22 of piping and these two options Comply Hith NUREG/CR-1161, 23 The first op. tion: Seismic ARS modal analysis with 24 50-Hz cut-off frequency, including the missing mass 25 correction. And this option is built in the Stone & Webster Carmen Gooden, CSR, RPR, Metro 429-5532

24 :

1 NUPIPE computer program in Version 4, Level 2 or later. issue.

O 2 Tne secone s119nt1y more conservative option. atso 3 simpler, is t constant acceleration analysis by.using the 4 Zero-period acceleration values in-all three directions. i 5' These results are then combined with the 50-Hz ARS results l 6 that do not include the high-frequency missing mass 7 correction, by the square root of the sum of the saucres 8 method. I 9 On mass point spacing: Guidance for locating lumped  :

i 10 mass points in piping systems is included in Attachment 3-7 of  :

11 CPPP-7. l 12 Mass point spacing is a review item on the CPPP-6 13 and -9 pipe stress analysis checklists.

l 14 The next topic is PSR Subappendix A19, corresponds to 15 GIR Appendix S. The subject is fluid transients. '

16 The external source concern is the following: The 17 completeness of the fluid transient identification and the 18 adecuacy of fluid transient analyses in the original design i 19 effort were questioned.

20 Issue resolution ano implementation, 21 Fluid transients Here identified by SWEC as follows:

22 Using the guidance given in NUREG-0582. l 23 Based on pas,t experience with other PWR's of similar.

24 design. l O 25 And overall assessment of system flow and component l

I l

l Carmen Gooden, CSR, RPR, Metro 429"5532 ___ _ j

25 1 operating characteristics.

() 2 Specific fluid transients are identified and 3 summarized i'n CPPP-10, Attachment 1.

4 Stone & Webster NUPIPE computer program is used by 5' Stone & Webster for fluid transient anal. es. Guidance for 6 fluid transient analysis is provided in sPPP-7, Section 7 3.4.5.5, and Attachment 3-1.

8 The next topic is on PSR Suboppendix A25 for GIR 9 Appendix Y. The subject is on Fisher / Crosby valve modeling 10 and qualification.

11 Ths external source concerns are as follows:

12 First, the assumption of a 55/45 ratio to account for

{} 13 14 imbalanced bloHdoHD loads in the double ported Crosby safety relief valve Has questioned.

15 Second: Modeling of flexible valves -- and that 16 means valves of frequency less than 33 HZ -- in the original 17 analysis did not account for ycKe flexibility.

18 Third: Fisher volve operators may not have been 19 qualified to Hithstand the loads imposed on them by the valve 20 operator supports.

21 Four: Valve accelerations and flange loads Here not 22 alHays Checked in the original piping analysis.

23 I s s u e r e s o !. u.t i o n : Through discussions Hith Crosby 24 valve regarding the double ported SRV fl3H distribution, it O 25 was verified that the flow distribution is 50/50 inherent in ,

l 1

Carmen Gooden, CSR, RPR, Metro 429-5532

26 ,

t i-1 the design. However, for conservatism an imbalance of 10

() 2 percent is assumed, resulting in a 55/45 load distribution.

f i 3 The' yokes of flexible valves are modeled to properly l' 1

4 predict the valve assembly frequency. ,

S* SWEC evaluated the Fisher valve support concern and

. t 6 concurred with the requirements for interface control of  :

7 supported valve operators.

l 4

i l

8 Valve accelerations and flange loads are evaluated ir 9 the piping analysis.

l

! 10 Implementation: CPPP-7, Section 3.4.5.6, defines the 11 applicable analytical method for the design and analysis of 12 open discharge SRV piping systems. A 55/45 flow distribution

{} 13 between discharging branches is conservatively used. ,

14 CPPP-7, Section 3.10.6.5, addresses the proper valve 15 yoke modeling of flexible valves. i i '

i 16 Valve support loads are transmitted to the i

17 responsible organization for design acceptance evaluation in i 9 '

i 18 accordance with CPPP-6, Section 7.4.3, and CPPP-9, Section i

19 7.4.1.3. l 20 Valve accelerations and flange loadings are evaluated 21 in a.ccordance with CPPP-7, Section 3.10.5.2.

]

j 22 The next topic is on PSR Subappandix A26 or GIR a

23 Appendix Z.

24 The subject is on pipin) modeling.

25 The external concerns are the following:

Carmen Gooden, CSR, RPR, Metro 429-5532

27 t

1 A feH instances were found where incorrect inputs .

'() 2 Here used in the original pipe stress analysis as folloHs:

3 Imp.oper stress intensification factors Here used in

(

4 c stress problem. <

i 5' Fluid and insulation Heights Here not included for 6 volves and flanges.

7 Incorrect pipe Hall thickness Has used.

8 Issue resolution and implementation.

9 CPPP-7, Section 3.0, provides guidance for the proper  !

10 modeling of piping systems. <

11 CPPP-6 and -9 include checklists to assure that '

12 appropriate piping models are created and adequate review of ,

13 the input and output is performed.

14 Piping and support calculation inputs are prepared i 15 and reviewed in accordance with SWEC Engineering Assurance 1

16 Procedures. '

17 Personnel are trained in the use of the appropriate  !

r

! 18 procedures.

! 19 Audits of project activities performed by SWEC 20 Engineering Assurance, TO Electric Technical Audit Program and 21 Engineering Functional Evoluotion provide assurance that the 22 procedural requirements are met and that the Hork is 23 technically adequate.  :

24 MR. D0YLE: I have one question. On the first bullet  !

k' 25 of this it says, "a feH instances Here found..." A few ,

l Carmen Gooden, CSR, RPR, Metro 429-5532

28 ,

1 instances in how large a sample? Or do you have any idea?

O 2 MR. CsA": I do not nave tne data witn me.  ;

3 MR.'0GDEN: Jack, these particular items are taken 4 from the CYGNA RIL, and these are the occasions identified in i 5' the RIL. We did not look at how large a sample. They were 6 doing their Independent Assessment Program and reported their 7 results back. And we see these things reported to us and i 8 documented in the Rev 4 RIL. i 9 MR SISKIN: And, Jack, let me clarify one point.

10 These were reviewed not of our work but of original work on  !

11 this project.

12 MR. D0YLE: I'm aware of that. So actually you don't 13 know except it wasn't a large sample? i 14 MR. OGDEN: I'm not -- I think CYGNA would be in a 15 position to answer that. Their results are reflected in the (1 RIL, and that's just where we picked this up from; their 16 17 findings of their reviews.

18 MR. SISKIN: But from a practical standpoint, it 19 really doesn't make any difference how large a sample it was, 20 since we assumed that it was a point of Concern and addressed 21 it on all our work. 1 22 MR. D0YLE: Very good.

23 MR. KLAUSE: ,Now I would like to introduce Wyn Evans  !

24 to cover the next project.

O 25 MR. EVANS: This is PSR Suboppendix A28, which i

Carmen Gooden, CSR, RPR, Metro 429-5532 - ___

29 1 I corresponds to GIR Appendix BB, and the subject is anchor

() 2 bolts and embedment plates, 3 The'following concerns were raised regarding original 4 design.

S' The first was embedment plates. There are two 6 concerns.

7 The spacing of attachments on embedded plates was not 8 checked.

9 And no procedure for the design of stiffeners 10 required for moment connections to embedded plates was 11 provided.

12 Through-bolts: The loads from pipe supports

() 13 14 utilizing through-bolts were not transmitted to the structural discipline for acceptance, p

15 Base plate edge distance: The base plate edge 16 distance tolerance was noted as having the potential of ,

i 17 increasing plate stresses by 15 percent in certain support

^

18 configurations.

19 Continuing on with the concerns.

1 j 20 Anchor bolts /embedment length: Differences were

! 21 noted between anchor bolt embedment lengths shown on the 22 support drawings and those used in the calculations.

23 Anchor spacing violations: Instances were observed 24 where pipe sleeve penetrations existed close to support base

-) 25 plates but were not shown on the support drawings.

Carmen Gooden, CSR, RPR, Metro 429-5532

30 1 And several instances Here observed where Hilti-KHik

() 2 bolts were installed close to through-bolt base plates but 3 Here not shoWn on the support drawings.

4 On to the issue resolution and implementation.

S' We've lumped embedded plates and through-bolts 6 together for the first topic.

7 Embedment plate design and attachment spacing are 8 validated by SWEC civil / structural discipline.

9 Embedment plate, base plate, and through-bolt loads 10 are transmitted in accordance with CPPP-6 and CPPP-9 to SWEC 11 civil / structural discipline for evaluation.

12 Base plate edge distance: The Post Construction l

{} 13 HardHare Validation Program, PCHVP, validates the as-built 14 bose olnte bolt hole edge distances. i 15 Anchor bolt embedment length.

16 Validated anchor bolt embedment lengths are shown on 17 the pipe support draHings and are indeed used to validate pipe 18 support anchorage designs in accordance with CPPP-7, 19 Attachment 4-4.

20 Anchor spacing violations.

21 During PCHYP SWEC civil / structural discipline 10 22 identifies anchor bolts installed close to through-bolts and 23 pipe sleeve penetrati,ons.

24 The anchor spacing violations are evaluated in 25 accordance with CPPP-7, Attachment 4-4.

Carmen Gooden, CSR, RPR, Metro 429-5532

1 The next topic is component Qualification, which is l

0 2 coveree in esa suecaoeneix ^>o wnicn corresaones to ata 3 Appendix DD.-

4 The first external source concern has to do with 5' dynamic pipe movements in support designs.

6 Not all appropriate dynamic pipe movements were  !

7 included in the original support design checking frame 8 clearances, swing angles or spring travel.

9 Incorrect stondord component allowables.

10 Incorrect U-bolt allowables were used in the original 7 1

4 11 design of support RH-6-064-011-S22R.

i 12 Untightened locknuts on strut.

13 Untightened locknut on a strut support was 14 identified. The concern was that the strut may not function i

15 as designed.

i 16 Inverted snubbers.  ;

i 17 Four supports were identified in which the snubber I

18 unit was installed 180 degrees from the configuration shown or l l 19 the support drawing.

l l 20 On to issue resolution and implementation.

l 21 The first subject: Predicted pipe displacements for 22 011 design conditions are considered in the pipe support j 23 design validation in .accordance with CPPP-7, Section 4.2. -

l 24 Support No RH-1-064-011-S22R was a cinched U-bolt I

'O 25 support with a strut, It was redesigned in accordance with i

l

! . i Carmen Gooden, CSR, RPR, Metro 429-5532 '

32 1 CPPP-7, Section 4.2.5.1. Therefore, the question of U-bolt

() 2 alloHables becomes moot.

3 CPP'P-7, Section 4.1, requires verification of 4 component standard supports by comparison to vendor-supplied 3' load capacity data sheets or certified design report summaries 6 unless uniquely qualified by calculation.

7 Post Construction HardHare Validation Program 8 validates the proper hardHare installation, including locking 9 devices, through inspections performed in accordance Hith 10 field verification method CPE-SWEC-FVM-PS-081.

11 And lastly, an inverted snubber has no impact on the 12 function of a snubber.

13 MR. D0YLE: I have one question on that inverted 14 snubber. In an area of high condensate, don't they sometimes 15 use boots on those?

16 MR EVANS: I'm not aware of that.

17 MR, SISKIN: It's my recollection that the boots Here 18 used Hhen they Here using a nitrated hard facing in these 19 mechanical snubbers, and they felt that you had too much of a 20 chance of adverse corrosion in high humidity. I think for 21 about the last five or six years they pretty much eliminated 22 the use of that material, so you no longer have that problem.

23 That is a subject tha.t tends to be addressed in equipment

,, 24 Qualification and Has addressed in equipment Qualification, J 25 but it's not something He're particularly bringing up noH Carmen Gooden, CSR, RPR, Metro 429-5532

33 1 unless the vendor specifies that He ought to Horry about it.

() 2 And vendors do not specify that for these (inaudible).

3 I remember the boot, but that Has a good number of 4 years ago.

5' MR COUNSIL: Jack, in addition to that, by the 6 technical specifications issue to us from the Nuclear 7 Regulatory Commission, He are required to test at least 10 8 percent of all snubbers, each outage, complete the whole 9 testing program every 10 years. In addition to that, on a 10 room closecut or containment closecut, as the case may be, all 11 snubbers are inspected; not necessarily tested, but inspected.

12 If anything shoHs on a snubber, I assure you it is taken out, 13 tested. And I think you've seen some of that when you Here at 14 Millstone Station perhaps.

15 MR. D0YLE: Oh, yes, 16 MR. SISKIN: And one of the things you are going to 17 be inspecting during that is trace of corrosion products along 18 the sleeves there, and there's Hhere it Hill appear.

19 MR. EVANS: The next topic is computer verification 20 and use. It's covered in PSR Suboppendix A32, 21 There Has a concern as to the verification and use of 22 the following computer programs used for the original design.

23 The first pr,ogram is ADLPIPE Version 2C dated April 1 24 '77. It has to do Hith piping analysis.

O 25 The second one is FUB - II - base plate Qualification I

l l

Carmen Gooden, CSR, RPR, Metro 429-5532

=

34 1 program by ITT Grinnell.

() 2 And a corner and LADA base plate qualification

~

3 program.

4 The issue resolution and implementation of this 5' topic.

6 First, the computer programs listed have not been 7 used in the SWEC validation effort. The question, once again, 8 is kind of moot.

9 And SWEC computer programs are identified in CPPP-7, 10 Section 5.0.

11 And all SWEC computer programs are verified for 12 technical adequacy versions are controlled in accordance Hith SWEC QA requirements.

{ 13 14 MR, SISKIN: Not Just for this project but for all 15 SWEC technical computer programs.

16 MR. EVANS: In the Hay of introduction to the next 17 topic, Stone & Webster is part of the closing out, resolving 18 all the issues that Here raised, and performed a review of the 19 SSER's to see Hhether there Here any issues Contained Within 11 20 the SSER that related specifically to piping and pipe 21 supports. The next three topics Hill cover that review.

22 The first one to be mentioned Hill be SSER 8, which I 23 Hill go into. That c,orresponds to -- or it's covered in PSR

,_ 24 Subappendix A36 which corresponds to GIR Appendix EE, 25 The concern was that the concrete design strength of Carman Gooden, CSR, RPR, Metro 429-5532

35 1 safety-related concrete installed betHeen January of 1976 and

() 2 February of 1977 was questioned. Concrete strength is t 3 design input'for Richmond inserts and Hilti bolt allowables.

4 For the issue resolution SWEC civil / structural group 5' validated the design strength of the safety-related concrete 6 placed during the period in question, and they found it to be 7 at least 4,000 PSI. This was used as input to establish 8 Richmond insert and Hilti alloHables.

9 MR. D0YLE: I have one question. That also holds 10 true for through-bolting --

11 MR. EVANS: Any time you (Inaudible), yes; anything 12 that would be effective.

{} 13 MR. NACE: We'd like to take a break at this time, 14 and we can resume in 15 minutes.

15 (A break was taken.)

16 MR, NACE: The meeting will come back to order.

17 MR. SISKIN: Before we resume the individual items, 18 I'd like to provide a little bit of additional information on 19 on item He talked about before. We confirmed that in view of 20 the fact that there are no corrosible materials in the 21 pressure-bearing surfaces of snubbers, there is no need to go 22 through an equipment Qualification on them. It's a normal 23 maintenance and inspe.ction item. There's no specific 24 equipment Qualification on it.

D 25 MR, OGDEN: Continuing with our discussion of the Carmen Gooden, CSR, RPR, Metro 429-5532

36 1 SSER review performed by Stone & Webster, He also did revieH (h 2 SSER-10, and this is covered by Subappendix A37 Hhich 3 originally Hus GIR Appendix FF. We have coupled with it in 4 this presentation the topic of the hydrotest, S' seismic /nonseismic interface that are delineated separately ir 6 Subappendix A33 and A34. We did this because all those three 7 topics are really one topic. And A33 and A34 ore really 8 subissues or different ways to expound on some of the 9 bulletized issues contained in SSER-10.

t 10 The external source concerns are as follows:

11 Uncontrolled Held repairs by plus Helding on Cable 12 tray supports, pipe supports and base plates may affect the  ;

{) 13 structural integrity of the component.

14 The second concern is that the sequence of steps (

15 folloHed for the hydrostatic testing of the Unit Number 1, 16 Loop Number 1, main steam and feedwater lines may have 17 affected the integrity of the components.

18 The third concern is that the hydrotest loading 19 conditions were not properly considered in the original piping 20 analysis and support design.

21 Fourth: Type II skewed Helds. Type II skewed 22 Helds -- for classification here are attachments-to-pipe --

23 Type II skewed Helds ,on pipe supports may be undersized.

24 And the issue of seismic /nonseismic interface.

O 25 There's two subissues here. The first is that the seismic Carmen Gooden, CSR, RPR, Metro 429-5532

37 1 effects of nonseismic piping attached to safety-related piping

() 2 were not adeauately considered in the original design. I I

3 The'second area is for safety-related piping routed 4 betHeen seismic Category I buildings and nonseismic buildings.

S' There are really tHo points here. One is that the 6 piping Has not seismically isolated, and tHo, the postulated 7 failure of the nonseismic building Has not considered.

8 The issue resolution and implementation on topic of 9 uncontrolled plug Helds.

10 The CPRT Action Plan V.D., which is the NRC TRT Issue 11 V.D., the results report concluded that unauthor! zed plug Helc 12 repair did not compromise the structural integrity of the 13 components, and SWEC concurs Hith this conclusion.

}

14 The pipe support installation and inspection criteric l

15 have been revised to prohibit uncontrolled plug Held repairs. '

16 On the issue of the Unit Number 1, Loop Number 1, 17 main steam hydrostatic testing, the CPRT Action Plan V.E.,

18 which is NRC TRT Issue V.E., results reoort concluded that no  !

19 deleterious effects resulted from the postulated sequence of '

20 events associated Hith the Unit Number 1, Loop Number 1 main l 21 steam and feedHater line hydrostatic tests. Again, SWEC j 22 concurs Hith this conclusion.

l 23 Further, und,er this top 1C He should point out that 24 the construction procedure CPM-1.2 and SWEC PSAS procedure O 25 CPSP-30 require engineering evaluation of the installed piping Carmen Gooden, CSR, RPR, Metro 429-5532

38 1 and pipe support configurations, including the proper design j

() 2 of temporary supports prior to a hydrotest.

3 On the topic of hydrotest, piping and supports are 4 evaluated for hydrotest loading in accordance with CPPP-7, S' Section 3.6.2.4 and Section 4.7.2. ,

6 On the topic of Type II skeHed Helds on pipe r

7 supports, the Type II skeHed Helds in Question are typically 12 8 found at the Junction of pipes and trunnions. The CPRT Actior 9 Plan V.A. results report confirmed that inspection of such 10 Helds has been performed in accordance with piping and I 11 equipment installation inspection procedure QI-QAP-11.1-26, 12 and are acceptable. SWEC concurs that these Helds are t

{ 13 acceptable.

i 14 Furthermore, the fabrication and installation 15 inspection of safety class component supports procedure 16 QI-QAP-11.1-28 Has revised to include inspection procedures 17 where the subject skeHed Helds occurred in pipe supports.

18 By way of clarification, let me point out the 19 distinction betHeen the second and the third bullet. The ,

20 second bullet addresses the piping inspection procedure, 21 piping Helds. The third bullet addresses pipe support Helds, 22 and it's the pipe support inspection procedure. And He do 23 concur that the Helds,are acceptable, and CPRT action plan 24 V.A. results report through their investigation found out that

') 25 the Helds were inspected. Even though they were pipe support j Carmen Gooden, CSR, RPR, Metro 429-5532

39 1 Helds, they were indeed inspected, but not per pipe support

-( ) 2 procedure, but the piping installation inspection procedure.

3 But their investigation did pinpoint a need for an inspection 4 procedure, you knoH, inspection requirements in the pipe 5' support inspection procedure. And so that Has provided, and 6 that procedure is QI-0AP-11.1-28.

7 On the topic of seismic /nonseismic interface, the 8 design procedure for interface anchors is contained in 9 Attachment 4-10 of CPPP-7.

10 And tHo methods are used for the design validation of 11 safety-related piping attached to nonseismic piping.

  • 12 The first procedure is that a plastic hinge moment is 13 applied on the nonseismic side to the interface anchor.

[

14 The second option is that a portion of the piping anc 15 supports on the nonseismic side were seismically analyzed.

le The effect of the remaining portion of the nonseismic piping 17 is accounted for by the application of a plastic hinge moment.

18 Perhaps for clarity I should point out What plastic i 19 hinge moment is. If you take a pipe and subject it to 20 bending, the maximum load Hhen it becomes fully plastic due to 21 bending, that is the maximum moment that that pipe can 22 deliver. The Hhole section is plastic. So no matter What the 23 event down the stream,of this plastic hinge is causing the 24 postulated failure of that oipe, that pipe cannot deliver any  ;

) 25 more moment than the plastic moment.

i I

Carmen Gooden, CSR, RPR, Metro 429-5532 l

40 1 MR. D0YLE: I concur.

() 2 MR. OGDEN: Also the plastic hinge moment is applied 3 to the safety-related piping routed between seismic Category I 4 and nonseismic buildings.

S' MR. D0YLE: These are the ultimate anchors?

5 MR. 0GDEN: Yes. Continuing with our discussion of 7 the SSER reviews, He also revieHed SSER-11 and the external 8 source concern expressed here: The SSER-11 describes the NRC 9 staff TRT position c.1 the evaluation and resolution of 10 technical questions and allegations relating to the OA/0C 11 group.

12 The issues identified in SSER-11 that are related to 13 piping design are as follows, and there are four:

{"

14 First is the as-built inspection program.

15 The subtopics under this discussion:

16 SSER points out that there Has excess 1Ve snubber 17 spherical bearing clearance.

18 Missing strut and snubber load pin locking devices.

19 Pipe clamp halves Here not parallel.

20 Snubber adapter plate bolts were not fully engaged.

21 Hilti-KHik bolts Here installed Hith less than 22 minimum embedment.

23 There was ab,sence of locking devices for threaded 24 fasteners on NF supports.

25 s The second topic we bring forHard from SSER-11 is the Carmen Gooden, CSR. RPR, Metro 429-5532

41 l

1 1 solation anchor.  !

() 2 NoH, He ho\e already discussed that under our 3 discussion of SSEO 10. It happens to he a topic that's i

4 repeated in SSER-:'. I 5' Also, the main steam loop hydro again is repeated in 6 SSER-11, and He have covered that in our discussion under 7 SSER-10.

i 8 The fourth topic is the radial shrinkage of girth 9 Helds in thin-Hall stainless steel pipe, Hhich was that they 10 were not adequately considered in the anal! sis.

11 Under our issue resolution and implementation, the 12 as-built inspection program, He Hill have some discussion

[} 13 14 under the Subappendix A39.

shortly.

That discussion Hill come up 15 The isolation anchor Has discussed under Subappendix 16 A57 of SSER-10.

17 Main steam loop hydro He discussed also under 18 Subappendix A37 of SSER-10.

19 And the fourth topic, the effects of radial shrinkage 20 of girth Helds on the pipe stress analysis are analyzed in 21 acco.rdance with CPPP-7, Attachment 3-15.

22 In PSR Subapoendix A39 He discussed the CPRT quality 13 23 of construction actio,n plan VII.C, review of piping and pipe 24 supports.

O 25 Before He go into this, we realize that you do not Cermen Gooden, CSR, RPR, Metro 429-5532 _

42 1 yet have their results report, but He have.been advised that

() 2 you will be receiving it shortly.

3 MR.'COUNSIL: Shortly.

4 MR 0GDEN: So with that we would like to cover the S' highlights of the program, and I am sure when you receive it 6 there Hill be other things.

7 Definition of the issue.

8 Evaluation Research Corporation performed the quality 9 of construction action plan VII.C sample inspection of 10 safety-related components.

11 ERC inspection -- which is Evaluation Research 12 Corporation -- covered approximately 82,500 inspection points 13 for piping and pipe supports.

14 ERC evaluated the results and recommended corrective 15 action for the adverse trends and construction deviations.

16 The results are discussed in the CPRT action plan 17 VII.C results report.

13 On issue resolution and implementation the Post 19 Construction Hardware Validation Program addresses the CPRT 20 VII.C recommendations through the PSAS FVMs. The FVMs in l 21 ques. tion, subject FVMs, are the CPE-SWEC-FVM-PS-080 and 081, 22 and the SWEC mechanical PCHVP.

1 23 All safety-related pipe supports are being physically I 24 validated under the PCHVP program whether they are modified or 25 not. Now, as far as the referenced FVMs, it's our L

i Carmen Gooden, CSR, RPR, Metro 429-5532 1

43 1

1 understanding that you do hnve these FVMs and that you have

() 2 been provided with the attribute matrix from the PCHYP 3 program. -

4 MRS. ELLIS: The first part of that, I think, was 5' some of tne things that we Here provided Just recently, a big 6 stack of procedures and stuff, wasn't it? And the other was c 7 previous letter, I believe, that was from the NRC, I think --

8 MR. COUNSIL: It Has one of the series of letters 9 that came out after the July public meeting. I believe it was 10 issued in September --

11 MRS. ELLIS: Right. Under cover letter from, I 12 think, you to NRC.

13 MR. COUNSIL: Yes, ma'am. All the rest of them, as 14 He Committed to at the December 9th -- the prehearing 15 conference, whenever that Has.

16 MRS. ELLIS: November 2nd and 3rd.

17 MR. COUNSIL: November 2nd and 3rd. Time is flying.

18 At that meeting I committed to issue the PSR and give 19 you all references that were within the body, referenced in 20 the PSR. That included the field verification method 21 procedures. It included the QC inspection procedures, and any 22 revisions in specification, things of that nature. So we 23 gave you a complete package of everything that had to do with 24 that PSR, and I think also informed you what Hasn't in there.

O 25 MRS. ELLIS: That was one of -- that Has a big stack Carmen Gooden, CSR, RPR, Metro 429-5532

44 i

1 of stuff all at one time.

() 2 MR COUNSIL: It Has a biQ stack.

3 MRS', ELLIS: I think I knoH Which -- What the point 4 is.

S' MR. 0GDEN: PSR Subappendix A35 is titled other 6 issues.

7 TERA cataloged and provided to SWEC under CPRT 8 responsibilities 972 external source Discrepancy Issue 9 Reports, on DIRs, related to the original design.

10 MR. SISKIN: Let me interrupt with one thing.

11 We did not depend upon TERA for a list of all the external 12 1 sues that He felt He had to address. We did it

{) 13 independently. But in addition, He had this TERA report to 14 supplement our efforts as a second check.

15 MR. OGDEN: And all but 51 of these 972 DIRs Here 16 consolidated into the topics addressed in PSR Subappendix Al 17 through A34.

18 The remaining 51 DIRs are miscellaneous and minor 19 topics, 20 The issue resolution and implementation. SWEC  !

21 resolved the issue identified in each of the 51 DIRs by 22 referencing the applicable design or administrative procedure 7.3 that resolved each is, sue.

24 These 51 DIRs are considered closed by SWEC and TERA, 25 and these 51 DIRs, you do have the DSAP-9 report and this is t

Carmen Gooden, CSR, RPR, Metro 429-5532 1

45 1 Appendix B of the DSAP-9 report where TERA delineates each of

() 2 these 51 DIRs and their resolution, and pinpoints the 3 proceduras that would address the concern.

4 And they are satisfactorily closed.

5' MR. SISKIN: The next item is a direct outgrowth of 6 the discussions He had during our March meeting wherein it was 7 requested by CASE that He examine some of the Helds taken out 8 of the plant, destructively examine them and determine that 9 they are okay. We handled the selection of the Helds on a 10 random and an engineered basis, chose the sample completely 11 random and then He supplemented that over and above by saying, 12 Hell, what were the most critical ones that we did not move

{} 13 and what Hould be the ones that would be most difficult to do 14 and so on. So it was a statistically valid random sample 15 supplemented by an additional engineered evaluation, and He 16 have all these samples that we have taken. They Hill be 17 available at the site thece on Saturday so you can actually 18 look at them.

14 19 But let me ask Fred to go on with the results of the 20 review of What He did.

21 MR. 0GDEN: As Ed pointed out, during the March 22 meeting you presented a request that some Held Joints from 23 pipe supports removed,from Comanche Peak be examined to verify 24 Held quality.

()

I I 25 . In response to this, 341 macro specimens of sectional l

l l Carmen Gooden, CSR, RPR, Metro 429-5532

46 l

1 faces from 93 Comanche Peak pipe Held Joints selected from 67 I) 2 supports were independently examined by three SWEC Helding 3 specialists.'

4 And all 341 specimens were determined to be S' sufficiently strong to perform their design function.

6 MR. SISKIN: Let me clarify this. When He're talking 7 about pipe Helds. the Helds that we're referring to are 8 supports, not pipes.

9 MR. 0GDEN: Thank you.

10 MR. D0YLE: "Sufficiently strong." What were the 11 attributes being checked?

12 MR. OGDEN: The attributes being looked at would be 13 such things as slight inclusions, lack of fusion, porocity, 14 uncercut. I'd have to reference the -- I could look at some 15 notes and give you --

16 MR. D0YLE: Could you tell us if there was any wash 17 passes or --

18 MR. 0GDEN: My recollection of the faedback is that 19 it was --- you couldn't tell hoH many passes, but they could 20 tell that there was more than one. They were of sufficient 21 number.

22 I think Hhat's important is not the number of passes 23 when one looks at the,results of the study, but the fact that 24 one ends up Hith good metallurgically-sound Helds that do what O 25 the engineer is asking them to do. -

~'

Carmen Gooden, CSR, RPR, Metro

- 429__5532. - _ - - . -

47 I

1 MR. D0YLE: That's true.

O 2 MR. S1Sx1N: And tnose welds and the report of the 3 results will'be available for you on Satuiday.

4 "RS. ELLIS: Can I get a copy of that or will I neec 5' to ask for that in discovery?

6 MR. COUNSIL: I have no objections to giving you that 7 report at all, Mrs. Ellis, but I would like to read it first 8 myself.

9 MRS. ELLIS: That sounds fair enough.

10 MR. 0GDEN: Any more questions?

11 MRS. ELLIS: Maybe later.

12 MR. D0YLE: No. I have other questions but 11rse I 13 explained, they'll come along.

14 MR. SISKIN: Let me finish up the last part of our 15 presentation, and then He'll get into your questions. I'd 16 very much like to hear the questions.

17 The remaining pieces really related to What is i

18 reportable under 50.55.E and other NRC regulations, and we j 19 have talked about a variety of issues and concerns, but there 20 is an odditional facet. Some of these things have to be 21 reported to Nuclear Regulatory Commission as an error, and I 22 think it's important to summarize Hhat those were, both for 23 large bore and for sm.all bore and to define what was done as a 24 result.

25 Ron, do yGu want to --

Carraen Gooden_, CSRo RPR, M9tro 429-5532

48 1 MR. KLAUSE: As Ed stated, this covers the O 2 S1gnificant neficiency Ana1ysis aeport tnat s eeen identified 3 in Appendix B of our large bore and small bore report. The 4 purpose of this matrix is to identify the SDAR number, which S' report is found, and what appendix is associated with that 6 topic.

7 Before I get into a discussion of each one of the 8 appendices, I'd like to state that B2 I am not going to go 9 into too much detail on because that is the generic report 10 that covers the modifications that are being encountered with 11 our Corrective Action Program on pipe supports. As you 12 recall, that has - DAR cataloged the type of modifications 13 that are being moJe and since the extent of the modifications 14 Here many, this Has Considered reportable under the 15 requirements of 50.55E. So those are unique for both 1arge 16 bore and small bore supports. So I'll get into more detail 17 on the other suboppendices.

18 MR. SISKIN: In reality, everything He have talked 19 about in March and today has been the explanation of that. 1 20 MR. KLAUSE: That's right.

21 MRS. ELLIS: You're aHare this is one of the areas l 22 He're most interested in, obviously.

23 MR. KLAUSE: ,Subappendix Bl. This is found in our 24 PSR --

25 MR. NACE: Excuse me. I Hant to point out on the Carmen Gooden, CSR, RPR, Metro 429-5532

49 1 last slide that you looked at there is a typo in the title of  ;

() 2 the B1 appendix, "valves" should oe "value".

3 MR.'KLAUSE: PSR Subappendix B1 and associated SDAR 4 CP-86-33. Discussion of stiffness values for Class 1 stress 5' analysis.

6 Definition of the issue is that pipe support 7 stiffness values used in the original Westinghouse Class 1 8 analysis for Unit 1 Here based on the original pipe support 9 stiffness values. As a result of the SWEC Corrective Action 10 Program, the Class 1 pipe support stiffnass values were found 11 to be significantly different.

12 The issue resolution and implementation. Class 1

{} 13 pipe support stiffness values are calculated in accordance 14 Hith CPPP-7, Section 4.3.2.2, and transmitted to Westinghouse 15 in accordance With CPPP-6 and -9.  :

16 MR. D0YLE: What you did here is you have a problem i 17 Hith stiffness of pipe supports and you trace it down on the 18 evidence of potential problems as, for example, the Class 1. l 19 MR. KLAUSE: That's correct. j 20 The SWEC scope includes the qualification of the 21 Class 1 pipe supports. Westinghouse is responsible for the 1

22 Class 1 pipe analysis as the NSSS supplier. They have 23 reperformed that stre,ss analysis for that code class.

15 24 MR. D0YLE: SWEC also has the Class 1 pipe supports?

O 25 MR. KLAUSE: The pipe supports, yes, sir.

Carmen Gooden, CSR, RPR, Metro 429-5532 i

50 1 MR. SISKIN: Which obviously are an input to O 2 westingnouse s stress analysis so tnat when we came up with 3 new values f'or the support, it was necessary for Westinghouse 4 to redo their analysis.

S' It's very important to understand that we did not 6 Just take a specific raised issue and resolve that specific 7 raised issue. If there has a potential concern, we tried to 8 track down Wherever that might impact something and address it 9 everywhere.

10 MR. KLAUSE: The next: PSR Suboppendix B3, SDAR 11 CP-86-63, pipe support installations.

12 Definition of the issue is a broken cotter pin Has 13 identified on a snubber.

14 For the issue resolution and implementation, the Post 15 Construction Hardware Validation Program validated cotter pin 16 installations.

17 Rather brief, t 18 MR. D0YLE: Just as a point of interest, how would o l

19 cotter pin get broken? '

l 20 MR. KLAUSE: I'll offer an opinion. Certain 21 supports have been removed for reinspection at various times. l 22 To remove a support for inspection, you will have to bend the 23 cotter pin and remove.it, and if they put it back in and l 24 respread it, there is a possibility for it to eventually break I 25 after repeated dismantling and reassembling. '

j Carmen Gooden, CSR, RPR, Metro 429-5532

51 l

1 MR. D0YLE: Do you have a procedure now if you remove  ;

O 2 o cotter 91a vo" thro it o cv ooo aut o me oae 1a7 3 MR.'KLAUSE: I'm not sure of those details, but I dc 4 knoH that He are ensuring that When that support is finally 5' turned over that inspection is done. If there's a cotter pin 6 present, it Hill be inspected.

7 MR. COUNSIL: We are reinspecting. That's one of the 8 efforts for actual final closecut of all supports. We're 9 inspecting for locknuts, cotter pins, so forth. And, Jack, if 10 you get the opportunity to look at that attribute matrix 11 you'll find that. In addition to that, though, our normal 12 room closecut, let's say if you Here in operation, an outage, 13 that type of effort is done on a room closecut effort basis 14 also. It's Just common sense to do it, make sure everything 15 has been put back exactly like it should have been. Cotter 16 pins, locknuts, all those things are on those checklists.

17 MR. D0YLE: I think the point I was making, though, 1

18 is if the re-forming of a cotter pin would cause a breakage, 19 what's being done in the future to prevent this from 1

20 occurring?

21 MR COUNSIL: If you break a cotter pin, then you put 22 a new cotter pin in, but typically hhen He find missing Cotter 23 pins, He are quite certain some of these cotter pins are 24 removed during painting and didn't get put back. I can only O 25 give another opinion, too, that if I Here putting up a neH Carmen Gooden, CSR, RPR, Metro 429-5532

52 l

1 support and I didn't have a cotter pin, I might 90 to the one O 2 next door and put 11 in. 1 tninx I ve seen some of tnat. 100 3 but that's why os one of your last checks on supports you 90 4 back through and make sure all locknuts, cotter pins and so 5' forth are in place and correct.

6 MR. SISKIN: I think your concern is that you reuse c 7 cotter pin and it would break and it's not obvious, and t?.at's 8 not the case. If you bent it that one extra time so it 9 breaks, it's going to break right then and there and going to 10 be visible. As long as it's in there in one piece, it's going 11 to serve its required function.

12 MR. COUNSIL: Typically it Hill serve its required 13 function even if one of the legs is still left.

14 MR. D0YLE: It only requires one.

15 MR. COUNSIL: It only needs one.

16 MR SISKIN: But He Hould not accept it if one of 17 those broke --

18 MR. COUNSIL: I will commit to both legs on all 19 cotter pins.

20 MR. KLAUSE: Next, Subappendix B4, SDAR CP-86-67, 21 preoperational vibration test criteria.

22 Definition of the issue is the original 23 preoperational vibration test criteria contains stress 24 endurance limits, allowable deflections and piping system l O 25 flexibility formulas which may not have been accurate.

l l

Carmen Gooden, CSR, RPR, Metro 429-5532

53 i 1

1 THo test data points exceeded the deflection limits. '

() 2 And finally, measured deflection directions Here not 3 clearly iden'tified.

4 For the issue resolution and implementation, S' preoperational vibration testing will be performed in 6 accordance with CPPP-25 Unit 1 piping vibration test 7 procedure.

8 MRS. ELLIS: You said on that one reperformed?

9 MR COUNSIL: It's reperformed.

10 MR. KLAUSE: PSR Subappendix B5, SDAR CP-86-73, 11 ASME snubber attachment brackets.

12 Definition of the issue is 31 safety-related supports 13 were installed.with rear brackets Which may restrict snubber 14 swing angles.

15 For the issue resolution and implementation, all 16 safety-reited snubber rear brackets are inspected to assure nc 17 binding in accordance with field verification method 18 TNE-FVM-PS-038.

19 And construction procedure CP-CPM-9.10A and quality 20 control procedures CP-0AP-12.1 and QI-QAP-11.1-28 require a 21 check for binding for neH installations.

16 l

22 MR D0YLE: I think binding Has picked up in your 23 hardHare check. ,

24 MR. XLAUSE: Yes, it was. We had identified the O 25 potential for binding in one of our early HalkdoHns of CPPP-5 Carmen Gooden, CSR, RPR, Metro 429-5532

54 1 and -8.

'( ) 2 MR. D0YLE: What I'm getting at, though, is that of 3 all the supports that Here put in, classed as old supports, 4 those have been inspected. So if this problem -- it says here 5' "binding for neH..." What I'm getting at is, the old 6 installations were picked up on the field walkdowns.

7 MR. XLAUSE: That's correct. That's what the FVM 8 requires under our PCHVP.

9 That concludes SWEC's presentation of the Appendix A 10 and Appendix B issues of our PSR. I Hould like to now turn it 11 over for large bore and small bore. I'd like to now turn it 12 over to Mr. Counsil.

(} 13 14 MR. NACE: I'll take it at this point. That does conclude the discussion of all the issues Hhich have come out 15 of the Design Validation Program in large bore and small bore 16 pipe supports, summarized, of course, in the Project Status 17 Reoorts. We're pretty proud of that set of activities of 18 validating that design.

19 We'd like to field your questions. We can go on a 20 break noH, if you Hant to, and let you formulate questioTS, or 21 you can fire away.

22 One of the problems I have is that because of the 23 time of the day noH, ,He're really not going to be able to get 24 through that second presentation. Remember, I started out O 25 saying there are three packages, and it might be disruptive if Carmen Gooden, CSR, RPR, Metro 429-5532

55 1 He stort that one and then break at five o' clock. We're goins

() 2 to lose the train of thought when He come back tomorrow 3 morning, bec'ause I think you will be interested in this second 4 presentation.

S' MR. D0YLE: So you'd rather I hold off on these?

6 MR. NACE: No, I'd rather you go ahead and fire aHay.

7 MR. D0YLE: Let's take a break first.

8 MR. NACE: We'll break until 3:45.

9 (A break was taken.)

10 MR. NACE: The meeting Hill come back to order. We'll 11 turn the floor over for CASE questions.

12 MR. D0YLE: As I mentioned before we took the break, 13 some of the questions went away, but my first question Has:

[ )

14 There are areas of concern raised by sources other than CASE, l 15 for example, Teledyne, Stone & Webster, et cetera, et cetera, 16 that's obviously gone by the wayside. Several other questions 17 have also been answered today. However, I have another areo 1

{

I 18 of concern. I was aware of it at the last meeting in March, i 19 but I didn't mention it at that time because I thought perhaps 20 these felloHs are a differen,t Category of Concern DeCause the 21 number 22 is not quite accurate as far as CASE is concerned. l 22 For example, generally in the findings of facts in chapter 23 23 you Hill find a large. number of anchors which were lodged 24 against thermal expansion, and those are also covered in 669B, O 25 for example, under 12M and 4D, E, F, G and H. And I don't Carmen Gooden, CSR, RPR, Metro 429-5532 _

56 l

1 knoH at what point those Hill be answered.

() 2 MR. 0GDEN: Are you saying 22?

3 MR. D0YLE: Chapter 23 in the findings of fact. What 4 these Here, these were issues that He raised and He argued in 5' the hearings, but He haven't heard anything about them. I 6 didn't know whether the anchors were treated separately from 7 the pipe supports or --

8 MR 0GDEN: What is the topic?

9 MR. D0YLE: What it is is the pipe was anchored but 10 the way in which it was anchored diametrically it was lodged 11 against thermal expansion.

12 MR. EVANS: As I remember the concern, it was the situation Where you had a pipe anchor with opposing trunnions

{} 13 14 and the concern is that due to thermal expansion of the pipe 15 that you would get resulting --

16 MR. D0YLE: Stress loads that Heren't accounted for.

17 MR. EVANS: What He have done on this issue is to 18 evaluate that situation. A STRUDL model is run and loads 19 developed due to that thermal expansion. In other words, the 20 pipe is growing. Those loads are evaluated in the design.

21 MR D0YLE: Where can He find this information?

22 I know that Stone & Webster do consider it. I Just don't i

23 don't know where in t,his document.

24 MR. XLAUSE: We're researching it.

25 MR. D0YLE: This is not an issue I need resolved l I

Carmen Gooden, CSR, RPR, Metro 429-5532  ;

57 1 right now, this minute. You could actually --

() 2 MR. SISKIN: I'm certain we did address it. We Hill 3 look it up ahd get back to you hopefully --

4 MR. D0YLE: There Here some of them also that Here 5' locked from Hall to Hall.

6 MR. SISKIN: That was covered in our March meeting.

7 MR. OGDEN: That was floor to floor, Hall to Hall.

8 MR. D0YLE: No, they actually had some anchors where ,

9 they Hould Come off the pipe With a double trunnion and then 10 go to this Hall --

11 MR. KLAUSE: Same issue.

12 MR. EVANS: Some issue.

13 MR. D0YLE: Also, on page 101 and 102 of my j 14 deposition I raised considerable concern over Appendix 11; 15 also brought it up in the hearings. At the time I brought it 16 up, Mr. Roger Reedy of the ASME Code Committee or consultant 17 to the Utility stated that it was not a concern because they  !

18 Here developing a matrix indicating supports which Here not  :

17 '

19 accessible under Appendix 11 for in-service inspection. Did l

20 Stone & Webster look in on the problem of in-service i 21 inspection?

22 Again, it's a question -- I knoH that in Boston they 23 have a provision for , Appendix 11, i 24 MR. SISKIN: There's no question of Boston or here.

() 25 Stone a Webster has a provision that's applicable to all Stone >

r Carmen Gooden, CSR, RPR, Metro 429-5532

58 1 & Webster work at any site.

() 2 MR. D0YLE: I'm also chare of that, but again, I 3 don't know where to find it.

4 MR KLAUSE: That issue Has addressed, Jack. It will S' be a reinforcement pad over a butt Held. I think that was 6 your particular --

7 MR. D0YLE: That would be --

8 MR. KLAUSE: We have addressed that, and there Has 9 also a specific DIR. We'll have to find where we have done 10 that.

11 MR. D0YLE: As I said, I don't need an ansHer to any 12 of these immediately. It's more of a paper trail than

[} 13 14 anything, because I am aware of the methodology used by Stone

& Webster.

15 MR. 0GDEN: Jack, I Hould like to point out that in 16 the March meeting in our Appendix B handout, which is local 17 pipe stresses, the first issue He discussed under CASE's 18 concern was integral attachments, and let me read and see that 19 He did indeed address this in that meeting. It reads, "Local 20 stresses in pipe Hall induced by integral attachments, 21 including loads, single and multiple trunnions, and opposing 22 trunnions, should be adequately evaluated." We had addressed 23 it in the March meeti,ng.

24 MR. D0YLE: Very good.

25 MR. EVANS: Let me give you the specific section in Carmen Gooden, CSR, RPR, Metro 429-5532

59 1 CPPP-7: Section 4.6.4.1, page 4-20.

() 2 MR. D0YLE: On any of these I could be wrong because 3 I have so mahy documents to go through.

4 MR. KLAUSE: We understand that.

S' MR. D0YLE: By myself. It's really aHesome. So I l 6 probably saw loads of stuff and just moved on down.

7 MR. SISKIN: We have 30 people trying to keep track 8 of it and we can't keep up.

9 MR D0YLE: Also, in Chapter 11 -- Section 11 of 669E 10 and also during the hearings, we had a great deal of 11 discussion on moment restraints and the upper lateral 12 . restraints. The main thing He were Horried about or Concerned

[}

13 about with the moment restraints is the fact that in the event 14 of any temperature rise due to the differential in thermal 15 transport betHeen steel and Concrete those supports Hhich Here 16 originally anchored, particularly when they had shear keys, 17 there could be stress levels that Here unaccounted for. And I 18 was Just wondering had anybody looked at it. Those were all 19 Class 1 structures, too, by the Hay.

20 MR. KLAUSE: Moment restraints are SWEC pipe stress, 21 pipe _ support scope of Work, so I Can't off the top of my head 22 tell you He're addressing that specific concern. But we have 23 to find out chapter and verse.

l 24 MR. D0YLE: Then another concern which Has covered 1r 25 the findings of facts in Chapter 19 and also in the hearings l i

l Carmen Gooden, CSR, RPR, Metro 429-5532

60 1 in the area of TR 6800, in that vicinity, Has the upper and

( ) 2 loHer lateral restraints. In addition to the problem we had 3 with the upp'er lateral restraints, we had an additional point 4 which was brought up during the hearings in which one of the 3' seismic restraints was a bank of about eight snubbers.

6 However, due to the fact that it wasn't introduced in my 7 deposition, it was considered -- Mr. Reynolds brought up the 8 fact that it was untimely, something, some legal words. But 9 my point at the time I brought it up in the hearings was a 10 bank of eight snubbers all working simultaneously you couldn't 11 set simultaneous lockup.

12 MR. SISKIN: I know what you're talking about, Jack.

13 We'll get back to you tomorrow on that.

14 MR. D0YLE: I realize that a lot of these Houldn't 15 come under pipe supports, but we might as well get them out of 16 the way now, at least give you some time for preparation.

17 This is another one where I may have received on 18 answer on it and Just not aware of it. It's covered under 19 669B, 13T and 130, specifically, or as one example, is the 20 kick loads in the pipe system. They had some supports. One 21 of them Has 39 degrees. Yet it only carried a vertical load, l 22 but sitting at 39 decrees it automatically puts a horizontal 23 kick into the pipe. ,

i 24 MR OGDEN: Jack, He did address that in the March O 25 meetings. I'm sure we could find out the reference to it. l l

Carmen Gooden, CSR, RPR, Metro 429-5532

61 1 But the ansHer to that is the discussion as part of the PSRT

() 2 review, Which He did talk about, where He started this 3 engineering process out Hith a stress engineer and a support 4 engineer reviewing, doing a paper as-built of the piping 5' system, and they recommended a pipe stress model consisting of 6 CPPP-7 requirements reflecting the guidance for pipe support 7 design and for pipe stress analysis, and then document that 8 suggested modifications or elimination of excess snubbers, 9 1dentification of potentially unstable supports require 10 modification and other things that are outlined in CPPP-6.

11 They identify Hhat they believe, that the realignment 12 of the support should be to best attain the objectives.

{} 13 That's outlined in PSRT cale and then subsequent stress 14 analysis is performed ensuring code compliance, and then the 15 support design is done behind that. Support valida(lon is 18 16 done behind that to ensure code compliance, l

17 One of the attributes He look at as part of that PSRT  !

18 1s orientation, among many others things, of each individual l

19 pipe support, and the orientation as indicated on the drawing 20 is an input to the pipe stress analysis. So that particular 21 support you're talking about or any like it Hould have been 22 coded in as line of action. And then He Hould go through our 23 design validation pro, cess. And then subsequent to that in the 24 Hardware Validation. Program, the Post Construction HardHare O 25 Validation Program, the orientation of all supports are again Carmen Gooden, CSR, RPR, Metro 429-5532

62 1 validated to be in accordance with the design drawing. So it O 2 1s very c1 ear 1y and definitive 1y cedressed in our prooram.

3 MR.*D0YLE: I'm sure it was.

4 MR. KLAUSE: Jack, before you go to the next subject, S' I'd like as a point of reference for the moment restraint 6 support qualifications -- that's our project procedure 7 CPPP-29, and that discusses the design criteria for alloHableS 8 for the qualification of moment restraint.

9 MR. NACE: Do you recall if He transmitted that to --

10 MR. KLAUSE: When He submit our budget procedures 11 to --

12 THE COURT REPORTER: Mr. Klause, I can't hear you.

13 MR. NACE: We're trying to determine Whether we have 14 provided that to -- I I

15 MR. KLAUSE: We Hill check and find out if it was 1 16 provided.

17 MRS. ELLIS: I don't recall.

l 18 MR. NACE: Do you have a copy here?  ;

19 (Document handed to CASE.) I 20 MRS. ELLIS: Just for the record, on the upper 21 late.ral restreint I Wanted to point out that that was the 22 motion -- Has one of the subjects of motion for summary 23 disposition which He , addressed, so it's definitely one of the 24 things that should be coverad, I think. And I am sure that 25 you Hould have in any event. I just Wanted you to know that I

Carmen Gooden, CSR, RPR, Metro 429-5532

63 1 for the record.

(,) 2 MR. D0YLE: I'm curious. I see a bank of snubbers tc 3 be disposed 'of.

4 MR. NACE: That piece of work is within the 5' civil / structural discipline taken from the Project Status 6 Reports. When we have the next phase of this meeting we're 7 going to give you an overview of the entire status, but He 8 aren't prepared to go into detail on that at this time. We 9 Hill do that, though, at the appropriate time.

10 MR. SISKIN: That analysis is done and He'll be 11 prepared to talk about it --

12 MR. COUNSIL: Mrs. Ellis, what I'd like to do, we

{} 13 14 have an extra copy with us of all of the CPPP-7 procedures plus project memoranda. They're uncontrolled. We Hill give 15 you that set tonight. All right? In the near future I will 16 transmit the three copies to make sure your references are 17 okay.

18 MRS. ELLIS: Great, because some of the ones we have 19 might be older versions to it.

20 MR. COUNSIL: I thought I Has keeping you up to date,  !

21 but I will verify that also. In the meantime, I'll give you 22 this.

23 MRS. ELLIS: ,I have to admit I'm not sure.

24 MR. D0YLE: When you've done the snubber '

) 25 re-evaluation program, when you streamlined the snubbers and Carmen Gooden, CSR, RPR, Metro 429-5532

64 1 removed approximately a thousand snubbers from the system, O 2 witnin tnat number of a tnousand snubbers. tnere were a number 3 of them which also could have been classed unstable, cinched 4 U-bolts, et cetera. In the cataloging of the modifications, 3' those four -- prudent, adjustments, et cetera -- if a snubber 6 was also unstable or had a cinched U-bolt, it went under Just 7 the heading of prudent and not a multiple heading. In other 8 Hords, it wasn't considered with its two, three shortcomings.

9 MR. KLAUSE: That's generally correct, Jack. If 10 it's not there, then you don't have the inspection -- okay --

11 for snubbers. But if it was an unstable support, classified 12 as a support, that Has removed also. We have multiple trends 13 on a support modification.

14 MR. D0YLE: The point I was making, there could be c I 15 snubber Just being removed, streamline the system. It could 16 also be an unstable support.

17 MR. SISKIN: If our Judgment was that it was unstable i

18 or it was a cinched U-bolt or something, its removal was 1

19 categorized as such. Some of the other ones that were removed i 1

20 for snubber reduction may have been in that category, but He 21 didn't necessarily do the analysis to determine that. So if 22 He knew it was categorized in a category that was .

23 unsatisfactory, it Ha.s branded as such. We didn't 24 do unnecessary analysis to 90 back and say, was that really O 25 stable or not? '

i l

Carmen Gooden, CSR, RPR, Metro 429-5532

65 1 MR. D0YLE: The Hord itself, "prudent". That O 2 basically means indeterminate, doesn t it?

3 MR.'SISKIN: Absolutely not.

4 MR. KLAUSE: In some cases it means iterative 5' analysis, so rather than to expend the engineering hours, if 6 you will, for analysis, it was prudent to Just unolug it since 7 it wasn't required to qualify in that piping system.

8 MR. COUNSIL: In hindsight, Jack, from my perspective 9 it was a poor choice of words. What He should have used is 10 expedient. It's a lot easier to take it out than sit and let 11 them analyze it.

12 MR. D0YLE: That's what I was getting at. Actually, 13 at the point in time it couldn't be qualified. It Hould take 14 a large expenditure of time to get it on paper.

15 MR. COUNSIL: More than it would have cost us than to 16 Just take it out.

17 MR. D0YLE: Right.

18 MRS. ELLIS: I think in effect you tHo are saying the l l

19 same thing. That's sort of What he meant by indeterminate. l 1

20 MR SISKIN: Well, no -- I 19 21 MRS. ELLIS: It was faster to go ahead and do 22 something else with it rather than take the time to analyze it 23 and see if it Has okay, 24 MR. SISKIN: Many of them Here in that category.

O 25 Some were removed simply because they weren't necessary and we Carmen Gooden, CSR, RPR, Metro 429-5532

66 l

1 wanted then isolated.

O 2 Ma. D0vte. I understone tnat.  !

3 MRS ELLIS: I think you're sort of saying the same l 4 thing, only different.

S' MR. SISKIN: I wouldn't want to say we removed a 6 thousand snubbers, therefore a thousand were indeterminately 7 unstable.

8 MRS. ELLIS: But some of them might have been.

9 MR. SISKIN: Some may very well have been, yes.

10 MR D0YLE: During this last SWEC presentation where 11 problems were classified as e.ternal source, I noticed a 12 number of them which also were originally CASE concerns. For 13 example, plug Helding. A fair number of them. Is that a 14 correct assessment, that -- for instance, we went through the 15 issue of plug Helding in the hearings and the NRC took it fron 16 there. And the people who finally pinned it down are 17 considered the external source?

18 MR NACE: Let me try to answer that. As you might 19 expect, trying to keep track of a vast amount of information 20 from various sources, we generally catalog things one of three  ;

21 different ways. If it came from what you would think of as a i 22 project team, it Hos a project thing. If it came from CPRT 23 it's generally called a CPRT/ Third Party.

If it came from

_ 24 anybody else, it was an external source issue.

25 That's Just an administrative convenience of how to Carmen Gooden, CSR, RPR, Metro 429-5532 j

67' 1 keep things sorted out. It was very, very correct. The CASE O 2 1ssues are classified external source issues. For that 3 matter, I think CYGNA issues are external source issues. NRC, 4 because of their questions and SSERs, TRT issues, Here 5' external source issues. And anything that --

6 MR. D0YLE: Teledyne?

7 MR. NACE: Teledyne, anything that came up from 8 somebody other than Project or CPRT Has --

9 MR. D0YLE: In some cases they Here actually multiple 10 source.

11 MR. COUNSIL: Multiple external sources. That's 12 true.

13 MR. D0YLE: Having mentioned the plug Helding issue, 14 hoH Has that validated by Stone & Webster? I should have 15 asked that before.

16 MR. 0GDEN: That Was validated under the ISAP. I 17 think He had reference to that, II.B. No. Let's 90 back to 18 the slide Hhere we talked about it and He Hill see the actual 19 reference. What Stone & Webster did do is He reviewed V.D.

20 We reviewed the results report, and their report indicates to 21 us -- relates the history of events found under the CPRT 22 investigation of this issue, and it reports on the testing 23 that they did of the plug Helds to assure that the plug Helded 24 members did not reduce the structure integrity of the member.

V 25 And the tests that were performed reported to have the same I

l 1

Carmen Gooden, CSR, RPR, Metro 429-5532

68 l

1 minimal ultimate tensile strength, et cetera. All these O 2 engineering properties we toox for as tne main memeer tnat was 3 being repair'ed, the base metal that was being repaired.

4 MR. SISKIN: Let's move that one onto the list to 5' talk about tomorrow. I know that we did the insoections. NRC I

6 did the inspections, we did the follow-on analysis. We don't 7 have a person here that Has involved Hith the actual analysis.

8 I'd like to get hold of Mr. (Inaudible) to try to answer that 9 question.

10 MR. D0YLE: Good idea.

11 MRS. ELLIS: And a little additional information 12 that we're concerned about on this. I guess one of the things 13 that we're concerned about on this one in particular is Just 14 exactly what Stone & Webster did as opposed to What somebody 15 else did, what you looked at to make your determination, Here l 16 you accepting somebody else's word for this part, and then 17 taking your analysis from that. Were you inspecting somebody 18 else's test Hithout -- that sort of thing is what He're 19 interested in.

20 Also, one of the things that is of concern is I think 21 the NRC staff people who finally Hent out and sure enough 22 found some Helds that Here unauthorized plug Held, which had

. l 23 been done in the, I think it was, north cable spreading room 24 right where Henry Stiner had sold some time back that they had 25 been done. Sure enough, they finally found them. I think 4 Carmen Gooden, CSR, RPR, Metro 429-5532'

69 l

1 that the NRC said that they only found them using flashlights l( ) 2 at an oblique angle, and I am.o little concerned whether or 3 not the people Who Here looking at it, Whether it Was Stone &

4 Webster or Whoever did the looking, did something similar to 5' that anr hoH secure He Can be in the knoHledge that they founc 6 everything that Has to be found in that regard.

7 MR, SISKIN: We Hill get back to you tomorrow.

8 MR. D0YLE: Ur, der A36, the validation of the concrete 9 that it was 4,000 PSI concrete. There was another issue came 10 up during the hearings in Hhich it was some of the Halls that 11 Here lacking rebar. Was that -- did Stone & Webster get 12 involved in --

13 MR. SISKIN: Yes.

(

14 MR D0YLE: And that Hon't be in the structural, 15 civil / structural, 16 i:nd during the course of all this Stone & Webster 17 Here not involved in determining -- He all aDreed there was a 18 vast number of bad supports, and during the program of 20 19 corrective action or even in determining which ones were, in 20 fact, bad supports, did Stone & Webster check the root cause 21 or generic implication of that part of your mission?  !

22 MR, SISKIN: Our mission was to assure that every 1 23 support that is in th,at plant is satisfactory. We started 24 basically from ground zero to do that. What existed before,

) 25 He do not have detailed information and Can't really Cover it.

Carmen Gooden, CSR, RPR, Metro 429-5532

70 1 1 MR. D0YLE: And one other more general question on

() 2 all these external issues that we Just discussed: Can we 3 astume that 'these were all valid concerns unless you stated 4 otherwise?

S' MR NACE: Yes.

6 MR. SISKIN: Rather than trying to answer that 7 question on an item-by-item basis, I think it's appropriate tc 8 say a predominant number were. I think, again, in some cases 9 where He didn't agree, He talked about it on a professional '

10 basis. But a predominant number were. We con 90 back and 11 study it more, in more detail, and see that Hhat has been done 12 is satisfactory at this point.

13 MR. COUNSIL: All of those external source issues, 14 Jack, did not all 90 to the SWEC PSAS. We indicated today 15 that there were 972. There Here other external source issues 16 that went to various organizations. Ebasco had a number of i

17 them. Impell had some, but not a large number, if I remember 18 correctly. Each of the Stone & Webster EDIRs, since we were 19 doing a total reanalysis of the entire -- they were grouped, 20 as He indicated in generic-type issues, 33 that were 21 subsequently culled out of there to 39.

22 In other instances, those specific DIRs themselves 23 are all being answere,d. I can't answer no, they Heren't all 24 valid, but somewhere I can also state some of the TRT issues 25 Here not valid and those have come out in the ISAP results Carmen Gooden, CSR, RPR, Metro 429-5532

~

71 i l

l 1 reports. So I think He have a track record of saying, okay,  !

() 2 this one is valid, this one isn't valid, and so forth. But ir 3 this case I can't ansHer because He grouped them all as for as 4 the pipe supports.

5' MRS. ELLIS: I think that was one of our concerns, 6 that it wasn't real clear, you know, in some of the Hording ir 7 here What the case Has, you knoH, Whether --

8 MR. COUNSIL: All DIRs that have come to us, ther 9 they're external source issues, whether they came out of the 10 Design Adequacy Program or they came out of construction, are 11 all categorized and they are all being answered. So at some 12 point I can give you a final on all of them that says, yes,

() 13 14 it's valid or no, it's not valid, and here's the reason.

MR. D0YLE: I think that probably answers the 15 question. We understood that Has going to be a difficult one 16 to answer here at the table.

17 MR. COUNSIL: I can't bring them all in. I read a 18 thousand of them over Christmas a year ago. ,

i 19 MR NACE: When you look at Hhat's called the DIR, 20 Which could be one of several types, Just for bookkeeping 21 purposes, but to my recollection there were some 4300 total i i

22 DIRs, either external source iss>Jes or design issues, that ,

23 came out of TERA Desi,gn Adequacy Program. Each of those was 24 treated as a separate document and dispositioned unto itself.

O 25 That is the file Bill Has talking about.

Carmen Gooden, CSR, RPR, Metro 429-5532 [

72 I

1 I better correct that. Each of thost is

() 2 dispositioned according to a procedure. There are probably a 3 small number'that aren't dispositioned yet that will be in the 4 very near future before He issue the remaining PSRs.

S' MRS. ELLIS: There is another one that's under PSR 6 Subappendix A32 about the computer program verification. This 7 is a little difficult to word so it Hill make sense as a 8 question, but I Hill giVe it a shot. One of the things that 9 is of concern is He know, or at least Jack knows and 10 understands, What computer programs Stone & Webster uses and 11 Hhat they are and so on. There is a concern as to the other 12 areas Where other kinds of computer programs may be used as to

{) 13 What their status is and whether those computer programs are 14 satisfactory and He con feel as comfortable with them as some 15 of the ones that He're more familiar Hith that Stone & Webster 16 uses, for instance.

17 MR. NACE: I'll field that question. Under the TU 18 Electric QA program, which is used as a mother progrcm, if yot 19 Hill, for all the contractors, He, in fact, have a procedure 20 or requirement for qualifying computei programs used in the 21 design. It's very similar to what Jack Hill remember as, I 22 believe it was, an EAP 5.25 in the Stone & Webster engineering 23 assurance manual.. We,used that procedure. All the contractor 24 programs that used the revalidated design are, in fact, 25 qualified. Exactly Hhat the format of that qualification Carmen Gooden, CSR, RF,.. Otro 429-5532

73 I

1 document is depends on some of the details of the individual

() 2 contractor program, but they all are qualified. That's 3 audited by the various quality assurance audits that are 4 imposed on the project.

5' MR. D0YLE: That's all. Mrs. Ellis may have a feH.

6 MRS. ELLIS: There Has -- Jack has one.

7 MR. D0YLE: Actually, What I have is a statement. I 8 Hent through all of the material I got that I knoH Where to 9 find to see if there Has anything missing. Those Here the 10 questions I Just asked in the past feH minutes.

11 So to the best of my knoHledge almost everything that 12 I have con' erns Hith from the hearings has either been covered 1

{} 13 or as the Stone & Webster people say, they Hill have ansHers 14 to it. So I can't think of another thing relative to the pipe 15 support system and the moment restraints, et cetera.

16 MRS. ELLIS: There was one statement regarding --

17 let's see, this is under PSR Subappendix A38, SSER-11 18 revieH -- Hhere you Hent through and identified the issues in 19 SSER-11 that Here related to piping design. There was one 20 statement in there, and I don't have it before me, but it does 21 not seem to be mentioned specifically here, and that Has that 22 the CYGNA concerns Hould be addressed later by the NRC staff 23 in a separate SSER, a,nd those specifically Here being 24 excluded. And I believe that Has in SSER-11 where they made O 25 that statement. They did in one of the SSER's, and I think Carmen Gooden, CSR, RPR, Metro 429-5532 1

74 1 that's the right one. At any rate, how does Stone & Webster,

() 2 or how Hill these CYGNA concerns be factored in and hoH Hill 3 they be integrated into this? I know the ones you've already 4 listed, but I --

5- MR. SISKIN: All of the CYGlA concerns 3re listed in 6 What's called the RIL, RevieH Issue; List.

7 MRS. ELLIS: Right.

8 MR. SISKIN: All of the concerns on the .IL relating 9 to pipe stress and supports have been addressed end 10 satisfactorily resolved with CYGNA and closed ou:.

11 MR. NACE: I might add beyond that all the CYGNA 12 issues that existed at one time with the project are, in fact, 13 being resolved and processed with CYGNA. CYGNA reviews have 14 been ongoing noH for about a year. What was on one of the 15 original pipe stress and support RevieH Issues List from CYGNA 16 included several items Hhich for our Convenience He'll 17 tran:fer to civil / structural, those things such as 18 Hilti-bolts, Richmond inserts and so forth. They are all 19 being prosecuted, if you will, with CYGNA. To the best of my 20 knowledge at this point in time, all of the -- He believe all 21 of the, not only the pipe supports but the cable tray hangers 22 and conduit support issues, are closable. CYGNA is rev1(Hing 23 and He are Cooperatin,o Hith them, and He Hill do What it takes

,, 24 to convince them that they are closed.

'"# 25 There are a few additional issues Hhich are on I

l Carmen Gooden, CSR, RPR, Metro 429-5532

75 1 Discipline Review Issues List relating to mechanical, O 2 electrical, instrument and controls cnd design controls, and 3 those are ve'ry small numbers. Those are also being Horked 4 and looked at closer.

S' With respect to your question of NRC and the SSER, I 6 can't speak on how they're going to -- What the NRC is going 7 to do With that, but I also know that they are involved in 8 following the CYGNA-TV Electric closeout.

9 MRS. ELLIS: I guess this leads to a question I 10 hadn't really meant to ask today but ce'rtainly something that 11 Hill need an answer at some point in time, so I will go ahead 12 and mention it now for your consideration Hhn. lever yoL Can 13 give us an answer. That is, what the status is of the CYGNA

(~

14 reports and how many there are going to be and Hhen they're 15 going to come out. Any information you can give us about that 16 I think would be helpful, especially Hith trying to get a 17 handle on where He'll be as far as scheduling and closing 18 things out and so forth. I don': leolly expect an answer 19 necessarily now, unless you know --

20 MR. NACE: I don't knoH.

21 MR. COUNSIL: I do not know the correct answer to 22 that question; however, our first goal is to get CYGNA to 23 close their Review Is, sues List and we Hill research ,41th them 24 once that closure is reached how long it will take them to 25 Hrite their final report. I don't have that ansHer today.

, Carmen Gooden, CSR, RPR, Metro 429-5532

76 1 But the status of all of their concerns, though, are updated

() 2 through their RevieHs Issues List.

3 All'the cYGNA concerns on the Review Issues List were i

4 referenced in a PSR, and in addition to that, they have 5' informed us that all pipe -- large and small bore -- 1ssues 6 have been closed.

7 MR. SISKIN: That's identified and specified in 4 of 8 the issues.

9 MRS. ELLIS: That's the one He Just got yesterday?

10 MR. COUNSIL: Yes, it's in there.

11 MRS. ELLIS: There Has another question that was 12 triggered, and this is the some sort of question as the last 13 one. Under PSR Siboppendix A39 about the CPRT quality of 14 construction action plan 7C, that Has triggered by something 15 that Stone & Webster said, and I don't remember exactly What 15 it Has noH, but I Has Hondering -- it sounded as though Stone 17 & Webster has already seen that. Is that Hrong? Right?

18 MR. NACE: We have an administrative process on the 19 site Hhich has been in existence since very early in the 20 program and at the point in time that the Third Party had a 21 recommendation from the Project, that was passed to the 22 project. And if you remember from our July meeting Hith the 23 NRC and one of the August transmittals, I believe it was 24 August 20th Hhere H3 gave a floH Chart Of the tHo Comanche

( 25 Peak programs, those recommendations that are received on the l i

l Carmen Gooden, CSR, RPR, Metro 429-5532

77 l

1 project are handled as a Criterion 16 Correction action

(,) 2 request. The kind of thing that Jack might remember as a 3 problem repo'rt, to Hhich you got to take criterion 16 4 cor ective action. When they gave you the list of things 5' that came out of ISAP-7C, there Has a summary of those 2

6 recommendations from the CPRT-7C activity.

7 MRS. ELLIS: And you know what the next question is.

8 Are He going to see 7C?

9 MR. COUNSIL: I think I can answer that one. 7C and 10 several other of the results reports Hill be issued with the 11 collective evaluation report, the overall report about all the 12 construction. I am told that that Hill be issued next Heek in

{} 13 toto. I mentioned today to David Real at the break that I 14 Just lost another conference room on my floor because the file 15 cabinets are being moved so that you can come and look when it 16 is issued.

17 MRS. ELLIS: Okay. And I guess there is one other 18 thing, Just as a point of clarification. I think He have 19 primarily been approaching this as sort of -- though we have 20 touched somewhat on implementation, primarily what He've been 21 trying to address and what He're seeing so far is really still 22 involved with the program plan and the means for rer,olution 23 rather than the implementation part. We're still going to 24 Hant to get into implementation to a far greater degree than 0 25 what He have done so far. I Just Hant to be real clear on I

Carman Goodea, CSR, RPR, Metro 479-9937

78 1 that.

() 2 MR. COUNSIL: When you're talking about 3 implementation -- I think He should clear this one up a little 4 bit. When He're talking implementation of design, He're 5- almost finished today, and when He issue the PSR, like the 6 first five that are out right now, the designs are finished.

7 If He're talking implementation of Converting the design into 8 a construr. tion and revieHing, you knoH, inspecting it, that is 9 ongoing. But the design Work is literally coming to a close 10 right noH, and when the PSR is issued, that is one of the 11 prerequisites of the issuance. The design is finished.

12 So Saturday When Jack goes on a tour, he's going to

{} 13 find that there's a lot of construction, reinspection, doHn 14 there in addition. E7 15 So I Just Wanted to clarify implementation. There's 16 on implementation phase in thc design process, too, as Hell as 17 in the construction process. Is that clear or --

18 MR. D0YLE: I'm really not sure if it is clear.

19 MR. SISKIN: For example, the acceptable design of 20 every support in the plant has been issued.

21 MR. D0YLE: That is, completed on paper.

22 MR. SISKIN: Completed on paper. You're putting 23 together the detailed, construction paper and that's basically 24 being staged, and most of that has been issued to O

  • - 25 construction. Many of the modifications have not been Carmen Gooden, CSR, RPR, Metro 429-5532

79 1 completed yet. The actual physical modifications. But if O 2 vou re saying Hnat about tne cesign of any support, if you go 3 through the ' plant and say, Hhat is that design going to look i 4 like?, I can give you the design package that shoHs you What 3' that's going to look like, Which fully implements the design 6 program that He've specified here today.

7 MRS. ELLIS: You're saying that you con do that, 8 MR. SISKIN: I can do that now, yes. Literally 9 every support in that plant has been designed safety-related.

10 MR. D0YLE: And there is no more such thing as a CMC 11 program.

12 MR, NACE: There is no CMC program. We're using a 13 DCA in a very similar fashion to what you remember as the 14 E&DCR, To reiterate and emphasize What Ed said, at the point 15 of issue of the PSR, the design is validated, we have a 16 procedure, a program is in place, to maintain and validate 17 throughout the field implementation.

18 MR. D0YLE: One of the things that concerns me about l 19 CMCs is that seemed to be one of the items that got the 20 program in trouble in the beginning, We haven't discussed l 21 Hhat the control is after the design leaves the engineering 22 office.

23 MR, NACE: I,f you remember your Millstone III days 24 and the ESDCRs, it's the same except He call them DCAs, O

25 I MR. D0YLE: Same thing. Same thing. '

Carmen Gooden, CSR, RPR, Metro 429-5532 l

80 1 MR, SISKIN: Except there is, in fact, an additional O 2 1evei of cnecx1ng on tne fact inat 11 s accurate 1y. odeaucte1, 3 controlled, even over and above the E&DCR orogram.

4 MR D0YLE: I Has pretty sure that the CMC program 5' had fallen out, but I Hanted to make sure of it. But I think 6 it wasn't too long ago He were still hearing CMC -- What? --

7 a year or two ago.

8 MR. NACE: To be honest with you, in some work 9 packages yet there probably still are CMCs because as you 10 might remember, those things are in the historical file.

11 When we get into design validation, other activities, 12 though, you Hill find that all those CNCs have been revieHed 13 by the three organizations that are validated design. They 14 Here picked up and P3sted appropriately, ano the same thing 15 has happened Hith other vehicles which have been used to  !

16 change the design in the existing plant.

17 MR D0YLE: I'm Hell satisfied with the front end of 18 the program, the engineering. Where I lack detail -- I'll ,

19 probably learn more Saturday -- is the back end, and it 20 appears froin past history that it was the back end that was '

21 driving the front end of the program.

22 MR. COUNSIL: On Saturday our people, Stone &

23 Webster, Hill be able,to shoH you hoH that validated design is 24 translated out of the plant and how the historic change paper O 25 is picked up in the final design, validated, and posted on the  ;

Carmen Gooden, CSR, RPR, Metro 429-5532 '

81 3 1 drawings. So that is all being done.

() 2 MRS. ELLIS: Just so I'm sure that I understand 3 What's going'on, these Project Status Reports, when they're 4 issued that means that the design part of that particular 5' program is through; is that right?

6 MR. NACE: "Through" is a very final we 1.

7 MRS. ELLIS: We know.

8 MR. NACE: Well, see, I would have to waffle on these 9 because in accordance with the rules of the industry that we 10 work in, the design is never through. The design is a living, 11 breathing thing that lasts the life of the plant.

12 What the PSR signifies is that He now have a

(} 13 validated design as, as Ed described it, in the piping area.

14 We have a contractor, in this case Stone & Webster Engineering 15 Corporation, Hho Hill stand behind that design, as AE for that 16 piece of the design, if you Hill, and we have the procedures 17 and programs in place to control and maintain that design in 18 its validated condition throughout the implementation phases l 19 and into the operation of the plant.

20 MRS. ELLIS: It doesn't necessarily mean that  !

l 21 implementation of the design is completed; is that right? i 22 MR. NACE: Yes. As Ed described it, in the pipe 23 support areas all the, pipe support designs are noH issued; 24 Stone & Webster paperwork. It does not mean that they are all 25 implemented in the field yet; however, any variation to the Carmen Gooden, CSR, RPR. Metro 429-5532

82 i

1 design that comes up when the field is in the implementation

() 2 stage, for Hhatever reason, interference, it doesn't fit, 3 Hhatever, is', in fact, captured within the design control 4 process so that it gets back to the engineer and he has to S' approve it before it's changed. And that's what I Has 6 describing to Jack, that he would recognize that program from 7 Millstone times.

8 MR. COUNSIL: We are going to talk about this 9 tomorrow when He 90 through the overview of what the CAP 10 programs are. -

11 (A break was taken.)

12 MRS. ELLIS: Just for the record for the clarity of

{} 13 anyone reading the transcript later on, there Here some items 14 mentioned earlier, one of them is 669B, Hhich refers to CASE 15 Exhibit 669B, Hhich was the attachment to Mr. Doyle's pretrial 16 testimony which was accepted in the September 1982 hearings.

17 He mentioned in his deocsition, Which Hould have been his 18 deposition that Has t'. Ken, I believe, August 19th and 20th, 19 1982, which was accepted as his pretrial testimony for the 20 September 1982 hearings as CASE Exhibit 669 and 669A.

21 MR COUNSIL: Jack, do you have any other questions?

22 MR. 00YLE: No.

23 MR. COUNSIL: ,

Ec Siskin has a clarifying comment.

24 Then I'd like to take about a five-minute break so he con O

, 25 caucus and make sure they have your questions Hritten 1

~~

Lurmen Gooden, CSR, RPR, Metro 429-5532

83 l l

1 properly, read them back to you, and then He'll be finished O 2 for 1ne eay.  !

3 MRS', ELLIS: We may have a few more, too.

4 MR. COUNSIL: I understand.

5' MR. SISXIN: Obviously from your questions there Has 6 a concern of how do we make sure of the designs that He 7 specified? There was a concern in your mind apparently, how 8 do He make sure that Hhat He specify in our design actually is 9 exactly What is constructed in the field? Referring back to 10 the comments He made earlier in PSR Subappendix A16, the 11 second paragraph specifies SWEC PSAS reviewed and validated 12 the installation specifications and reviewed the resulting 13 inspection procedures to ensure consistency Hith our 14 engineering requirements. And any indication by inspection 15 that there is a variation from those requirements we again 16 Hill disposition properly so that we're in a position not only 17 to specify What is required but He're in a position to ensure 18 that that is, in fact, what is installed.

19 MR. D0YLE: Actually I Hasn't as much concerned about 20 the construction of the design as I was that there might be 21 the possibility of a CMC-type program Where what we called 22 someHhat knoHledgeable people Hould go out and on their own 23 make a change without. informing Engineering.

l 24 MR. SISXIN: Absolutely not. Mr. Couns11 and Mr.

lO 25 Nace and, in fact, I have been very explicit in not agreeing Carmen Gooden, CSR, RPR, Metro 429-5532 l

84 1 to such a system because then we no longer have engineering O 2 contro1 necessary to ee ante to stand eenind not 1, actua11y 3 installed in the plant.

4 MR D0YLE: That was the point I was trying to bring 5* up. l 6 MRS. ELLIS: And there was another sort of extensior 7 of that concern which goes to those who ars Horking on the h

8 plant other than Stone & Webster. I know you can't do 9 anything about that.

l 10 MR. SISKIN: I think Mr. Counsil's and Mr. Nace's c 11 policy was not Just directed at Stone & Webster alone.

12 MR. NACE: What we to1d you about the engineering ,

13 control over the erection and inspection process applies 14 across the board, regardless of engineering contractor, I 15 regardless of construction contractor. What we hope to I 16 convince you in these meetings today and tomorrow also is not I 17 only do I have three contractors in engineering by different f; 18 names called Stone & Webster, Ebasco and Impe11, but what I '

19 try to avoid, they only knoH they work for different companies 20 when they get their paychecks or when they come to those  !

21 meetings because the procedures are very much integrated.  !

22 They're doing business very much the same way. The control i 4

23 over the erection pro, cess is the same way. The DCA as I talked 24 about in the SWEC case is used across the board.

O 25 MR. COUNSIL: If you would like to, we're ready to Carmen Gooden, CSR, RPR, Metro 429-5532 '

85 1 caucus for about five minutes, and then we'll come'back for

() 2 questions so He'll be sure He have them.

3 (A break was taken.)

4 MR. NACE: The meeting Hill come back to order.

S' We'll read back to you What He think the questions are that 6 remain that have not been ansHered. So if you could correct 7 them or add to them if He missed something, I would appreciate 8 it.

9 MR. CHAN: I would like to summarize the questions 10 that you have asked us, Jack. There are six of them.

11 The first one is on the approaching trunnion design, 12 and He have provided you Hith a reference, so if you read it 13 and you have some questions, let us knoH.

14 On the second item on the ASME Section 11, the 15 specific inspection. These concerns are documented in NDIRs 16 and Stone & Webster's response to all of those, He'll get a 17 list of those and get copies of those tomorroH and Hill show 18 you.

19 On the third item on the moment restraints, He have 20 provided you our procedure which contains our design criteria.

21 I think the Hay He understood your Question Has that you Hant 22 to knoH Whether the effect of the differential temperature 23 groHth on the shear c,onnection between the moment restraint 24 and the concrete have been addressed.

25 MR. D0YLE: Exactly.

Carmen Gooden, CSR, RPR. Metro 429-5532

86 1 MR. CHAN: So again, we have the procedure and He

() 2 Hill take a look at it, and you can let us knoH if you have 3 any other qu'estions.

4 The fourth item as He understand your concern is on 5' the potential differential lockup on a bank of, you said, 6 eight snubbers, and I think He Called it a bank of 7 five snubbers at the upper lateral restraints on the steam 8 generator.

9 MR D0YLE: I'm not sure of the number. I Just 10 remember that there Has a multiplicity of them.

11 MR. CHAN: We Hill bring somebody in tomorroH morning 12 to talk about it. We have done tie analysis.

(} 13 The next one is on the 35-degree struc or snubber anc 14 kickloads, and I think Fred has given you an ansHer. It is 15 something that He haVe taken Care of in our analysis.

16 The last one is on the uncontrolled butt Held, and 17 your question was how Stone & Webster validates the ISAP 18 results report. And again, tomorroH morning we Hill get 19 somebody who has looked at that and can come back and tell you 20 hoH He did that.

21 Those are the six Questions that I have. Any  ;

22 corrections, please let us knoH.

23 MR. NACE: I pight comment on the question on the moment restraints.

i 24 You said that he has that procedure. You 25 mean CPPP-29, this one?

Carmen Gooden, CSR, RPR, Metro 429-5532

87 1 MR. CHAN: Yes.

() 2 MR. D0YLE: Your ansHers do reflect the questions 3 that I had,-

4 MR. NACE: Did He miss any?

5' MR. D0YLE: No.

6 MR COUNSIL: We oHe you one other thing and that's 7 the complete set of procedures.

8 MR. D0YLE: Thank you.

9 MR. NACE: What we'd like to do now is to adjourn for 10 the day and start again tomorrow morning at 8:30. And what 11 He'll do tomorrow morning is when He start we'll start with 12 the same panel and get back to you on the questions that

(} 13 14 Alan read off, and if you have anything else that you want to bring up at that point in time, He'll entertain those 15 questions then.

16 Then He'll move from that presentation whenever He 17 finish it into the second of'the premajor ports that I 18 mentioned at the start, which would be the overvieH of the s1X 19 Corrective Action Programs folloHed by. depending on hoH long 20 the day goes, the cable tray hangers and conduit supports.

21 MR. D0YLE: Very good.

22 MR. NACE: We'll adjourn until 8:30 tomorrow morning.

23 24 (The meeting was adjourned at 5:15 p.m.)

25 Carmen Gooden, CSR, RPR, Metro 429-5532

88 '

1 STATE OF TEXAS )

() 2 COUNTY OF TARRANT 3 I, Carme'n Gooden, Certified Shorthand Reporter of the 4 State of Texas, certify that the foregoing proceedings were S' reported stenographically by me at the time and place 6 indicated, and that it is a true record of the proceedings 7 held at that time.

8 Given under my hand and seal of office on this the 20th 9 day of December, 1987.

.10 11 ,

12 #4 Carmen Gooden, Notary Public anc O 13 14 Certified Shorthand Reporter in and for the State of Texas.'

15 Certificate No.: 2353 Expiration Date: 12-31-87 16 Notary Expires: 08-10-91 17 18 19 l

20 l 21 22 '

l 23 ,

)

1 24 r~%

\

'%d 25 l l

Carmen Gooden, CSR, RPR, Metro 429-5532 l

R O

Ak CASE 22 TOPICS i

a \

PSR I 39

^ ' ' 8 GENERIC ISSUE REPORT 33 TOPICS 2 DSAP IX RESULTS REPORT TOPICS e COMPUTER PROGRAM VERIFICATION e OTHERISSUES (

l 1 CPRT QUALITY OF CONSTRUCTION TOPIC l Y

9 4

4 I

LARGE BORE & SMALL BORE GENERIC ISSUES REPORTS (glr)

LARGE BORE SMALL BORE PROJECT STATUS REPORT PROJECT STATUS REPORT

/

9 PROJECT STATUS REPORTS 3 APPENDIX A C CPRT AND EXTERNAL ISSUES

)

Y Y j PROJECT STATUS REPORT PROJECT STATUS REPORT APPENDIX B APPENDIX B SIGNIFICANT DEFICIENCY SIGNIFICANT DEFICIENCY ANALYSIS REPORTS -

ANALYSIS REPORTS i

l

{ CASE MEETING TOPIC MATRIX i PSR MARCH DECEMBER '

SUB GIR 1987 1987 ISSUE TITLE APPENDIX APPENDIX MEETING NEETING RICHMOND INSERTS Al A X X LOCAL STRESS IN PIPING A2 B X WALL-TO-WALL AND FLOOR-TO-CEILING SUPPORTS A3 C X i

PIPE SUPPORT / SYSTEM STABILITY A4 D X X PIPE SUPPORT GENERIC STIFFNESS AS E X UNCINCHED U-BOLT ACTING AS A TWO-WAY A6 F X RESTRAINT FRICTION FORCES . A7 G X AWS VERSUS ASME CODE PROVISIONS A8 H X A500, GRADE B TUBE STEEL A9 I X TUBE STEEL SECTION PROPERTIES A10 J X U-BOLT CINCHING All K X AXIAL / ROTATIONAL RESTRAINTS A12 L X BOLT HOLE tiAP A13 M X OBE/SSE - DAMPING A14 N X X SUPPORT MASS IN PIPING ANALYSIS A15 0 X PROGRAF 94ATIC ASPECTS AND QA INCLUDING A16 P X X ITERATIVE DESIGN MASS POINT SPACING A17 Q X HIGH FREQUENCY MASS PARTICIPATION A18 R X FLUID TRANSIENTS A19 5 X k

l l

PSR MARCH DECEMBER SUB GIR 1987 1987 i l ISSUE TITLE APPENDIX APPENDIX MEETING MEETING t

SEISMIC EXCITATION OF PIPE SUPPORT MASS A20 T X LOCAL STRESS IN PIPE SUPPORT MEMBERS A21 U X  !

SAFETY FACTORS A22 V X SA-36 AND A307 STEEL A23 W X

U-BOLT TWISTING A24 X X**

i FISHER /CROS8Y VALVE MODELING/0UALIFICATION A25 Y X i PIPING MODELING A26 Z X WELDING A27 AA X X~

ANCHOR BOLTS /EMBEDMENT PLATES A28 88 X -

i STRUT /SNU88ER ANGULARITY A29 CC X i COMPONENT GUALIFICATION . A30 DD X l ' STRUCTURAL MODELING FOR FRAME ANALYSIS A31* A,E,U X***

COMPUTER PROGRAM VERIFICATION AND USE A32* -

X HYDROTEST A33* FF X SEISMIC /NONSEISMIC INTERFACE A34* FF X OTHER ISSUES 435* -

X i

SSER-8 REVIEW A36 EE X SSER-10 REVIEW A37 FF X SSER-11 REVIEW A38 GG X CPRT GUALITY OF CONSTRUCTION REVIEW ON A39* -

X PIPING AND PIPE SUPPORTS PIPE SUPPORT WELD REVIEW TASK - -

X

  • INDICATES ISSUES INCLUDED IN THE PSR ADDITIONAL TO THE ORIGINAL 33 GENERIC ISSUES
    • WAS PRESENTED AS PART OF GIR APPENDIX L
*** WAS PRESENTED AS PART OF GIR APPENDIX A, E AND U i

\

i PSR SUBAPPENDIX A1_

. (GIR APPENDIX A)

RICHMOND INSERTS ADDITIONAL EXTERNAL SOURCE CONCFRNS:

0 FATIGUE LIFE OF THREADED ROD / BOLT l

SA-36 MATERIAL USED FOR THREADED ROD IN RICHMOND INSERTS COULD EXPERIENCM FATIGUE FAILURE DUE TO THE HIGH NUMBER OF LOAD CYCLES.

O ALLOWABLE SPACING OF RICHMOND INSERTS l RICHMOND INSERT ALLOWABLES SHOULD BE REDUCED FOR CLOSE SPACING.

Al-1

Q PSR SUBAPPENDIX Al

. (GIR APPENDIX A)

RICHMOND INSERTS (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION 0 ASME AND AISC DEFINE THE LOWER BOUND STRESS CYCLE VALUE FOR CONSIDERATION OF FATIGUE AS 20,000. SWEC HAS DEMONSTRATED THAT THE NUMBER OF EQUIVALENT STRESS CYCLES FOR PIPE SUPPORTS AT CPSES IS LESS THAN 7,000. THEREFORE, FATIGUE IS NOT A RELEVANT CONCERN.

O SWEC IS PERFORMING A WALKDOWN TO IDENTIFY RICHMOND INSERT SPACING (FVM-075). THIS ACTUAL INSERT SPACING WILL BE USED TO REDUCE THE ALLOWABLE LOADS USING TME METHODOLOGY CONTAINED IN CPPP-7, ATTACHMENT 4-5.

1 e

Al-2

}

l

% 9 PSR SUBAPPENDIX A4 (GIR APPENDIX D)

PIPE SUPPORT / SYSTEM STABILITY ADDITIONAL EXTERNAL SOURCE CONCERNS:

0 STRUT-COLUMN STABILITY THE CONCERN IS THAT THE STABILITY (ALLOWABLE AXIAL LOAD)<0F THE STRUT-COLUMN ASSEMBLY MAY NOT BE ADEGUATELY REPRESENTED BY THE BUCKLING CAPACITY OF EACH MEM5ER 1 l

e  !

A

' - ~

's v.

A4-1 l

)

PSR SUBAPPENDIX A4

, (GIR APPENDIX D)

PIPE SUPPORT / SYSTEM STABILITY

. (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION 0 THE EQUATIONS TO EVALUATE THE STRUT-COLUMN ASSEMBLY CRITICAL BUCKLING LOAD ARE PROVIDED IN SECTION 4.2.4 AND ATTACHMENT 4-9 0F CPPP-7.

A4-2

i PJR SUBAPPENDIX A14 l

. (GIR APPENDIX N)

OBE/SSE DAMPING ADDITIONAL EXTERNAL SOURCE CONCERNS:

0 THE CONCERN WAS THAT DAMPING VALUES USED IN THE ORIGINAL ANALYSIS WERE HIGHER THAN THE VALUES IN NRC REGULATORY GUIDE 1.61 AND WHETt'ER PROPER DAMPING VALUES WERE USED IN THE ORIGINAL ANALYSIS OF MIXED iIZE PIPING SYSTENS.

l i l 1

l O

A14-1

PSR SUBAPPENDIX A14 t

. -(GIR APPENDIX N) l OBE/SSE DAMPING (CONTINUED)

ISSUE RESOLUTION 0

CPPP-7 LIMITS DAMPING VALUES TO THOSE LISTED IN REGULATORYGUIDE 1,61 OR CODE CASE N-411 (USE OF CODE CASE N-411 HAS BEEN APPROVED BY THE NRC).

O MIXED SIZE PIPING SYSTEMS ARE CONSERVATIVELY EVALUATED WITH THE LOWER DAMPING VALUES-OF RG 1.61 WHEN RG 1.61 DAMPING IS USED.

e A14-2 i

e

PSR SUBAPPENDIX A14

-(GIR APPENDIX N)

OBE/SSE DAMPING (CONTINUED)

IMPLEMENTATION 0 REGULATORY GUIDE 1.61 AND CODE CASE N-411 DAMPING VALUES ARE SPECIFIED IN CPPP-7, SECTION 3.4.5.4.1.

0 THE PROPER USE 1

OF DAMPING VALUES IS A REVIElf ITEM IN THE PIPE i STRESS ANALYSIS CHECKLISTS OF CPPP-6 AND CPPP-9.

l A14-3

i PSR SUBAPPENDIX A16 i (GIR APPENDIX P)

PROGRAMMATIC ASPECTS AND QA INCLUDING ITERATIVE DESIGN l 1

ADDITIONAL EXTERNAL SOURCE CONCERNS l

0 ORIGINAL CALCULATIONS DID NOT FOLLOW PROJECT GUIDELINES FOR QUALITY ASSURANCE. NC STANDARDS WERE SPECIFIED FOR THE QUALIFICATION OF PERSONNEL AT DIFFERENT LEVELS. ,

O PROBLEMS WHICH WERE GENERIC IN NATURE WERE NOT RESOLVED PROMPTLY DURING THE ORIGINAL DESIGN EFFORT.

0 ORIGINAL PROCEDURES FOR CONSTRUCTION AND INSTALLATION WERE INADEQUATE AND WEPE NOT UPDATED.

O FREQUENT CHANGES AND LACK OF ADEQUATE CONTROL OF ORIGINAL PROCEDURES RESULTED IN MANY VIOLATIONS OF THE PROCEDURES.

O IN RANDOM CHECKS OF ORIGINAL CALCULATIONS, ERRORS WERE FOUND.

l l

4 A16-1

PSR SUBAPPENDIX A16  !

_(GIR APPENDIX P)  :

PROGRAMMATIC ASPECTS AND QA INCLUDING ITERATIVE DESIG (CONTINUED) u ISSUE RESOLUTION / IMPLEMENTATION I

l 0 l ALL ACTIVITIES OF THE PIPING AND PIPE SUPPORT CORRECTIVE ACTION PROGRAM ARE PERFORMED IN ACCORDANCE WITH SWEC'S QUALITY ASSURANCE (QA) PROGRAM.

O SWEC'S QA PROGRAM INCLUDES THE DEVELOPMENT OF PROCEDURES AND DESIGN CRITERIA COVERING THE ESSENTIALS OF THE PIPING AND SUPPORT VALIDATION PROCESS. GENERIC PROBLEMS ARE REVIEWED FOR REPORTABILITY IN ACCORDANCE WITH SWEC ENGINEERING ASSURANCE PROCEDURES AND CPPP-19. '

0 SWEC EA, TU ELECTRIC TECHNICAL AUDIT PROGRAM (TAP) AND SWEC'S ENGINEERING FUNCTIONAL EVALUATION (EFE) PROGRAM AUDITS EVALUATED THE TECHNICAL ADEQUACY OF THE ENGINEERING PRODUCTS (E.G, CALCULATIONS, DRAWINGS AND SPECIFICATIONS).

O TIMELY AMD COMPLETE RESPONSES ARE DEVELOPED FOR EVERY ITEM IDENTIFIED THROUGHOUT THE AUDIT PROCESS AND APPROPRIATE CORRECTIVE AND PREVENTIVE ACTION ARE TAKEN WHENEVER THEY ARE REQUIRED.

A A16-2

PSR SUBAPPENDIX A16

. (GIR APPENDIX P)

PROGRAMMATIC ASPECTS AND QA INCLUDING ITERATIVE DESIGN

. (CONTINUED) 0 THE FOLLOWING LIST OF AUDIT SUBJECTS DESCRIBE THE DEPTH OF THE AUDITING BEING PERFORMED.

O ADEQUACY OF THE SWEC-PSAS DESIGN PROCEDURE 0 ADEQUACY OF THE SWEC-PSAS PROJECT PROCEDURES j 0 CALCULATIONS - TECHNICAL ADEQUACY ,

O CALCULATION - DOCUMENTATION ,

0 DOCUMENT CONTROL 0 INDOCTPINATION AND kRAINING 0

PERSON'tEL QUALIFICATION AND EXPERIENCE VERIFICATION 0

SYSTEh INPUTS TO PIPE STRESS AND SUPPORT ANALYSIS 0 CONSTRUCTION SUPPORT t.cTIVITIES 0 COMPLIANCE WITH PROJECT PROCEDURES 0

SWEC-PSAS REVIEWED AND VALIDATED INSTALLATION SPECIFICATIONS AND REVIEWED THE RESULTING TH3PECTION PROCEDURES TO ASSURE CONSISTENCY WITH OUR ENGINEERING REQUIREMENTS.

l l

0 A16-3

. a l \

~

. 1 l

PSR SUBAPPENDIX A27 (GIR APPENDIX AA)

WELDING 1

1 ADDITIONAL EXTERNAL SOURCE CONCERNS 0 DESIGN OF WELDED / BOLTED CONNECTIONS NO EVIDENCE WAS FOUND THAT WELDS ON BASE PLATES ATTACHED TO THE STRUCTURE WITH COMBINATION OF WELDS AND BOLTS WERE ORIGINxLLY DESIGNED FOR THE ENTIRE SHEAR LOAD IN ACCORDANCE WITH ASME SECTION III PARAGRAPH XVII-2442.

O IMPROPER WELD CALCULATION FOR COMPOSITE SECTIONS THE ORIGINAL DESIGN OF THE WELD BETWEEN THE COVER PLATES AND THE TUBE STEEL OR WIDE FLANGES IN COMPOSITE SECTIONS WAS NOT ALWAYS CORRECT, AtlD NOT ALL THE LOADS WERE CONSIDE9ED.

O LINEAR ANALYSIS THE QUALIFICATION OF BASE PLATE WELDS TO LINEAR ANALYSIS INSTEAD OF PLATE-AND-SHELL REQUIREMENTS WAS QUESTIONED.

l A27-1 ,

l

. . _ , . , _ , . ,---'y -- --! . - , - - - -- ' - - - - - ' - --r'~ ~ - - " ~ ~ - - " ' ~ ' - * ' ' ' " " ' ' - - ' ' ' ' ' '

-' ' ' ~

1' t 1 PSR SUBAPPENDIX A27,

. (GIR APPENDIX AA)

WELDING (CONTINUED)

I ISSUE RESOLUTION /IMPLEMENTATIO_M i

0 WELDED / BOLTED CONNECTIONS WELDED / BOLTED CONNECTIONS ARE DESIGNED IN ACCORDANCE WITH I PARAGRAPH XVII-2442 0F ASME SECTION III PER CPPP-7 O WELD CALCULATION FOR COMPOSITE SECTIONS l l

COVER PLATE WELDS ARE DESIGNED FOR ALL APPROPRIATE LOADS INCLUDING SHEAR FLOW O LINEAR ANALYSI_S  !

l ASME SECTION III, SUBSECTION NF-1230 ALLOWS THE USE OF EITHER  ;

PLATE-ANU-SHELL OR LINEAR SUPPORT RULES FOR THE DESIGN OF WELDS {

l CONNECTING LINEAR AND PLATE AND SHELL ELEMENTS i

=

CPPP-7 ATTACHMENT 4-2 PROVIDES DESIGN GUIDANCE FOR PIPE SUPPORT WELDS.

e A27-2

l l

PSR SUBAPPENDICES A17. A18 (GIR APPENDIX 0/R)

HIGH FREQUENCY MASS PARTICIPATION / MASS POINT SPACING EXTERNAL SOURCE CONCERNS:

0 THE ORIGINAL PIPE STRESS SEISMIC ANALYSES DID NOT INCLUDE SUFFICIENT MODES TO COMPLY WITH THE FSAR REQUIREMENT THAT THE INCLUSION OF ADDITIONAL MODES DOES NOT RESULT IN MORE THAg A 10%

INCREASE IN THE SYSTEM RESPONSE.

i 0 THE MASS POINT SPACING IN THE ORIGINAL ANALYSES DID NOT ALWAYS  !

MEET THE ORIGINAL PROJECT CRITERIA.

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A17-1 I

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t PSR SUBAPPENDICES A17, A18 (GIR APPENDIX Q/R)

_HIGH FREQUENCY MASS PARTICIPATION / MASS POINT SPACING 1

~

(CONTINUED)  !

ISSUE RESOLUTION / IMPLEMENTATION 0 MASS PARTICIPATION CPPP-7, SECTION 3.10.6.8 ESTABLISHES THE FOLLOWING TWO / OPTIONS FOR THE SEISMIC ANALYSIS OF PIPING (WHICH COMPLY WITH NUREG/CR-1161):

l 0 SEISMIC ARS MODAL ANALYSIS WITH 50-Hz CUT-OFF FREQUENCY, INCLUDING THE MISSING MASS CORRECTION (NUPIPE-SW V04/LO2 OR I LATER ISSUE).

O A CONSTANT ACCELERATION ANALYSIS BY USING THE zERO-PERIOD ACCELERATION VALUES IN ALL THREE DIRECTIONS. THESE RESULTS ARE THEN COMBINED WITH THE 50 Hz ARS RESULTS THAT DO NOT  !

INCLUDE THE HIGH-FREQUENCY MISSING MASS CORRECTION, BY THE j

SQUARE ROOT OF THE SUM OF THE SQUARES METHOD. l 0 MASS POINT SPACING l

l 0 GUIDANCE FOR LOCATING LUMPED MASS POINTS IN PIPING SYSTEMS IS INCLUDED,IN ATTACHMENT 3-7 0F CPPP-7.

O MASS POINT SPAC:tNG IS A REVIEW ITEM ON THE CPPP-6 & CPPP-9 PIPE STRESS ANALYSIS CHECKLISTS.

l A17-2 l

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PSR SUBAPPENDIX A19 (GIR APPENDIX S) i a

FLUID TRANSIENTS EXTERNAL SOURCE CONCERNS:

0 THE COMPLETENESS OF THE FLUID TRANSIENT IDENTIFICATION AND THE ADEQUACY OF FLUID TRANSIENT ANALYSES IN THE ORIGINAL DESIGN EFFORT WERE QUESTIONED.

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o A19-1

- 1 s

PSR SUBAPPENDIX A19

. (GIR APPENDIX S)

FLUID TRANSIENTS i (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION 0

FLUID TRANSIENTS WERE IDENTIFIED BY SWEC AS FOLLOWS:

0 USING THE GUIDANCE GIVEN IN NUREG-0582 s 0

BASED ON PAST EXPERIENCE WITH OTHER PWR'S OF SIMILAR DESIGN 0 OVERALL ASSESSMENT '0F SYSTEM FLOW DIAGRAMS AND COMPONENT OPERATING CHARACTERISTICS.

O SPECIFIC FLUID TRANSIENTS ARE IDENTIFIED AND SUMMARIZED IN CPPP-10, ATTACHMENT 1.

0 NUPIPE-SW PROGRAM IS USED BY SWEC FOR FLUID TRANSIENT ANALYSES.

GUIDANCE FOR FLUID TRANSIENT ANALYSIS IS PROVIDED IN CPPP-7, SECTION 3.4.5.5 AND ATTACHMENT 3-1.  !

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1 A19-2 l

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PSR SUBAPPENDIX A25 (GIR APPENDIX Y)

FISHER / CROSBY VALVE MODELING/0UALIFICATION EXTERNAL SOURCE CONCERNS:

0 THE ASSUMPTION OF A 55/45 RATIO TO ACCOUNT FOR IMBALANCED BLOWDOWN LOADS IN THE DOUBLE PORTED CROSBY SAFETY RELIEF VALVE WAS QUESTIONED.

O MODELING OF "FLEXIBLE" VALVES (F $ 33 Hz) IN THE ORIGINAL ANALYSIS DID NOT ACCOUNT FOR YOKE FLEXIBILITY.

O FISHER VALVE OPERATORS MAY NOT HAVE BEEN QUALIFIED TO WITHSTAND THE LOADS IMPOSED ON THEM BY THE VALVE OPERATOR SUPPORTS.

O VALVE ACCELERATIONS AND FLANGE LOADS WERE NOT ALWAYS CHECKED IN THE ORIGINAL PIPING ANALYSIS.

e A25-1

- - - - f -- -- - , , _ , _ , . - -

_,._-_,,,,,.._,,,,,_,_,--,,,,_-.,_.,.,,,_n,, , , , , . , , . _ , , _ . , , - , , _ , - - .

PSR SUBAPPENDIX A25 l

(GIR APPENDIX Y) i FISHER / CROSBY VALVE MODELING/ QUALIFICATION  !

. (CONTINUED) l ISSUE RESOLUTION 0 THROUGH DISCUSSIONS WITH CROSBY VALVE REGARDING THE DOUBLE PORTED SRV FLOW DISTRIBUTION, IT WAS VERIFIED THAT THE FLOW DISTRIBUTION IS 50/50 INHERENT IN THE DESIGN. HOWEVER, FOR CONSERVATISM, AN IMBALANCE OF 10% IS ASSUMED, RESULTING IN A 55/45 LOAD DISTRIBUTION. l l

i 0 THE YOKES OF "FLEXIBLE" VALVES ARE MODELED TO PROPERLY PREDICT I

THE VALVE ASSEMBLY FREQUENCY.

j 0 SWEC EVALUATED THE FISHER VALVE SUPPORT CONCERN AND CONCURRED j WITH THE REQUIREMENTS FOR INTERFACE CONTROL OF SUPPORTED VALVE ,

OPERATORS.  !

l 0 VALVE ACCELERATIONS AND FLANGE LOADS ARE EVALUATED IN THE PIPING ANALYSIS.

e A25-2

PSR SUBAPPENDIX A25

. (GIR APPENDIX Y) I l

FISHER / CROSBY VALVE MODELING/0UALIFICATION l

. -(CONTINUED)

IMPLEMENTATION 0 CPPP-7, SECTION 3.4.5.6 DEFINES THE APPLICABLE ANALYTICAL METHOD FOR THE DESIGN AND ANALYSIS OF OPEN DISCHARGE SRV PIPING SYSTEMS.

A 55/45 FLOW DISTRIBUTION BETWEEN DISCHARGING BRANCHES IS CONSERVATIVELY USED.

O CPPP-7, SECTION 3.10.6.5 ADDRESSES THE PROPER VALVE YOKE MODELING OF "FLEXIBLE" VALVES.

O VALVE SUPPORT LOADS ARE TRANSMITTED TO THE RESPONSIBLE l ORGANIZATION FOR DESIGN ACCEPTANCE EVALUATION IN ACCORDANCE WITH l CPPP-6, SECTION 7.4.3 AND CPPP-9, SECTION 7.4.1.3.

0 VALVE ACCELERATIONS AND FLANGE LOADINGS ARE EVALUATED IN ACCORDANCE WITH CPPP-7, SECTION 3.10.5.2. 1 i

4 A25-3 1

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_ _ _ _ _ , ._, . - . . . - --- -- - - - - - - ' ~ ~ ~ ~ ~ ^ ' ~ ~ ~ ~ ~~

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PSR SUBAPPENDIX A26 (GIR APPENDIX Z)

PIPING MODELING EXTERNAL SOURCE CONCERNS:

0 A FEW INSTANCES WERE FOUND WHERE INCORRECT INPUTS WERE USED IN THE ORIGINAL PIPE STRESS ANALYSES AS FOLLOWS:

0 IMPROPER STRESS INTENSIFICATION FACTORS WERE USEb IN A STRESS PROBLEM. '

0 FLUID AND INSULATION WEIGHTS WERE NOT INCLUDED FOR VALVES AND FLANGES.

O INCORRECT PIPE WALL THICKNESS WAS USED.

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I PSR SUBAPPENDIX A26

-(GIR APPENDIX Z)

. PIPING MODELING ISSUE RESOLUTION / IMPLEMENTATION 0 CPPP-7, SECTION 3.0 PROVIDES GUIDANCE FOR THE PROPER MODELING OF PIPING SYSTEMS.

O CPPP-6 & -9 INCLUDE CHECKLISTS TO ASSURE'THAT APPROPRIATE j PIPING MODELS ARE CREATED AND ADEQUATE REVIEW OF THE INPUT AND.0UTPUT IS PERFORMED.

O PIPING AND SUPPORT CALCULATION INPUTS ARE PREPARED AND REVIEWED IN ACCORDANCE WITH SWEC ENGINEERING ASSURANCE PROCEDURES.

O PERSONNEL ARE TRAINED IN THE USE OF THE APPROPRIATE PROCEDURES.  !

l 0 AUDITS OF PROJECT ACTIVITIES PERFORMED BY SWEC ENGINEERING ASSURANCE, TV ELECTRIC TECHNICAL AUDIT PROGRAM AND ENGINEERING FUNCTIONAL EVALUATION PROVIDE ASSURANCE THAT THE PROCEDURAL i REQUIREMENTS ARE MET AND THAT THE WORK IS TECHNICALLY ADEQUATE.

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A26-2 P

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-e---ee- --

e PSR SUBAPPENDIX A28

. (GIR APPENDIX BB)

ANCHOR BOLTS /EMBEDMENT PLATES EXTERNAL SOURCE CONCERNS:

THE FOLLOWING CONCERNS WERE RAISED REGARDING THE ORIGINAL DESIGN:

0 EMBEDMENT PLATES 0 THE SPACING OF ATTACHMENTS ON EMBEDDED PLATES WAS NOT CHECKED 0 NO PROCEDURE FOR THE DESIGN OF STIFFENERS REQUIRED FOR MOMENT CONNECTIONS TO EMBEDDED PLATES WAS PROVIDED 0 THROUGH-BOLTS 0 LOADS FROM PIPE SUPPORTS UTILIZING THROUGH-BOLTS WERE NOT TRANSMITTED TO THE STRUCTURAL DISCIPLINE FOR ACCEPTANCE.

O BASE PLATE EDGE DISTANCE O THE BASE PLATE EDGE DISTANCE TOLERANCE WAS NOTED AS HAVING THE POTENTIAL OF INCREASING PLATE STRESSES BY 15% IN CERTAIN SUPPORT CONFIGURATIONS A28-1

l .

l s PSR SUBAPPENDIX A28

. (GIR APPENDIX BB) l ANCHOR BOLTS /EMBEDMENT PLATES (CONTINUED)

EXTERNAL SOURCE CONCERNS:

l O ANCHOR BOLT EMBEDMENT LENGTH i

0 DIFFERENCES WERE NOTED BETWEEN ANCHOR BOLT EMBEDMENT LENGTHS  !

SHOWN ON THE SUPPORT D RAWINGS AND THOSE USED IN THE CALCULATIONS.

O ANCHOR SPACING VIOLATIONS l

0 INSTANCES WERE OBSERVED WHERE PIPE SLEEVE PENETRATIONS EXISTED CLOSE TO SUPPORT BASE PLATES BUT WERE NOT SHOWN ON

{

THE SUPPORT DRAWINGS 0 SEVERAL INSTANCES WERE OBSERVED WHERE HILTI-KWIK BOLTS WERE INSTALLED CLOSE TO THROUGH-BOLT BASE PLATES BUT WERE NOT SHOWN ON THE SUPPORT DRAWINGS.

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A28-2

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PSR SUBAPPENDIX A28 (GIR APPENDIX BB)

ANCHOR BOLTS /EMBEDMENT PLATES (CONTINUED)  !

ISSUE RESOLUTION / IMPLEMENTATION 1

0. EMBEDMENT PLATES /THROUGH BOLTS 0 EMBEDMENT PLATE DESIGN AND ATTACHMENT SPACING ARE VALIDATED BY SWEC CIVIL / STRUCTURAL DISCIPLINE I O EMBEDMENT PLATE, BASE PLATE, AND THROUGH-BULT LOADS ARE TRANSMITTED IN ACCORDANCE WITH CPPP-6 AND CPPP-9 TO SWEC CIVIL / STRUCTURAL DISCIPLINE FOR EVALUATION l

0 BASE PLATE EDGE DISTANCE 0 THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)

VALIDATES THE AS-BUILT BASE PLATE BOLT HOLE EDGE DISTANCES 0 ANCHOR BOLT EMBEDMENT LENGTH 0 VALIDATED ANCHOR BOLT EMBEDMENT LENGTHS ARE SHOWN ON THE PIPE SUPPORT DRAWINGS AND ARE USED TO VALIDATE PIPE SUPPORT ANCHORAGE DESIGNS IN ACCORDANCE WITH CPPP-7, ATTACHMENT 4-4 O ANCHOR SPACING VIOLATIONS 0 DURING PCHVP SWEC CIVIL / STRUCTURAL DISCIPLINE IDENTIFIES ANCHOR BOLTS INSTALLED CLOSE TO THROUGH-BOLTS AND PIPE SLEEVE PENETRATIONS 0 ANCHOR SPACING VIOLATIONS ARE EVALUATED IN ACCORDANCE W1 f H CPPP-7 ATTACHMENT 4-4 A28-3

,6 s

PSR SUBAPPENDIX A30 (GIR APPENDIX DD)

COMPONENT QUALIFICATION I 1

l EXTERNAL SOURCE CONCERNS:

1 i

0 DYNAMIC PIPE MOVEMENTS IN SUPPORT DESIGNS NOT ALL APPROPRIATE DYNAMIC PIPE MOVEMENTS WERE INCLUDED IN THE ORIGINAL SUPPORT DESIGN WHEN CHECKING FRAME CLEARANCES,, SWING ANGLES, OR SPRING TRAVEL.

l 0 INCORRECT STANDARD COMPONENT ALLOWABLES INCORRECT U-BOLT ALLOWABLES WERE USED IN THE ORIGINAL DESIGN OF SUPPORT RH-1-064-011-522R 0 UNTIGHTENED LOCKNUTS ON STRUTS AN UNTIGHTENED LOCKNUT ON A STRUT SUPPORT WAS IDENTIFIED. THE CONCERN WAS THAT THE STRUT MAY NOT FUNCTION AS DESIGNED.

O INVERTED $NUBBERS FOUR SUPPORTS WERE IDENTIFIED IN WHICH THE SNUBBER UNIT WAS INSTALLED 180 DEGREES FROM THE CONFIGURATION SHOWN ON THE SUPPORT DRAWING. '-

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s A30-1 l

s PSR SUBAPPENDIX A30

. (GIR APPENDIX DD)

COMPONENT QUALIFICATION (CCHTINUED)

ISSUE RESOLUTIONS / IMPLEMENTATION O PREDICTED PIPE DISPLACEMENTS FOR ALL DESIGN CONDITIONS ARE CONSIDERED IN THE PIPE SUPPORT DESIGN VALIDATION IN ACCORDANCE WITH CPPP-7, SECTION 4.2.

O SUPPORT NO. RH-1-064-011-S22R WAS A CINCHED U-BOLT SUPPORT WITH'A STRUT. IT WAS REDESIGNED IN ACCORDANCE WITH CPPP-7, SECTION  !

4.2.5.1. '

CPPP-7, SECTION 4.1 REQUIRES VERIFICATION OF COMPONENT STANDARD SUPPORTS BY COMPARISON TO VENDOR-SUPPLIED LOAD CAPACITY DATA SHEETS OR CERTIFIED DESIGN REPORT SUMMARIES UNLESS UNIQUELY QUALIFIED BY CALCULATION 0 THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM VALIDATES THE PROPER HARDWARE INSTALLATION, INCLUDING LOCKING DEVICES, THROUGH I INSPECTIONS PERFORMED IN ACCORDANCE WITH FIELD VERIFICATION METHOD CPE-SWEC-FVM-PS-081.

O AN INVERTED SNUBBER HAS NO IMPACT ON THE FUNCTION OF A SNUBBER A30-2

l PSR SUBAPPENDIX A32

. COMPUTER PROGRAM VERIFICATION AND USE EXTERNA'l SOURCE CONCERN:

THERE WAS A CONCERN AS TO THE VERIFICATION AND USE OF THE FOLLOWING COMPUTER PROGRAMS USED FOR THE ORIGINAL DESIGN:

0 ADLPIPE VERSION 2C (DATED APRIL 1977) - PIPING ANALYSIS, O Fus II- BASE PLATE QUALIFICATION - ITT GRINNELL.

O CORNER AND LADA BASE PLATE QUALIFICATION PROGRAM.

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PSR SUBAPPENDIX A32 COMPUTER PROGRAM VERIFICATION AND USE (CONTINUED)

ISSUERESOLUTION/IMPLEMENTkTION:

0 THE COMPUTER PROGRAMS LISTED HAVE NOT BEEN USED IN THE SWEC VALIDATION EFFORT, O SWEC COMPUTER PROGRAMS ARE:  !

O IDENTIFIED IN CPPP-7, SECTIoN 5.0.

O VERIFIED FOR TECHNICAL ADEQUACY AND VERSIONS ARE 00NTROLLED IN ACCORDANCE WITH SWEC QA REQUIREMENTS.

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A32-2

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PSR SUBAPPENDIX A36

.(GIR APPENDIX EE)

. SSER 8. REVIEW

~

l EXTERNAL SOURCE CONCERN:

1 0 THE CONCRETE DESIGN STRENGTH OF SAFETY-RELATED CONCRETE,  ;

l INSTALLED BETWEEN JANUARY 1976 AND FEBRUARY 1977, WAS QUESTICNED. l THE CONCRETE STRENGTH IS A DESIGN INPUT FOR RICHMOND INSERT AND HILTI BOLT ALLOWABLES.

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PSR SUBAPPENDIX A36 (GIR APPENDIX EE)

SSER 8 REVIEW ISSUE RESOLUTION l

0 THE SWEC CIvrt/3TRUCTURAL GROUP VALIDATED THE DESIGN STRENGTH OF THE SAFETY RELATED CONCRETE PLACED DURING THE PERIOD IN QUESTION TO BE AT LEAST 4,000 PSI. THIS WAS USED AS INPUT TO ESTABLISH RICHMOND INSERT AND HILTI ALLOWABLES.

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PSR SUBAPPENDICES A33 .

A34, A37 (GIR APPENDIX FF)

SSER'-10 REVIEW, HYDR 0 TEST, SEISMIC /NONSEISMIC INTERFACE EXTERNAL SOURCE CONCERNS:

0 UNCONTROLLED WELD REPAIRS BY PLUG WELDING ON CABLE TRAY SUPPORTS, PIPE SUPPORTS AND BASE PLATES MAY AFFECT THE STRUCTURAL INTEGRITY OF THE COMPONENT 1 0

THE SEQUENCE OF STEPS FOLLOWED FOR THE HYDROSTATIC TESTING OF THE UNIY Il LOOP #1 MAIN STEAM AND FEEDWATER LINES MAY HAVE AFFECTED THE INTEGRITY OF THE COMPONENTS 0

HYDROTEST LOADING CONDITIONS WERE NOT PROPERLY CONSIDERED IN T!iE ORIGINAL PIPING ANALYSIS AND SUPPORT DESIGN 0 TYPE II SKEWED WELDS (ATTACHMENTS-TO-PIPE) ON PIPE SUPPORTS MAY BE UNDERSIZED 0 SEISMIC /NONSEISMIC INTERFACE O

THE SEISMIC EFFECTS OF NONSEISMIC PIPING ATTACHED TO SAFETY RELATED PIPING WERE NOT ADEQUATELY CONSIDERED IN THE ORIGINAL DESIGN 0

FOR SAFETY RELATED PIPING ROUTED BETWEEN SEISMIC CATEGORY 1 BUILDINGS AND NONSEISMIC BUILDINGS:

A. PIPING WAS NOT SEISMICALLY ISOLATED B. THE POSTULATED FAILURE OF THE NONSEISMIC BUILDING WAS NOT CONSIDERED A37-1

I PSR SUBAPPENDICES A33. A34. A37 (GIR APPENDIX FF)

SS_ER-10 REVIEW HYDROTEST. SEISMIC /NON_ SEISMIC INTERFACE (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

0 UNCONTROLLED PLUG WELDS l

0 THE CPRT ACTION PLAN V.D. (NRC TRT ISSUE V.D) RESULTS REPORT CONCLUDED THAT UNAUTHORIZED PLUG WELDS REPAIR DID NOT COMPROMICE THE STRUCTURAL INTEGRITY OF COMPONENTS. SWEC CONCURS WITH THIS CONCLUSION.

O PIPE SUPPORT INSTALLATION AND INSPECTION CRITERIA HAVE BEEN REVISED TO PROHIBIT UNCONTROLLED PLUG WELD REPAIRS 0 UNIT #1 LOOP #1 MAIN STEAM HYDROSTATIC TESTING 0

THE CPRT ACTION PLAN V.E. (NRC TRT ISSUE V.E) .RESULTS REPORT CONCLUDED THAT NO DELETERIOUS EFFECTS RESULTED FROM THE POSTULATED SEQUENCE OF EVENTS ASSOCIATED WITH THE UNIT #1 LOOP #1 MAIN STEAM AND FEEDWATER LINES HYDROSTATIC TESTS.

SWEC CONCURS WITH THIS CONCLUSION.

A37-2

l PSR SUBAPPEND CES A33, A34 A37 (GIR APPENDIX FF) i SSER-10 REVIEW, HYDROTEST, SEISMIC /NONSEISMIC INTERFACE  ;

(CONTINUED) 115.E RESOLUTION / IMPLEMENTATION: (CONTINUED)

O CONSTRUCTION PROCEDURE CP CPM-1.2 AND SWEC-PSAS PROCEDURE CPSP-30 REQUIRE ENGINEERING EVALUATION OF THE INSTALLED '

PIPING AND PIPE SUPPORT CONFIGURATIONS INCLUDING THE PROPER DESIGN OF TEMPORARY SUPPORTS PRIOR TO A HYDROTEST 0 HYDROTEST O PIPING AND SUPPORTS ARE

] EVALUATED FOR HYDROTEST LOADING IN ACCORDANCE WITH CPPP-7, SECTION 3.6.2.4 AND 4.7.2 0

TYPE II SKEWED WELDS (ATTACHMENTS-TO-PIPE) ON PIPE SUPPOP1S 0 THE TYPE II SKEWED WELDS IN QUESTION ARE TYPICALLY FOUND AT THE JUNCTION OF PIPES AND TRUNNIONS O THE CPRT ACTION PLAN V.A RESULTS REPORT CONFIRMED THAT INSPECTIONS OF SUCH WELDS HAVE BEEN PERFORMED IN ACCORDANCE WITH PIPING AND EQUIPMENT INSTALLATION INSPECTION PROCEDURE QI-QAP-11.1-26, AND ARE ACCEPTABLE. SWEC CONCURS THAT THE WELDS ARE ACCEPTABLE.

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PSR SUBAPPENDICES A33, A34, A37

.(GIR APPENDIX FF)

SSER'-10 REVIEW, HYDROTEST, SEISMIC /NONSEISMIC INTERFACE (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

0 .QI-0AP-11.1-28, FABRICATION AND INSTALLATION INSPECTION OF SAFETY CLASS COMPONENT S'UPPORTS, WAS REVISED TO INCLUDE INSPECTION PROCEDURES WHERE THE SUBJECT SKEW WELDS OCCUR IN PIPE SUPPORTS 0 SEISMIC /NONSEISMIC INTERFACE 0 THE DEFIGN PROCEDURE FOR INTERFACE ANCHORS IS CONTAINED IN ATTACHMENT 4-10 0F CPPP-7 0 Two METHODS ARE USED FOR THE DESIGN VALIDA710N OF SAFETY l RELATED PIPING ATTACHED TO NONSEISMIC PIPING l

A37-4

W .

i PSR SUBAPPENDICES A33 A34, A37 l

l 1

(GIR APPENDIX FF)  !

i SSER-10 REVIEW, HYDROTEST, SEISMIC /NONSEISMIC INTERFACE (CONTINUED)

1. A PLASTIC HINGE MOMENT IS APPLIED ON THE NONSEISMIC l SIDE TO THE INTERFACE ANCHOR
2. A PORTION OF THE PIPING AND SUPPORTS ON THE NONSEISMIC SIDE WERE SEISMICALLY ANALYZED. THE EFFECT OF THE REMAINING PORTION OF THE NONSEISMIC PIPING IS ACCOUNTED '

FOR BY THE APPLICATION OF A PLASTIC HINGE MOMENT 0 A PLASTIC HINGE MOMENT IS APPLIED TO THE SAFETY RELATED PIPING ROUTED BETWEEN SEISMIC CATEGORY 1 AND NONSEISMIC BUILDINGS i

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/

PSR SUBAPPENDIX A38

_(GIR APPENDIX GG)

SSER-11 REVIEW JXTERNAL SOURCE CONCERN:

SSER-11 DESCRIsES THE NRC STAFF TRT POSI1 ION ON THE EVALUATION AND i RESOLUTION OF TECHNICAL QUESTIONS AND ALLEGATIONS RELATING TO THE [

QA/QC group. '

i THE ISSUES IDENTIFIED IN SSER-11 THAT ARE RELATED TO PIPING DESIGN ARE: .

l 0

AS-nu!LT INSPECTION PROGRAM (SEE SUBAPPENDIx A39)

O Ex:ESS SNUBBER SPHERICAL BEARING CLEARANCE O

MISSING STRUT AND SNUBBER LOAD PIN LOCKING DEVICES 0

PTPE CLAMP HALVES WERE NOT PARALLEL 0

SNUBBER ADAPTER PLATE BOLTS WERE NOT FULLY ENGAGED I O HILTI-KWIK BOLTS WERE INSTALLED WITH LESS THAN MINIMUM EMBEDMENT 0 AsSENCE OF LOCKING DEVICES FOR THREADED FASTENERS ON NF SUPPORTS O ISOLATION AN_CHOR$ (SEE SSER-10, SusAPPENDIx A37) 0 MAIN STEAM LOOP HYDRO (SEE SSER-10, SusAPPENDIx A37)

O RADIAL SHRINKAGE OF GIRTH WELOS IN THIN-WALL STAINLESS STEEL WAS NOT ADEQUATELY CONSIDERED IN THE ANALYSIS.

A38-1 I

1 PSR SUBAPPENDIX A38 (GIR APPENDIX GG)

SSER-11 REVIEW (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION 0 AS-BUILT INSPECTION PROGRAM 6

0 SEE SUBAPPENDIx A39 e, O Is0LATION ANCHOR 3 ,,

O SEE SURAPPENDIx A37 0 MAIN STEAM LOOP HYDRO O SEE SUBAPPENDIx A37 0

THE EFFECTS OF RADIAL SHAINKAGE OF GIRTH WELDS ON THE PIFE STRESS ANALYSIS ARE ANALYZED IN ACCORDANCE WITH CPPP-7, ATTACHMENT 3-15, 1

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A38-2

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PSR SUBAPPENDIX A35 OTHER ISSUES ,

i EXTERNA'L SOURCE CONCERN:

0 TERA CATALOGED AND PROVIDED TO SWEC 972 EXTERNAL SOURCE DISCREPANCY ISSUE REPORTS (DIRS) RELATED TO THE ORIGINAL DESIGN.

O ALL BUT 51 oF THESE 972 DIRS WERE CONSOLIDATED INTO THE TOPICS ADDRESSED IN PSR SUBAPPENDICES A1 THRu A34 0

THE REMAINING 51 DIRS ARE MISCELLANEOUS AND MINOR TOPICS 4

e A35-1

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I PSR SUBAPPENDIX A35 OTHER ISSE E (CONTINUED) .

ISSUE 92'OLUT:{ON/ IMPLEMENTATION:

0 SWEC RESOLVED THE ISSUE IDEllT.TFIED IN EACH OF THE 51 OIRS aY REFERENCING THL' APPLICABLE DESIGN OR ADMINISTRATIVE PROCEDURE THAT RESOLVED 2ACH ISSUE O THESE Fs DIRS ARE CONSIDERED CLOSED BY SWEC AND IFE.'

I A35-2 l

w CASE REQUEST  !

l PIPE SUPPORT WELD REVIEW TASK QSE CONCERN '

0 CASE REQUESTED, DURING THC MARCH MECsTING, THAT SOME WELDED JOINTS FROM PIPE SUPPORTS REMOVED FROM CPSES BE EXAMIhED TO VERIFY WELD  !

QUALITY. ,

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WRT 1  :

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CASE REQUEST 4

PIPE SUPPORT WELD REVIEW TASK ISSUE R'SOLUT70N:

E 0 341 MACR 0 SPECIMENS CF SECTIONAL FACES FROM 93 CPSES PIPE WELD JOINTS SELECTED FROM 67 SUPPORTS WERE INDEPENDENTLY EXAPINED BY THREE SWEC WELDING SPECIALISTS.

O ALL 341 SPECIMENS WERE DETERMINED TO BE SUFFICIENTLY STRONG TO PERFORM THEIR DESIGN FUNCTION.

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WRT-2

i<

APPENDIX B SIGNIFICANT DEFICIENCY ANALYSIS REPORTS (SDARs)

LARGE BORE SMALL BORE SDAR NUMBER PSR PSR TITLE SDAR-CP-86-33 B1 B1 STIFFNESS VALVES FOR CLASS I STRESS ANALYSIS SDAR-CP-86-36 B2 -

LARGE BORE PIPING AND SUPPORTS SDAR-CP-86-72 -

B2 SMALL BORE PIPING AND SUPPORTS 50AR-CP-86-63 B3 B3 PIPE SUPPORT INSTALL-ATIONS SDAR-CP-86-67 B4 B4 PREoPERATIONAL VIBRA-TION TEST CRITERIA SDAR-CP-86-73 -

B5 B5 ASME SNUBBEn ATTACH-MENT BRACKETS 9

e

- -- ,- - - . , - - - - - + - , ,,,-.n - -- ,, - , ,---

o .s 4

.PSR SUBAPPENDIX B1

-(SDAR CP-86-33)

' STIFFNESS VALUES FOR CLASS 1 STRESS ANALYSIS DEFINITION OF ISSUE:

THE PIPE SUPPORT STIFFNESS VALUES USED IN THE ORIGINAL WESTINGHOUSE CLASS 1 PIPE STRESS ANALYSIS FOR UNIT 1 WERE BASED ON THE ORIGINAL t PIPE SUPPORT STIFFNESS VALUES. AS A RESutT oF THE SWEC CORRECTION ACTION PROGRAM THE CLASS 1 PIPE SUPPORT STIFFNESS VALUES WERE FOUND BE SIGNIFICANTLY DIFFERENT.

1 l

t h

B1-1 i

9

--, , . . . . - . _ - A

O q,.

l

.PSR SUBAPPENDIX B1 (SDAR CP-86-33)

. STIFFNESS VALUES FOR CLASS 1 STRESS ANALYSIS

~

(CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

CLASS 1 PIPE SUPPORT STIFFNESS VALUES ARE CALCULATED IN ACCORDANCE WITH CPPP-7 SECTION 4.3.2.2 AND TRANSMITTED TO WESTINGHOUSE IN ACCORDANCE WITH CPPP-6 & -9.

l 1

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l l

l i

. l B1-2 '

l

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I

  • f*44e i

! 6

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l I

PSR SUBAPPENDIX B3

-(SDAR CP-86-63)

PIPE _ SUPPORT INSTALLATIONS DEFINITION OF ISSUE:

O A BROKEN COTTER PIN WAS IDENTIFIED ON A SNUBBER 83-1 e

e I

i PSR SUBAPPENDIX B3

. (SDAR CP-86-63)

PIPE SUPPORT INSTALLATIONS (CONTINUED)

ISSVE RESOLUTION / IMPLEMENTATION:

0 THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM VALIDATES COTTER PIN INSTALLATIONS.

I Il

'B3-2

. 4. )

J e

PSR SUBAPPENDIX B4 (SDAR CP-86-67)

PREOPERATIONAL VIBRATION TEST CRITERIA DEFINITION OF ISSUE:

0 THE ORIGINAL PREOPERATIONAL VIBRATION TEST CRITERIA CONTAINED STRESS ENDURANCE LIMITS, ALLOWABLE DEFLECTIONS, AND PIPING SYSTEM FLEXIBILITY FORMULAS WHICH MAY NOT HAVE BEEN ACCURATE.

O Two TEST DATA POINTS EXCEEDED THE DEFLECTION LIMITS.

O MEASURED DEFLECTION DIRECTIONS WERE NOT CLEARLY IDENTIFIED.

l 1

l 1

B4-1 '

5 i

i i

PSR SUBAPPENDIX B4 I

-(SDAR CP-86-67) 1 PREOPERATIONAL VIBRATION TEST CRITERIA .

(CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

0 PREOPERATIONAL VIBRATION TESTING WILL BE PERFORMED IN ACCORDANCE WITH CPPP-25 UNIT 1 PIPING VIBRATION TEST PROCEDURE.

I 4

l B4-2 l

l 1

1

,, c!

cr l

PSR SUBAPPENDIX B5 i

. (SDAR CP-86-73)

ASME SNUBBER ATTACHMENT BRACKETS I i

DEFINITION OF ISSUE:  !

t O 31 SAFETY RELATED SUPPORTS WERE INSTALLED WITH REAR BRACKETS ,

WHICH MAY RESTRICT SNUBBER SWING ANGLES.

i i

[

i i

i i

B5-1  !

1 i

j l

. _ _ _ __ ._._ f

E v'

PSR SUBAPPENDIX B5

. (SDAR CP-86-73)

ASME SNUBBER ATTACHMENT BRACKETS (CONTINUED)

ISSUE RESOLUTION / IMPLEMENTATION:

0 ALL SAFETY RELATED SNUBBERS / REAR BRACKETS ARE INSPECTED TO ASSURE NO BINDING IN ACCORDANCE WITH FIELD VERIFICATION METHOD TNE-FVM-PS-038.

O CONSTRUCTION PROCEDURE CP-CPM-9.10A AND QUALITY CONTROL {

PROCEDURES CP-0AP-12.1 AND QI-0AP-11.1-28 REQUIRE A CHECK FOR BINDING FOR NEW INSTALLATIONS.

I B5-2

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1 1

( 2 3

4 5

6 7

8 9 TU ELECTRIC PUBLIC MEETING 10 11 December 18, 1987 12

(- 13 14 15 YOLUME II 0F II 16 l

17 ..

18 RECEIVED 19 DEC 2 31987 ElLLIAM G. COUNSit 21 22 s I i

23 Taken by: Carmen Gooden, CSR, RPR December 17-18, 1987

) 24 ,

(

25 Carmen Goode.1, CSR, RPR, Metro 429-5532

2 f

1 ER0CEED1NG1

( 2 3 (The meeting reconvened at 8:30 a.m.)

4 5 MR. NACE: the meeting will come back to order. Good 6 morning. What I would like to do now is pick up with the SWEC 7 piping project and return to the questions that were addressec .

8 yesterday afternoon.

9 MR, KLAUSE: Good morning, Jack. What we'd like to 10 do is to discuss the areas that were raised at the end of 11 yesterday's meeting. In the order I'd like to go this morning 12 is the moment restraint first, and we've asked Wyn Evans to

{- 13 discuss this question, 14 MR, EVANS: First off, I'd like to restate our 15 understanding of your concerns where we're all talking from i 16 the same basis. The way we understand your concern is that 17 there are certain moment Testraints that are highly

18 constrained due to the shear loads at the base plates. And i 19 the concern is that due to high LOCA temperatures there would 20 be loads developed within the structure that should be 21 considered in the design, '

22 Easically, that's about it. ..

s 23 MR. D0YLE: That's correct. I wouldn't restrict it 24 purely to LOCA; any rapid thermal differential, with LOCA k 25 being the more severe, Carmen Gooden, CSR, RPR, Metro 429-5532

l l 3 -

3 i

l l 1 MR. EVANS: Yes, I guess nny significant increase ir

([ 2 temperature. We have performed a review to see whether any of ,

3 our moment restraints fall into this category. We found one 4 and for that moment restraint the thermal effects are being 5 considered, or are considered.

6 MR. D0YLE: I guess my next question is I knew of at 7 least half a dozen that Here in the plant. What happened 8 with the rest?

9 MR. EVANS: We did -- t 10 MR. D0YLE: I'm not saying that's all that Here l 11 there. That's the ones that I knew. ,

12 MR. EVANS: We did find some others in areas where i

(

13 the increase in environmental temperature Has not significant; 14 therefore, He did not classify that as being pertinent to your 15 concern.

16 MR. D0YLE: I'm assuming that somewhere there is 17 documentation relative to-'SWEC's treatment of the problem; 1s 18 that correct?

19 MR. SISKIN: It would be in the individual 20 calculation.

21 MR. D0YLE: We Hill have access to that?

22 MR. SISKIN: Yes. ,

23 MR. D0YLE: Right offhand -- I mean, I accept your l 2 '

24 answer, but I can't Qualify the support unless I know what's

("

25 .been done.

Carmen Gooden, CSR, RPR, Metro 429-5532

i 4

1 MR. EVANS: Sure.

( 2 MR SISKIN: In order to clarify that, I think the 3 approoriate thing would be why don't I commit to give you a 4 list of all of the moment restraints and the environmental 5 temperature increases that might be encountered and then 6 anything that you feel Hill be appropriate He'll give you a 7 copy of that particular calculation. You obviously can have 8 any calculation you want, but He'll highlight it as to which ,

9 ones might have this thermal temperature consideration and 10 that Hill make it easier for you to check if you Hant to 90 11 back and look at your notes and see.

12 MR. D0YLE: Yes.

( 13 MR. SISKIN: We will provide it to Mr. Couns11 and he 14 can Horry about the copies.  ;

15 MR. KLAUSE: Okay. For the next subject He*re i 16 talking about plug Helds. I'll ask Alan Chan to address that 17 issue. ~ "

r 2

18 MR. CHAN: Jack, He understand your question that you '

19 asked was how did we validate the ISAP results report on the 1 20 uncontrolled plug Helds. Basically, Jack, He reviewed this ,

21 ISAP results report Just like He normally do Hhen He receive 22 design information from other organizations. We Hill look at 23 the reasonableness of the approach, the method and procedures  !

24 used, and the reasonableness of the conclusion of that report. l

(' \

25 And that is basically our involvement. On this specific issue !

Carmen Gooden, CSR, RPR, Metro 429-5532

1 '

5 l

1 of plug Helds What He did was He looked at What was done in

( 2 this investigation and for the ASME pipe supports He note that 3 any base metal repair Hould have to be done with the issuance 4 of what is called a repair process sheet issued by engineering 5 for ASME pipe supports. I Hant to make the distinction.

6 There are two issues involved. One is pipe supports, and the 7 other one is cable trays. So I'm talking about.ASME pipe 8 supports. So any repair Hould require a repair process sheet 9 issued by engineering first of all. Then there was no 10 indication that there Has any unauthor1 Zed repair of these 11 plug Helds done; however, there was one instance in Hhich this 12 Has done on one pipe support, but it Has Caught right after it

{ 13 was done and, in fact, the foreman responsible for that Held 14 Has immediately demoted.

15 So in addition to that, the practice on pipe 16 supports, Hhen you have, let's say, a hole that was not used 17 on this, a drill hole, tG~ reject that s'upport and scrap that 18 particular pipe support.

19 NoH, as part of the investigation, two random 20 samples, each one containing 60 pipe supports, Here selected, 21 and inspectors Here trained and procedures Here developed to 22 try to locate these plug Helds. And of_these 60, two samples 23 of 60, none Has found, no plug Helds Here found on these 24 supports.

25 Another indication is that samples were made out and Carmen Gooden, CSR, RPR, Metro 429-5532

6 1 a couple of test Helding procedures were used to try to create

( 2 these unauthorized plug Helds, and in the process the Helding 3 procedure called for trying to create a bad plug Held.

4 basically, try-to create as much slack as possible. After .l 5 that was made, these Here cut and tested, and in every case it 6 Has found that the strength of the member was stronger where  ;

7 the plug Held was there.  ;

8 And I think Hith that, the final conclusion was that l

[

9 He do recognize that the inspection process is a very simple j 10 thing to do in terms of plug Helds, but in instances where you i 11 can detect it, you will find that in the case of pipe supports

12 none Has found. And in the situation if the plug Held Has  !

{ 13 done so Hell that you cannot detect it, I think the conclusion  ;

14 is that it Has so good that it cannot be detected, then the l

\

15 strength of that member is going to be very good.  !

16 MR. D0YLE: My basic concern is not so much the pipe  !

l 17 supports that are being"done today, but the earlier ones that  ;

18 Here done from 1970 forward. During the hearing there were i

19 allegations that illegal plug Helding was being carried out.  !

(

20 The NRC developed a procedure whereby they could 90 in and

) 21 find some of those, and they did, in fact, find some.

I 22 What I'm concerned with is one of these charges that  !

(

23 Has made was in particularly thick pieces of metal the man  !

2  :

i 4

r 24 could actually make a circular Held, build up a circular Held )

25 at the top plate, turn the plate over and do the same in the  !

1 I c

Carmen Gooden, CSR, RPR, Metro 429-5532 i

i 7

1 bottom plate and leave a void.

( 2 I don't know if any of those Were ever found, but I 3 know that that was an allegation. I qlso know that AWS has 4 changed their code requirements for plug Helding to include 5 volumetric inspection for that very reason.

6 I understand what you're saying and I appreciate Hhat 7 has been done. It appears to be the only viable Hay to 8 approach the problem, and I recognize also that when you're 9 using an X70 rod to cover a piece of metal, you're going to 10 end up Hith at least an equal strength.

11 But my primary concern Has: Is there any way to finc 12 any of these illicit plug Helds where they are voided?

13 MR. CHAN:

( I think the important thing here is that 14 for pipe supports -- again, I Want to emphasize there are two 15 separate issues here, pipe supports and cable trays -- for 16 pipe supports there is enough procedural control that this was 17 not -- there Has reasonab'l'e assurance that this Has not done.

18 MR. D0YLE: I'm quite sure that within the general 19 body of the pipe support it hasn't been done because they're 3

20 all Helded. There were no holes put in them for starters.

21 The only place there could possibly be a problem Hould perhaps 22 be in the tube steel Richmond anchor setup where oversized 23 holes were made, and rather than plug Helding they were fillet 24 in. There were allegations, I believe, to that effect.

I

~

25 In addition to that, there were probabilities on the Carmen Gooden, CSR, RPR, Metro 429-5532

i 8 1 base plate, and I think on the base plate, if there were plug

( 2 Helds, it would be obvious. And I think what I Has looking 3 for: Do you have a procedure in the field walkdown where a 4 man takes a flashlight and takes an oblique look at the base 5 plate? I don't think you're going to find any in the main 6 body of the pipe support because there's no reason to plug a 7 hole in the first instance.

8 MR. COUNSIL: Jack, tomorrow when you're on site 9 He'll recheck the obliqueness on that procedure on how they 10 Here inspected. We'll check that and show you in the morning.

11 In addition to that, the other thing you should know on the 12 tube steel on the Richmond, all of those Here taken down to --

13 as for os cutting down the length of the span of the tube

(

14 steel, and you remember when we discussed it in March'the back 15 Hings were put on?

16 MR. D0YLE: Yes.

l'7 MR. COUNSIL: I'm fairly certain that all those Here 18 fully reinspected again in going back up. That's on the 19 oversized hole cuestion. We'll verify that on the procedure 20 tomorrow morning also.

21 MR. D0YLE: I think that's the answer He're looking 22 for generally. As I stated, I don't think there are any 23 problems with the tube steel that makes up the body of the 24 support because there's no reason to add a hole in there 25 in the first place. I think if there is a problem -- and I Carmen Gooden, CSR, RPR, Metro 429-5532

l -

g 1 think the test shows that the allegation referred to base

( 2 plate testimony, and finding plug Helds in the base plate 3 Houldn't be too difficult of a procedure.

4 MR. SISKIN: Jack, I guess one of the things that's 5 bothering me -- as I remember the tube-steel is no larger thar 6 a half inch and most of it is three-eighths.

7 MR. D0YLE: Yes.

8 MR. SISKIN: I'm almost wondering how you could have 9 a void in such a situation.

10 MR. D0YLE: You wouldn't. That's what I Just got 11 through stating. In the case of pipe support in the tube 12 steel there was never a necessity for a hole; therefore, therg

{

13 Hould never be a necessity to plug up on the hole. If there 14 is a problem in the pipe support area, it Hill be in the base 15 plate, Hith the exception of the Richmond anchor tube steel

16 arrangement, because even when I was there myself, a Richmond 17 was preset, then the hole-Has drilled,"the tube steel did not 18 always fit the way the Craft would have liked. And they had 19 two options. One was to bang it on and strip the threads.

20 Another was to open the hole up a little bit. So the easier 21 of the two options or more feasible of the two options was 22 open the hole up a little bit. In some. cases they opened the 23 hole -- this part I don't know; this was one of the 24 allegations -- in some cases they opened the hole a little too 25 much. When they did that, they would take it out and Just Carmen Gooden, CSR, RPR, Metro 429-5532

T 10 1 Held enough so that on the surface it appeared to be all

( 2 right. But Bill Counsil has said that those have all come 3 doHO and been reinspected.

4 MR. COUNSIL: That's why I want to check the 5 procedure.

6 MR. D0YLE: If we have a procedure on that, He have 7 no problem. And if He have an in.epection procedure during 8 the walkdown on the base plates. Because they did the 7914 9 Halkdown, they checked the dimensions of the anchor bolts, anc 10 I'm Just wondering is there a procedure in existence that 11 says, while you're doing that, check to see if it has been 12 plug Helded. It was one of the allegations at the hearing.

( 13 MR. SISKIN: I'll have to check and see what it says.

14 MR. D0YLE: It's not a difficult thing. Once you 15 find that, then you can check and if there's no void -- I 16 think I've already concurred in the hearings that if you plug 17 Held properly or you don't even have to'~ plug Held properly, 18 close to properly, you Hill be equal, beccuse you're working 19 Hith a higher strength Held run.

20 MR. KLAUSE: The next subject is the ASME-11 21 in-service inspection concern that you raised. We were unable 22 to get the right person last night, so we're going to have to 23 defer that subject for a later meetinc.

24 For the steam generator upper lateral support, you

('

25 will be hearing later on in the discussion SWEC's scope of -

Carmen Gooden. CSR, RPR, Metro 429-5532

5 -

11 1 Work. Part of that work is done. It's Westinghouse's

( 2 responsibility, so again, that subject Hill have to be 3 discussed at a later date.

4 I believe that concludes oJr number of questions that 5 you had raised last night.

6 MR. D0YLE: I'm quite su e that some of these fell 7 into another arena.

8 MR. KLAUSE: Right; other than the civil / structural 9 one that He deferred yesterday.

10 MR. NACE: Were there any other questions, Jack, fron 11 last night?

12 MR. D0YLE: I have no further questions.

( 13 MRS. ELLIS: I guess that's it for now. We may have 14 some more as He revieH the records.

15 MR. NACE: I'd like to take a short break for ten 16 minutes so we can set up a new panel. We'll reconvene at 17 9:10. -- -

18 (A break Has taken.)

4 19 MR. NACE: The meeting will come back to order. This 20 is the second part of the agenda which I talked a, Jt 21 yesterday. The panel He have here noH will discuss the 22 Corrective Action Program on the six Project Status Report 23 areas that are not yet issued. The intent of this part of the 24 pr sentation is to give you an overview of r. hat those six

('

25 Project Status Report areas consist of, what type of work they Carmen Gooden, CSR, RPR, Metro 429-5532

I 12 1 have been Oving to give you some indication of what the

( 2 Project. Status Report Appendix A and B Hill look like Hhen He

? issue it in the very near future. More importantly,-to give 4 you an opportunity to ceview the program that is being enactec 5 in these areas to make sure that you fully understand what it 6 1s He're doing.

7 This panel is a mixed panel consisting of our 8 director of engineering for TV Electric, Mr. Owen Lowe. With 9 him on the panel are members of the Ebasco, Impell and Stone s 10 Webster organizations that are participating in these six 11 Project Jtatus Report areas.

12 I'll let Mr. LoHe and the individuals introduce .

( 13 themselves as they are speaking.

14 MR. LOWE: Thank you, Larry. By Way of t

15 introduction, I am Owen LoHe. I'm the director of engineering 16 for Comanche Peak for TV Electric.

17 A brief thumbnal'I background sketch. I have been an 18 engineer for 21 years. Thirteen of those 21. years have been 19 in the nuclear industry, primarily involved in two projects t

20 over the 13 years, from the stage Where they were holes in the 21 ground to a point where they were verv close to commercial 22 operation. .  ;

23 I am a registered professional engineer in several 24 states and a member of the American Society of Civil

(

25 Engineers.

Carmen Gooden, CSR, RPR, Metro 429-5532

i -

13 1

1 To my immediate right is Ralph Ackley, Ralph, I'd

( 2 like you.to tell the folks a little bit about yourself. 1 l

3 MR. ACKLEY: Good morning. My name is Ralph Ackley,-  !

4 and I am the project manager from Stone & Webster of the 5 civil / structural, mechanical, electrical and I&C Corrective 6 Action Programs. I'm also an assistant engineering manager at 7 Stone & Webster in our engineering department.

8 I have had 20 years in the nuclear industry, 15 of 9 those years at Stone & Webster. I served as an engineering 10 officer in the United States Navy Reactor Program. I am a 11 registered professional engineer.

12 My most recent project assignment before Comanche In

{ 13 Peak Has as project engineer for the Millstone III site.

14 that capacity I was in charge of all engineering between 1982 15 to 1985, Hhich includes the final stages of final completion 16 as Hell as the licensing of the plant.

l'7 MR. LOWE: To Rd'Iph's right 15'Mr. Siskin whom you 18 met yesterday. I Hon't ask him to review his credentials at 19 this time.

20 To my left is Enver Odor from Ebasco. Enver?

21 MR ODAR: Good morning. My name is Enver Odar. I'a 22 with Ebasco Services, and I an assigned as the project 23 engineering manager to this project for the scope of Work that 24 He're performing. I joined Ebasco 22 years 090, still Hith 9

25 Ebasco and most of my 22 years of professional life was on Carmen Gooden, CSR, RPR, Metro 429-5532

14 1 nuclear industry, nuclear powerplants.

( 2 The most recent powerplant that I completed before 3 coming here was Shearon Hcrris powerplant for Carolina PoHEr.

4 and Light, which is presently operating.

5 I'm a registered professional engineer,in two states, 6 and I am a member of the American Society of Civil Engineers 7 and Americon Society of Seismological Engineers.

8 MR. LOWE: And to Enver's left John Wawrzeniak from-9 Impell.

10 MR WAWRZENIAK: Good morning. As Owen mentioned, my 11 name is John Wawrzeniak. I'm the project manager for Impell.

12 I have over 20 years of experience in the' nuclear industry,

( 13 including engineering and engineering management in several 14 different nuclear facilities, dealing with engineering de. Sign 15 analysis as well as construction Gf thnse facilities.

16 I am a registered professional engineer in several 17 states, a member of ASME, presently ho1d several ASME code 18 committee positions including member of the ASME 19 main committee on qualification equipment, member of ASME 20 subgroup on design and former chairman of the ASME Horking 21 group on designing pumps.

22 MR. LOWE: Thank you, John. 3y way of opening 23 remarks, I'll state the obvious, that He hav9 Just gone 24 through a very detailed review of technical issues in the pipe

~

25 support, pipe stress arena. Those areas, as you are chare, Carmen Gooden, CSR, RPR, Metro 429-5532

15 1 cover two Project Status Reports or two Corrective Action

( 2 Program scopes of work. Later in this meeting, as time 3 allows, He Hill cover in great detail the cable trays, conduit 4 supports, Trains A, B and C creater than two inches, and 5 conduit supports, Train C less than two inches in diameter, 6 which constitute three additional scopes of Hock Hithin the 7 Cortactive Action Program. Those three scopes of Hork are 8 also covered in three additional PSRs.

9 What He would like to accomplish with this pane.1 this 10 morning is a much less detailed overview of the issues being 11 covered or the scopes being covered in the remaining six 12 Corrective Action Program scopes of Hork as represented by six

( 13 additional Project Status Reports not yet issued but about to 14 become available.

15 We are prepared to give you a fairly comprehensive I 16 Hould say, overview. It is not our intention today, however, 17 in the time period we have available-to go into a great deal 5

of detail on technical issues.

18 We Hill be more than hapopy to 19 entertain your questions as they come up.

20 We do not have a lineup of technical experts behind 21 us that could give you great detailed answers, but we Hill 22 attempt to entertain your questions as.they arise.

23 As you're aware, the Corrective Action Program scope 24 covers the safety-related aspects of CPSES at Comanche Peak.

( '

25 The CAP organization consists of three engineering Carmen Gooden,.CSR, RPR, Metro 429-5532

sy._ .g

. - - ' ~

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16 s

1 contractors -- Stone a Webster, Ebasco and Impell -- 6nd the I 2 Corrective Action Prog' ram is divided into 11 scopes of Hork.

3 The work performed under the Correct 19e Action 4 Program is, in faci, reported then and consistent Hith the 11 i

5 scopes of Hork in 11 Project Status Reports. As I aid 6 earlier, five of those Project Status Reports are available.

7 The other six are going to become available very shr.'rtly.

8 The 11 scopes are divided into large bore pipe 9 supports and.small bore pipe supports. We Hill talk in this 10 panel about the mechanical scopes of work; civil / structural:

11 electrical I&C; instrumentation and controls;-HVAC heating, 12 ventilating and air conditioning; and equipment qualification.'

( 13 I would like to bring your attention particularly to 14 the mechanical scope of Hork. The primary responsibility for 15 the mechanical PSR lies Hith Stone & Webster. We have chosen 16 to package as tso supplements to the mechcnical report one, 17 system interaction for Hhich Ebasco has the primary 18 responsibility, and second, fire protection, which is Impell's 19 respons101'ity.

Our selection of mechanical PSRs^in which He 20 Hish to include those is really a question cf convenient l l

21 packaging. The primary interface with systems interaction and 22 fire protection is a systems mechunicair.e.ated interface, l 23 although it certainly does not exclude instrumentation and 24 controls and electrical interface as Hell.

C.~ i 25 Finally, the lost three remaining scopes of work are Carmen Gooden, CSR, RPR,-Metro 429-5532 1 .

17 l

1 the cable trays, cable tray hangers, conault supports, as He

( 2 discussed earlier.

3 I think it would be appropriate at this time to 4 remind ourselves of the mission of the Corrective Action 5l Program in total. We have charged our Correct 1ve Action 6 Program contractors to demonstrate that the design of systems, 7 structures and components complies with the licenseing 8 requirements. Also, to demonstrate that existing systems, 9 structures and components'are in complinnce with the' design.

E Or, where necessary, to develop modifications which Hill bring 11 the systems and structur?s and components into compliance Hitt 12 the design.

( 13 In addition, the Corrective Action P99 ram mi' lon is 14 to tevelop procedures, an organizational plan ant' 15 documentation to maintain compliance to the ',tr.er' sing 16 commitmsat throughout the life of Comanche Feak.

17 The next page of the handout 1s'a simplified --

18 ,

1s there a question?

19 -- is a simplified version of the i.cH chart that 20  ;

appeared earlier in the August 28th letter submitted to the 1

21 NRC. We have simplifted it for our purposes here. It ha? 01Jj 22 the same elements os you see in the more complex chart it. thcz 23 submittal. '

24 What this f; hart demonstrates are the elements and '

~

25 processes of .ne Corrective Action Program. Let me point out Carmen Gooden, CSR., RPR, Metro 429-5532

18 a couple of key blocks on'this chart.

1 The Design Basis

( 2 Documents are an essential element of the-Corrective Action 3 Program documentation. They are the. documents which' provide c 4 detailed working description of'the licensing requirements 5 primarily as they're presented in the FSAR, but clso from all 6 the other sources of licensing commitments that He make.

7 A detailed working. description is then used for ths 8 production ~of-subtier documents such as calculations, 9 specifications and drawings.

10 A key element, of course, of the design Corrective 11 Action Program is the design validation element on which we 12 have concentrated in the March meeting and earlier in.this-  ;

( 13 meeting, and which we Hill continue to' concentrate on iri our 14 discussions of the remaining six corrective action scopes.

15 The second element, of~ course, is the post  ;

16 construction hardware validation. That activity is for the 17 most part begun, some 50, nlus or minu's'one or two, field

]

1E verification methods, and is scheduled for completion in July 19 of 1988. i 20 The reconciliation process that appears in the third 21 block from the bottom is a process Hhich compares-the results 22 of the Design Validation Program and tha'results of the Post I

23 Construction Hardwcre Validation Program and reconciles any 24 potential differences between the two. That is not to say 25 that it is required to complete the design validation effort.

),

Carmen Gooden, CSR, RPR, Metro- 429-5532

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

19 1 Really, the desion validation effort is done; either done now .

( 2 or essentially completed; H'.11 bc very shortly. And the post 3 construction hardware vuliaation process Hill then follow.

4 Final comment on this chart: I'd like to call your s

5 attention to the bottom block, ' ie final documentatioli Design i

6 Validation Packages. As you are Hr.11 aware, there are ,

7 speculations as tc Hhether it's tens of millions or hundreds 8 of millions of documents associated with Comanche Peak, and 9 I'm not sure I'm exaggerating particularly when I go to ther 10 hundreds of millions category.  !

i 11 MRS. El.LIS: I think He would agree with that.

12 MR. LOWE: What the Lceign Validation Package does -

{ 13 for us is to provide us a He]l-orgcni ' ed index or road map 14 through that documentation for ecch subset of -- or the scope 15 of work being validated by the corrtctive action contractors.

16 The documents are filed in an orderly manner within.our 6  ;

17 existing documentation filing system ot Comanche Peak, but 18 these Design Validation Packages helo us in determining which 19 of those millions of documents are associated with a 20 particular design validation activity.

21 So we have created this Design Validation Package to 22 facilitate review on our part L" '1 th.e various parts of 23 people that are interested in doing a review on our 24 activities.

(

25 A major product of the Corrective Action Program is C <

t .. _, I l ,

Carmen Gooden, CSR, RPR. Metro 429-5532

I l I

20 1 Project Status Report. The report is a summary report. Our

( 2 intentions in three major parts of that report are to report 3 on how the objectives of the Corrective Action Program scope 4 were met, report on how all of the issues were resolved,-and 5 the PrcJect Status Report also identifies preventative action 6 to assure that similar problems do not occur in the future.

7 In summary, then, the Corrective Action Program Hhen 8 compieted assures that the design of systems, structures and 9 components complies with our licensing commitment;-that 10 systems, structures and components are installed in accordance 11 .:4th the design: that all issues ara resclved, and that design 12 ciocumentation is acceptable and controlled.

( 13 Havir.g soid that, let me 90 on to the first four of 14 the Corrective Action Programs that we intend to discuss 15 today, namely mechanical, civil / structural, electrical and 16 instrumentation and controls, and turn the microphone over to 17 Ralph Ackley who will give us an overv'teW of those Correcti/e 18 Action Program scopes.

MR. ACKLEY: Tnank you. I'm going to wait a few 20 minutes until they get cse passed out.

21 MRS. ELLIS: While they're doing that, I-would Just 22 like to acknowledge that He have received the December lith 23 letter enclosing the revisions of the field verification 24 methods and quality inspection procedures and erection

(.

25 specifications referenced in the cable trays and cable troy Carmen Gooden, CSR, RPR, Metro 429-5532

~

21 1 hangers and the conduit supports.

( 2 . We appreciate that. Obviously He have not had a 3 chance to read the foot-thick or so materials yet, but He do 4 appreciate getting them.

5 MR. ACKLEY: After a little more than a year of  ;

6 design validation work we certainly Helcome the opportunity td 7 get together with you and discuss our program. .As OHen said, 8 He Hill be er6phasizing today the methodology scope of our .

9 program. We also are 9t.no d

to talk about the status of desigr 10 validation and Project Status Reports as they stand today, 11 And He are going to provide a summary of the results to date.

12 We also included in the package issues which are ,

13 going to be presented in the Pro). . Status Report, which we

{

l'4 certainly hope to be able to get together Hith you at future  !

15 meetings to discuss the technical aspects of it. As Owen f 16 snid, He have a lengthy program here and time does not alloH 17 that at this meeting. ,

18 Our design validation effort is part of the  !

19 Corrective Action Program and has been very broad in these 20 four disciplines. Yet the requirements of design in the 21 Corrective Action Program require a very detailed, very deep 22 review of all technical aspects of the design. Our work 23 encompasses all safety-related designs assigned to Stone a 24 Webster in civil / structural, mechanical, electrical and 25 instrumentation and controls area. And it includes interface Carmen Gooden, CSR, RPR, Metro 429-5532  ;

j 22 1 Hith the nuclear scheme of supply system design, as well as

( 2 interfac.e with the vendor component design.

3 The design validation work has been performed 4 primarily in our Boston and Cherry Hill offices. We have 5 assigned a set of engineers to the Job site to do validation 6 Hork which is more directly related to field and collection of 7 field data. In the overall program the results.of their work 8 ar2 reviewed by our lead engineers in our Boston and Cherry 9 Hill offices.

10 Our validation of design has been very extensive over 11 the last year. We have spent more than one million manhours 12 in the execution of that design validation. We have placed

( 13 our top Stone & Webster technical personnel on the assignment.

14 The supervisors in all of our areas are senior level Stone &

15 Webster engineers with extensive design construction 16 experience on licensing the plants that have been designed by 17 Stone & Webster. And among others that includes four plants 18 which have been licensed in the last three years.

19 All work which we have performed in all stages, both 20 design and validation stages of the Corrective Action Program, 21 has been performed under the Stone a Webster Quality Assurance  !

22 Program. You're familiar with the program from the 23 discussions in the pipe supports crea. It is the same 1

24 program. As Ron Klause has explained at aarlier meetings,  !

(' l 25 the program has been approved by the Nuclear Regulatory Carmen Gooden, CSR, RPR, Metro 429-5532

5 -

23 l I

i l

1 Commission and has been used on many licensing-documents, l

( ~2 The programs and the procedures and the technical 3 approaches that He used here are well established and have 4 been used on all of the plants that Stone & Webster has 5 designed and participated in licensing.

6 We also keep our Quality Assurance Program and our 7 procedures current, involving regulatory requirements Hhich 8 are absolutely essential.

9 Over the past year our design validation work has 10 been extensively audited by several organizations, including 11 Stone & Webster Quality Assurance, the TU Electric Quality 12 Assurance Department. We have had technical audits as part of the Comanche Peak Response Team overview throughout our

{ 13 14 validation work, and we have had one inspection and expect  ;

15 some more by the Nuclear Regulatory Commission in the Office 16 of Special Projects.

l'7 Now, as Owen har explained, the general assignments 18 by engineering contractors involved 11 scopes of work. Stone 7

19 & Webster has responsibility for six of those 11 scopes of 20 work. Ron Klause and his engineers previously discussed large

)

21 bore pipe supports and small bore pipe supports. The other 22 four scopes of. Work in the Stone & Webster respor sibility are

~

23 the ones that we're talking about noH: civil / structural,  !

24 electrical, instrumentation and controls, and mech'anical'.

~

25 As Owen pointed out, the mechanical scope of Hork i Carmen Gooden, CSR, RPR, Metro 429-5532

i 24 1 also includes systems interaction program and fire protection

( 2 which will be discussed later on at this meeting.

3 These four disciplines -- the nature of our Hork, as 4 I said, was very broad, and it's very difficult in a session 5 like'this to explain the entire scope of'the Hork~1n a few 6 Hords. What we have chosen to do here is to provide you a 7 listing of the Design Validation Packages that describe the 8 scope of our Hork. Over the next three or four pages in the 9 handout, He have 67 Design Validation Packages listed. The 10 Design Validation Package is a scoping document. It provides-11 a Complete and organized grouping of activities for the design 12 validation.

{ 13 When the Hork is complete, the design validation Hill 14 be a listing or an index, if you Hill, which identifies all 15 documents that Here necessary to validate the design.

16 Now, if He look on the first page of the Design 17 Validation Package descriptions in the ' civil / structural area 18 He notice that there are packages relating to each of the 19 structural buildings that He need to look at. There are also 20 structural component packages such as pipe Whip restraints, i 21 liners and others on the list. And also He have design 22 validation activities which are part of.our Design Vall'dation 23 Packages which cross all structural areas, such as tornado 24 design, various testing programs for structures, and t

25 validation of the seismic amplified response spectrum, as Hell Carmen Gooden, CSR, RPR, Metro 429-5532

i 25 1 as others that are listed there.

( 2 On the next page you Hill find a listing of the 3 electrical and instrumentation and controls Design Validation 4 Packages. The electrical area has DVPs, as He call them, 5 associated with the major electrical systems -- or should I 6 say all electrical systems. We also have activities in 7 Packages Which cross system boundaries, such as.our cable 8 systems, our electrical independence, which is our reg guide, 9 Regulatory Guide .175 electrical separation, as well as 10 others.

11 .I might point out in both the electrical and -- as a 12 matter of fact, in all these Design Validation Packages He

( 13 have interfacing amongst the disciplines structural, 14 electrical, instrumentation and controls and mechanical, as 15 Hell as interface Hith the other contractors' Hork. We'll be 16 discussing that in a few moments as to how He control that.

l'7 On the electricot and instrumentation and control 18 packages at the very bottom of each grouping you Hill notice 19 there is an entry on electrical activities associated Hith the 20 safety-related heating-ventilating and instrumentation and 21 controls activity associated with safety-related heating and i l 22 ventilating. ,

23 What those represent are Stone & Webster's  !

24 responsibility With the interface With Ebasco in the design of f

25 the fluid systems. When Enver Odar explains a little bit on  !

Carmen Gooden, CSR, RPR, Metro 429-5532

26 1 his heating-ventilating program, he will explain how that

( 2 interface is maintained.

3 Just a couple of notes on the mechanical Design 4 Validation Packages. As you would expect, they are for the 5 most part oriented along fluid systems lines, but He also have 6 packages associated with valves which include all valves 7 within mechanical systems. We also have packages on page six 8 in your handout which includes the radiation Hork, radiation 9 design Hork, performed for the project, which is under our 10 responsibility, as well as the accident analyses that are 11 associated with the design of post-accident systems.

12 Do you have any questions on the general scope of our

( 13 work that I might be able to answer at this time?

14 MR. D0YLE: I have none.

15 MR. ACKLEY: We have on the next slide a brief status 16 of where He stand in the Corrective Action Program. The four 17 Project Status Reports Hith results fr'om'the Stone & Webster 18 design validation are scheduled for issue in January of 1988.

l 19 These Project Status Reports are a very comprehensive summary i

20 of design validation results. They provide a thorough l 21 explanation of the method, as well as findings associated with 22 our design validation work. And they contain references to l 23 allow for requests for further information for substantiating 24 documentation or to delve into the technical details as might f

25 be required. The design validation phase of the Corrective Carmen Gooden, CSR, RPR, Metro 429-5532

i ~

27 1 Action Program Hill be complete upon Project Status Report

( 2 issue in January.

3 Now, underway is the Post Construction Hardware 4 Validation Program. These activities are in process and all 5 Stone & Webster disciplines are scheduled for completion in 6 July of 1988.

7 The next slide is a slide that Owen has presented in 8 general in his part of the presentation. This is a 9 simplification of the flow charts and methodologies that were 10 presented in the August 28th Texas Utility letter to the 11 Nuclear Regulatory Commission.

l 12 The design validation phase of the work is described l 8 i 13 as constituted in the first three blocks of the chart, and

{- ,

t 14 that is the area that He Hill emphasize in our discussion 15 today.

16 In the next few slides after this one He will provide 17 some details to you on the methodology of each of these 18 elements of the Design Validation Program.

19 As I said earlier, when we issue the Project Status 20 Report, He Hill have completed the design validation and will 21 have assured ourselves that the validated design is consistent 22 Hith the final safety analysis reports., At that time all 23 required design modifications identified in design validation 24 Hill be initiated, and Stone & Webster and Texas Utilities

~

25 will have assured themselves that programs and procedures are Carmen Gooden, CSR, RPR, Metro 429-5532

i 28 1 in place to maintain that design basis through the rest of the t

( 2 Correct 1.ve Action Program as Hell as for the life of the 3 plant.

4 And again, I emphasize that by issue of the Project 5 Status Report, the design validation is complete.

6 The first step in the performance of a design 7 validation is to do a very detailed review of the final Safeti 8 Analysis Report, the Safety Evaluation Report, the ,

9 supplementary Safety Evaluation Report and other licensing ,

10 commitments to establish a basis for the validation of design.

11 These requirements oa the design of the plant are then 12 compiled into Design Basis Documents which He'll discuss on I

( 13 the next slide.

14 During the desion validation and into the future, we 15 expect it will be involving regulatory requirements that must 16 be reconciled with validated design. At any nuclear plant l'7 this is an important facet of the licensing program. We have 18 procedures in place at Comanche Peak to assure that happens. l 19 Such items as NRC inspections, NRC review of the final Safety  :

20 Analysis Report, revision to regulatory guides, and issuance 21 of Nuclear Regulatory Commission bulletins, and notices. All ,

22 have potential to affect the design, and they all must be '

23 monitored, and they are.

24 The Project, Texas Utilities, Stone & Webster and all

( '

25 the other contractors are to continue to review the validated Carmen Gooden, CSR, RPR, Metro 429-5532

i 29 1 design against these regulatory revisions and regulatory

( 2 questions, and He'll be making changes now and in the future 3 as required to meet our regulatory responsibilities.

4 Owen gave you a brief description of Design Basis 5 Documents. They are the controlled working document in the 6 hands of the engineers that provide the licensing criteria by 7 which the e.igineer does his work on an every-day bas'.'.s. After 8 revieH of the licensing commitments and licensing documents ir 9 our design validation, Stone & Webster developed a set of 10 Design Basis Documents which are then used by the engineers tc 11 ensure compliance with these licensing commitments. There 12 are approximately 75 Design Basis Documents in the Corrective

( 13 Action Program scope of work amongst all engineering 14 contractors, j

15 Under the scope of work that I'm discussing in these j 16 four disciplines, Stone & Webster has prepared 47 of these l'7 documents and all 47 documents have been issued by Stone &

i 18 Webster, reviewed by the various contractors,. and issued by TU l 19 Electric. The Design Basis Documents cover safety-related i 20 design requirements and are procedurally controlled to ensure 21 consistent application by all engineering disciplines, both 22 the disciplines that are primarily involved in the use of the 23 documents, as Hell as interfacing technical disciplines, the 24 need to know the criteria that other organizations are using.

25 The controlled Design Basis Documents form the validation of Carmen Gooden, CSR, RPR, Metro 429-5532

. l I

30 i

l 1 the design hardware and Corrective Action Program. But

( 2 equally importantly, they control the design changes for the 3 life of the plant. This is an extremely important part of the 4 design control process of any Job, and this job has procedures 5 in place to ensure that happens, 6 Also, the Design Basis Documents describe the 7 engineering functional requirements for systems, structures 8 and components. And that establishes the bases for testing, 9 operating and maintenance procedures assoClated Hith the ,

10 design.

11 So not only are these documents used as an 12 engineering basis, but they are also used to provide the

( 13 engineers direction to other organizations and to establish 14 the operating basis of the plant.

15 As He said, all design validation is performed to the 16 Design Basis Documents. Upon preparation of these documents, l'7 our engineers have compared the existing design documentation 18 to these DBDs. This documentation includes calculations, j 19 drawings, specifications, and change control documents 20 associated with these calculations, drawings and 21 specifications. The original design documents that are 22 required to validate the design have been documented by Stone 23 a Webster to be either acceptable to the Design Basis Document 24 or He have modif.ed those documents as He see fit to meet the

( '

25 licensing commitment.  :

I 1

Carmen Gooden, CSR, RPR, Metro 429-5532

i 31 1 When the original documents file was found to be

( 2 incomplete or not suitable to satisfy the Design Basis 3 Documents, He, Stone & Webster, have prepared new design  ;

4 documentation. The original documents were then voided Hhere ,

5 appropriate.  !

i 6 At the conclusion of the design validation phase,  ;

7 upon issue of the Project Status Reports, all design documents 8 which are required to attest to the validity of the license  !

9 design, Hill have been accepted or revised by Stone & Webster.

f 10 That is, they Hill have been documented as acceptable or He i

11 Hill have issued modifications and our name Hill appear on  !

i 12 those documents.  !

9  !

{ 13 During the course of the design validation He have f

r 14 initiated design modifications as a result of our review of i 15 the design. These design modifications Hill bring the 16 structures, systems and components into compliance with the  :

I l'7 Design Basis Document. -- "

18 Yes, ma'am?

19 MRS. ELLIS: I Just wanted to verify when you have l 20 done all of this, you're still retaining the original l

21 documentation as part of the historical file.

22 MR. ACKLEY: Yes, ma'am. When.He say voiding a 23 document, He are saying He take it out of normal use of the 24 project, but He put it in the records file so it can be 25 examined at any time. I i  ;

Carmen Gooden, CSR, RPR, Metro 429-5532

i 32 1 MRS. ELLIS: I thought that's what you meant. I

( 2 wanted to be sure.

3 MR. ACKLEY: Let me stop where I am to talk a little 4 while. Are there any questions on the steps of design 5 validation that I presented so far?

6 MR. D0YLE: I have none.

7 MRS. ELLIS: (Shakes head).

8 MR. ACKLEY: As we have discussed earlier, equally 9 important with the review of the original document is the 10 maintenance of the technical interface. Comanche Peak has 11 enhanced these procedures to control that technical interface 12 and technical interface requirements amongst the various

( 13 engineering. disciplines. Some examples of -- this is only a 14 few examples, but there are hundreds. We have a load 15 reconciliation program for embedment in base plates for the 16 reconciliation of loads coming out of suspended systems 17 support. We have performed the design"validation of the 18 interface design parameters between mechanical fluid systems 19 design and the pipe stress analysis. Such items as design 20 pressures and temp!ratures associated with the system through 21 transient analysis of system conditions form the basis for 22 pipe stress analysis. That work, that original work, has beer 23 reviewed and validated or changed by Stone & Webster as input 24 to the pipe stress analysis, t

~

25 In addition -- Just one last item -- on an ongoing Carmen Gooden, CSR, RPR, Metro 429-5532

i -

33 1 basis each time that a design document is changed, let's say c 1

( 2 DCA interdiscipline design review is done and those changes 3 Here required to make sure that the technical interface is 4 satisfied in each and every change.

5 The next slide in the packet provides some summary 6 level results and statistics coming out of the Stone & Webster 7 design validation for civil / structural, electrical, 8 instrumentation and controls and mechanical.

9 In the course of our design validation.He have 10 reviewed approximately 3,000 original calculations, 4200 11 design drawings and associated Design Change Documents to 12 those drawings, and approximately 150 specifications, both

( 13 installation and procurement specifications.

14 We have developed and issued 47 Design. Basis 15 Documents and approximately 1200 Stone & Webster calculations.

16 These calculations supplement, supercede for our new 17 calculations to the original calculation file. In the course-18 of the design validation He have resolved and issued 19 corrective action as it has been required to meet the '

20 licensing commitment. This corrective action can come from 21 many sources, including the design validation effort itself.

22 Discrepancy Issue Reports, and,He have reviewed over 23 1900 of those as part of our design validation, and He have 24 provided individual responses to those Discrepancy Issue

. 25 Reports as part of our Horkup to issue the Project Status Carmen Gooden, CSR, RPR, Metro 429-5532

34 1 Reports. I

(. 2 MR. NACE: May I interrupt Just a minute, Ralph?

3 Yesterday we Here talking about the Discrepancy Issue Reports, 4 DIRs, in the piping area. The piping group He're talking 5 about, I think, it was 972 DIRs, and I said there Here about 6 4300 total. So you have 972 by piping. Ralph has Just 7 indicated that his scope of work contains 1900, and later on 8 Impe11 and Ebasco scopes as discussed by this panel, plus the 9 cable tray and conduit scopes, Will contain the rest.

10 MR. D0YLE: Thank you.

11 MR. ACKLEY: In addition, there are over 80 design 12 issues from the Comanche Peak Response Team and external

{ 13 sources that we have solved -- or resolved; excuse me -- and 14 He'll be discussing those in the last part of my presentation.

15 Are there any questions on the overall summary of our 16 validation results?

17 MR. D0YLE: I have Just one question and probably 18 should have asked it earlier on the voided calculations.

19 Is that a part of the cataloging system for retrieval?

20 MR. ACKLEY: Yes.

L 21 MR. D0YLE: In other Hords, you have a historical 22 paper trail for everything that has been done at the plant to 23 date.  !

24 MR. ACKLEY: Yes. As an example, if we review a 25 calculation and find it to be not suitable or not complete Carmen Gooden, CSR, RPR, Metro 429-5532

~ '

35 1 enough to the current design, He may choose to do a complete

.( 2 new calculation. That new calculation Hill reference the old 3 one. And then He Hill issue the new calculation, and at this 4 point of issuing He will void the old calculation. So at that 5 point He have one calculation on file for that ,particular 6 design activity.

7 MR. NACE: I think He might clarify, the voided calc 8 Just goes into what you might think of as suspense files, 9 historical file.

10 MR. D0YLE: But it is retrievable.

11 MR. NACE: It's retrievable through our records 12 management program. The engineer, as you know, is always

( 13 interested, almost totally interested, in the current 14 calculation because that is the current design of the plant.

15 The other thing I wanted to mention: Yesterday He 16 talked briefly on CMCs. You brought CMC up. Part of the 10 17 validation process involving all the cantractors Hould have 18 been to take the historical change paper, which CMCs were one 19 type that may have affected the design, fed that back to that 20 particular contractor, Whoever had cognizance of that scope, 21 in the process of validation then he took cognizance of that 22 earlier change paper, or What someone called deficiency paper, 23 as it may have affected the design.

24 MR. COUNSIL: We Hanted to make that point, Juanita, 25 because both yourself and Billie have brought it up numerous Carmen Gooden, CSR, RPR, Metro 429-5532

36 1 times. We are reviewing all of it.

( 2 MRS. ELLIS: Okay.

3 4 MR. ACKLEY: On page 13 of the handout and in 5 succeeding pages He have a brief discussion of the specific 6 issues. The Corrective Action Program provides assurance that 7 the validation resolves design and hardware issues identified 8 by the Comanche Peak Response Team and external sources, as 9 Hell as issues raised from the validation activities 10 themselves.

11 The Project Status Report Hill address the definitior 12 of each issue and the resolution of the issue as required by

{ 13 the Corrective Action Program, including both corrective and 14 preventive action.

15 On the next few pages in your handout He have 16 provided a list of the Corrective Action Program issues 17 identified to date that Hiil be included in the Project Status 18 Reports.

19 NoH, this list will grow between now and the issuing 20 of the Project Status Reports because we are in the process ir 21 our work and He expect more issues to be included by the time 22 the Project Status Report is issued. 1.Hould like to point 23 out one thing from yesterday's discussion, that in civil /

24 structural area, on the list that He have provided for you, 25 the issues concerning reinforcement of the steel placement in >

Carmen Gooden, CSR, RPR, Metro 429-5532

37 i

l 1 the upper steam generator restraint design are covered and

( 2 Hill be. explained in the Project Status Reports upon issue. i 3 This concludes my presentation. Are there any other 4 questions that I might be able to field?

5 MR. D0YLE: I have no questions. ,

6 MR NACE: We'd like to take a short break at this 7 time and reconvene at 20 after the hour.

8 (A break Has taken.)

9 MR NACE: The meeting will come back to order.

10 MR. LOWE: The next speaker Hill be Enver Odor who 11 Hill discuss the systems interaction supplement of the 12 Mechanical Project Status Report.

( 13 MR, ODAR: Before I cover the systems interaction 14 aspect, I would like to take this opportunity to tell you that 15 He are very glad to be here, and we appreciate the opportunity 16 to discuss with you the areas of work that are being performec 17 by Ebasco as part of the Corrective Ac't1~on Program.

18 We will cover the Systems Interaction Program, which 19 I will present later on, the HVAC program aspects, and later 1

20 on this afternoon we Hill discuss the details of issues and i 21 issue resolution of the CTHs, as Hell as on safety-related 22 Trains A and B and larger than two inch. Train C conduit 23 systems.

24 I Hill provide an overvieH of the validation

~

25 activities which are being performed by Ebasco on the Systems Carmen Gooden, CSR, RPR, Metro 429-5532 i

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  • 38 1 Interaction Program.

( 2 Systems interaction validation efforts are among 3 the --

4 MR. NACE: Excuse me, Enver. Could we turn up the 5 microphone one more -- -

6 MR. ODAR: Tne system interaction validation effort 7 is along with TV Electric Corrective Action. Program scopes of 8 work which are assigned to Ebasco. And as was pointed out, 9 the methodology and summary of the results of this effort will 10 be contained in a supplement to the mechanical PSR.

11 In a summary fashion, systems interaction can best be 12 defined as a program which is required to assume an occurrence

{ 13 of postulated, though unlikely u.id very extreme, event. Then 14 it requires the program to identify and quantify results and I 15 effects of these events and then systematically proceed to 16 assure that safety-related systems, structures and components 17 will maintain their function during and after such events in 18 order to assure safe shutdown and assure mitigation or  :

19 containment of the consequence of this event, i 20 High energy line breaks and internally generated 21 missiles and the resulting effects are among such postulated i i

22 extreme events that we are required to address in the Systems 23 Interaction Program.

24 During my overview of the validation process of the

( ~

25 Systems Interaction Program, I Hill be using terminology, Carmen Gooden, CSR, RPR, Metro 429-5532

39 1 especially in defining the event and the effect, which may

( 2 require clarification. There are technical terms used. So I 3 thought it would be beneficial if I would try to explain the 4 basics of an occurrence of the event and then identify the 5 terms up front so He will all understand what is meant by that 6 terminology.

7 Even though the piping syctem; are properly designed, 8 the Systems Interaction Program is required to assume that 9 high energy lines break and the break is a sudden, complete 10 severence of the pipe often referred to in the industry as a 11 guillotine break.

12 As a result of a pipe break, the broken end of the

( 13 pipe will undergo excessive motion, and the high energy fluid 14 that comes speHing out of the pipe Hill obviously offect the 15 oreas in front of them.

16 The excessive motion ;f the broken pipe is referred l 17 to as pipe Whip. That's one term I si11 be using. The l l

speHing stream of fluid is referred to as Jet, ard everything 18 11 19 that is subject to being hit by that Jet is defined as a Jet 20 impinged target. Target is a new term which I will be 21 referring to. Target is any one of the eqfety-related zb 22 structures, systems and co.aponents which are either in the 2.5 path of the excessively moving pipe or ;ubject to Jet

.w 24 impingement loads.

25 In orJer to establish what is in that path, he have Carmen Gooden, CSR, RPR, Metro 429-5532

'40 1 to establish the extent of movement and the extent of ]

( 2 applicability of the Jet. These areas are defined as zones of 3 influence. That's another thing I will be using.

4 Another resulting effect of a high enargy pipe break 5 is the change in temperature humidity and the pressure in the 6 area where the pipe break took place or is postulated to take And these are referred to as environmental effects.

7 place.

8 So I hope I have defined the target, the Jet and the 9 zones of influence to this process.

10 To give you a better understanding perhaps of Hhat 11 really is happening, I would like tc make an analogy with a 12 simple gardenhose. If you have a gardenhore H.ith a faucet

( 13 open and the sprinkler shut off, and if ycu were to sutdenly i 14 cut that hose right across, you would probably see a movement 15 of the hose ond, of course, a Jet of water thct would 2e s ,

16 speHed out.

17 Another area that's covered-by systems interaction is 18 the internally generated missiles, another terminology, 19 Internally generated missiles are pos'.Liated to tnke place 20 from, as an example, the rotating equipment with a broken 21 piece flying through the casing and perhaps impinging i

22 something on its way. An example of this Hould be a fan or a 23 piece of blade during rotation could be broxen-cnd fly out.

l 24 With this lengthy introduction, let me proceed Hith

(

25 this.

l

- - l Carmen Gooden, CSP., RPR, Metro 429-5532 l

1 ' -

41 1

1 The Systems Interaction Program scope then includes-( 2 identification and protection of the essential systems, 3 structures and components from the unacceptable interaction 4 resulting from the following postulated events: Break in 'nior 1 5 energy and moderate energy piping systems, flooding 6 environmental effect in Seismic Category I structures outside 7 containment, internally scnerated raissiles. And in addition, 8 it also includes the assessment of effects from a postulated i

9 safe shutdown earthquake on nonseismic systems, structures anc 10 components where failure due to that effect may affect 11 safety-related structures, systems and components.  !

12 The objective of the Systems Interaction Program $

{ 13 portion of this Corrective Action Prcaram is to assure thut 14 the postulated event cannot prevent safe shutdown of the 15 accident nor prevent mitigation of the consecucaces of tnese 16 postulated events.

17 Are there any ocustions in my"descrigtion of events?

18 Ebasco is achieving this objective through a 19 systematic validation process which is schematically shown on 20 this chart, Which has already been discussed in some detail. >

21 I'll cover the design validation relcted activity chaHn on 22 this chart such as identification of licensing commitment, 23 development of Design Basis Documents and performance of the  :

24 validation in a little more detail.

( '

. 25 The licensing commitments related to the events 1

Carmen Gooden, CSR, RPR, Metro 429-5532 ,

i 42 1 Hithin the Systems Interaction Program Here identified throust

( 2 extensive review of the Comanche Peak licensing documents.

3 This included the FSAR, the regulatory guides, Safety 4 Evaluation Report and its supplements and the correspondence 5 from TU Electric and NRC.

6 We have identified approximately 88 such commitments 7 which relate to Systems Interoction Program scope of work.

8 The design basis for the systems interaction effort 9 is established from these identified commitments and they are 10 detailed in Design Basis Documents hhich form the basis for 11 the design evaluations.

12 We have issued three such DBDs for the three distinct

( 13 events within the Systems Interaction Program: one 1er 14 seismic /non-seismic interaction program, one for a postulated 15 pipe break and their effects, and one for missile postulation 16 and the effects of this, 17 I'd like to point out that these events are 18 considered on any nuclear poHer plant. It's not unique to 19 this.

20 The Ebasco systems interaction design validation 21 process validates that the design of structures, systems and 22 components complier witn the design tasls and provides

[

23 asstcnnte that the e:Santjal tystems, structures and 24 components Hill continue to perform their essential function f,

25 when subjected to sy;tems interactions resulting from the Carmen Gooden, rSR, RPR, Metro 429-5532

4 I

43 1 postulated event such as, to restate again, pipe rupture,

( 2 which includes HELB and MELB high-energy and moderate-energy 3 lines, environmental and flooding, internally generated 4 misiles, safe shutdown.

5 Perhaps I should come back and define what essential 6 means. Essential are those safety-related structures, systems 7 and components which are required to remain functional in 8 order to assure actual safe shutdown and mitigating 9 consequences.

10 The validation process includes identification of 11 potential target, identification of interaction'Hith the 12 event, assessing and then determining if-the design meets the 13 design basis, and if not, development of modifibations in

{

14 order to meet the design basis, i 15 The design validation is performed utilizing many 12 >

16 tools available for this type of assessment. Utilizing event

! l'7 diagrams which are often' referred to as' fault tree diagrams, 18 which is a logical systematic Hay to identify. systems and

19 components and then assure they are able to perform.

j 20 This includes development of calculations to show

! 21 broken pipe movement, pipe whip, and resulting fluid Jet i 22 impingement zones in the areas affected.by all this are k 23 recorded. '

, 24 It also includes development of calculations to show  !

l 25 environmental and flooding effects resulting from the j

Carmen Gooden, CSR, RPR, Metro 429-5532

I 44 i

1 postulated pipe breaks; the areo the pipe break occurred.

([ 2 And it includes the development of calculations to 3 estimate the failure zone for non-seismically supported 4 systems, structures and components; mostly components. This 5 zone defines the maximum range that the component can traverse 6 in case it fails, grossly fails, during the seismic event.

7 I'd like to cover the specific issues on various 8 items of this, but very conceptually, since this is 9 prelimircry in nature, but it Hill be shown in the PSAR in 10 more dett11, there Here a number of external source issues 11 HM ch Camd from the revieH of the CPRT, and these include 12 quetticos on high energy line break, Hhich included

( 13 development. Questions on development of Jet impingement 14 zones, pipe whip zones of influence and target identification. ,

15 We havo issues on missile hazards, also from CPRT.

10 We have seismic design of control room ceiling 17 elements issue. -- -

18 And there are some issues on fire protection systems 19 interaction aspects.

20 In addition, there Here issues determined to be 21 reportable under the provisions of 10 CFR 50.55(e), which were 22 identified during the implementation of.the Corrective Action 23 Program. These ,ere related to computer software and modeling 24 te:hniques and refer primarily to high energy line breaks, t

25 Technical reviews, resn'r'. ion and corrective and Carmen Gooden, CSR. P.PR, Metro 523-5532

.,.y. c . . - .

i '

145. 5 1 preventive action for the above issues will ba presented in

( 2 Supplement A to the mechanical PSR, which Hill be repo rted in 3 the Systems Interaction Program portion of the torrective l

-4' Antion Pi ogrom.

5 MR, D0YLE: I have no Questlohs.  !

6 MR, ODAR: If there are no i'urther questions, I will -

7 -

give the floor to John WaHrZenick tf Impell Nho.will be  ;

8 providing a discussion on fire protection asprcts, which is fl 9 also part of the mechanical, i

10 MR. WAWRZENIAX: As mentioned my ndme is John I i l

11 Wawrteniak, and I'm the project manager for Impe11 I f

12 Corporation.  :

1

( 13 What I'd like to cover th.i.s morning are two.of the l 14 work scope areas that we've been assigned as far as the (  !

15 Corrective Action Program, namely the fire protection and '

I 16 equipment qualification areas of corrective action, i

~

17 Later on this afternoon you H1'll hear additional i efforts by Impell concerning the cable trays as Hell as 28  !

l 19 conduits, Train C conduit efforts; however, this morning I  !

20 would Just like to concentrate on the fire protection and  !

l 21 equipment qualification scopes of Hork, f

22 - To provide an overvieH of the Corrective Action ,

{

23 Program for fire protection, this effort will be described j i

24 within the supplement of the mechenical Project Status Report. l

i j

25 And what I'd like to do now is to discuss, briefly discuss.  :

l i

Carmen Gooden, CSR, RPR, Metro 429-5532 l

7 c  ;-

1

+ .

qg 1

1 the extent to which the validation effort has been completed- l I 2 for the fire protection area and to bring forth some of the 3 inaJor' issues that Her! Considered during'the completion of  !

4 this validation score.

c 5 The overall objective of the fire protection scope is ,

6 to demonstrate that the installed fire protection system, 7 structures and components comply with the licensing 4

i S commitments & Hill perform their designed functions.

6

9 These objectives are being implemented through a l 10 systematic evaluation of the fire protection portion of the l

11 Corrective Action Program as depicted on thts chart that you  ;

12 have already seen previously by various other presentctions.

13 As indicated, this is a simplification of the previously'

{

14 presented Corrective Action Program block diagram. It 15 presents various inputs and decision blocks within the overall ,

16 CAP program, which I would specifically like to discuss those ,

17 activities undertaken underneath the-licensing commitment identification area, development of Design Basis Documents, as 18 l 19 Hell as the overall design validation effort completed. '

) '

l 20 Licensing commitments in the fire protection area 21 have been identified through an extensive review of the CPSES '

22 licensing documents, including such documents as the FSAR, t

23 Safety Evaluation Reports and supplements, NRC regulatory ,

24 guides, as well as TV Electric and NRC correspondence.

L 25 Approximately 600 fire protection licensing ,

i J rmen {oopm,JSR, RPR, Metro 429-5532

~

47 1 commitments have been identified. These commitments have beer -

( 2 validated through the various disciplines involved in the fire 3 protection program, 4 Our licensing commitment is to Appendix A of the 5 Branch Technical Position 9.5-1, in which general criteria anc 6 recommendations for separation are provided.

7 Additionally, He are also committed to. provide a 8 comparison to Appendix R of 10 CFR 50, which is the current 9 day fire protection methodology which identifies specific 10 separation criteria for fire safe shutdown equipment.

11 In essence, the Appendix R evaluntion is an 12 evaluation of defense in depth from a fire protection 13 standpoint of not only preventing the fire from starting but  !

{

14 also detecting, controlling and extinguishing the fire, and if ,

15 a fire did occur of protecting the safety operation of plant 16 safe shutdown systems. This involves extensive evaluation of i 17 fire protection features 7uch as bcrriers, seah, walls, 13 ,

18 pressure systems and datectio: systems, fire.sofe shutdown ,

19 capability and separation criteria which is on evaluation of 20 the system needed to shut down the plant safely, alternate and 21 dedicated shutdown criteria to ensure that He do have 22 dedicated shutdown through the control room, and in the event 23 of a fire that we also have alternate shutdown capability, as 24 Hell as dealing with such subjects as emergency lighting and 25 communication. .

Carmen Gooden, CSR, RPR, Metro 429-5532

I 48 '

1 Therefore, the fire protection program as implementec

( 2 at Comanche Peak assures that He have not only captured the  !

3 licensing commitments that He are currently required to meet, 4 which is Appendix A to the Branch Technical Position, but alsc >

5 that we have enhanced our overall program to ensure that He  ;

6 Peet the current doy methodology and systems criteria as belns 7 dictated in Appendix R of 10 CFR 50.  !

8 This criteria and bases have been established ano .

9 consolidated within the Design Basis Document, which has been 10 used during the design validation effort.

i 11 The fire protection Design Basis Documents are [

12 :onsolidated into six DBDs dealing with the subject areas of

( 13 fire hazards analysis, penetration seals, fire safe shutdown 14 analysis, fire barriers, fire detection system, and fire j 15 suppression system.

l 16 The design and design controi procedures were l

17 enhanced to implement the~' design basis"defined in these DBDs, ,

, 18 Hhich those procedures encompass not only the design basis 19 itself but also the resolution of CPRT issues, industry  !

t 20 experience, as well as regulatory and professional guidance ,

21 such as applicable codes and standards. I 22

  • The design validation effort for fire protection i

23 demonstrates that the systems, structures and components 24 comply with these licensing commitments, satisfies the design L 25 basis and Hill satisfactorily perform the design functions.

i Carmen Gooden, CSR, RPR, Metro 429-5532

j -

49 1 Design validation has been performed by review of the

( 2 original calculations and drawings, a raview of fire test 3 reports, performance of engineering Halkdowns, as well as the 4 generation of additional drawings and calculations.

5 The features which have been validated include fire 6 barriers, fire suppression systems, fire detection systems, 7 communication systems, as Hell as emergency lighting systems.

8 The fire prctection analysis that has been validated 9 includes fire hazards analysis, as Hell as fire safe shutdown 10 analysis.

11 Fire safe shutdr <n analysis, to give you a little 12 definition, is an evaluation of the fire safe shutdown system.

( 13 Safe shutdown systems that are necessary to shut doHn the 14 plant is the identification of all essential fire safe 15 shutdoHn OQuipment and any operator actions as necesScry in 1G order to maintain control of any fire in any crea.

17 That information-is input data into the fire hazards 18 analysis which integrates results of the fire hazards analysis 19 und then in turn evaluates the need for fire barriers, reviews 20 combustible loading, suppression detection evaluations, as 21 Hell as NSPA code compliance.

22 This information is contained into six Design 23 Validation Packages for the fire prctection information in 24 Hhich these DVPs are an index of current documentation needed

( '

25 to document the validation effort of each individual's Carmen Gooden, CSR, RPR, Metro 429-5532

1 - -

50 1 particular design scope, but would not necessarily list all

( 2 the historical documents that may have been needed during the 3 validation effort previously; it mcy have been voided or 4 superceded.

5 These validation packages include fire hazards 6 analysis, penetration seals, fire safe shutdown analysis, fire 7 barriers, fire suppression and fire detection.

8 This validation effort is nearing completion and is 9 scheduled for year-end. This information Hill-be integrated 10 into Supplement B of the mechanical Project Status Report.

11 Dealing with specific issues in the fire protection 12 area, before I get into that Larry mentioned the DIRs that

{ 13 Impell is responsible for. In total Impell is responsible for 14 approximately 300 DIRs in the areas of fire protection, 15 equipment qualification, cable trays, as Hell as Train C.

16 The Corrective Action Program for fire protection 17 validates the resolution'Uf design and~ hardware issues 18 identified by CPRT, external issues and Corrective A'ction i l

19 Program.

20 The CPRT issbas which were resolved thrcuch the DIR l 21 issues include fire exit routes, flame spread of interior ,

22 finishes, fire damper testing, eight-hour emergency lighting I 23 units, fire protection systems interaction, fire safe shutdowr 1

24 and alternate shutoown, as well as Hork in progress. l 25 As a final note, I Hill note that He have had an NRC i

Carmen Gooden, CSR, RPR, Metro 429-5532

]

'T -'

51 L-1 audit of the fire protection program during the-Heek of ,

lb 2 October 19th through 23rd, in which no deviations or 3 violations Here identified in the CPSES fire protection ,

4 program. ,

5 I'd likeLto field-any questions that you may have on- t i 6 fire protection before I go on to equipment qualifications. .

t 7 MR. D0YLE: I have none.  ;

) 8 MR. WAWRZENIAK: Before we_get going on equipment. I 4

i 9 qualification, I'd like to augment something that Mr. .

r 10 Siskin mentioned yesterday concerning the qualification of l.

11 snubbers. These components do'indeed see a very comprehensive 12 venaor qualification effort, including not only tests but also f

4 i

(N14 13 load gradings of these items. This qualification stctus is ir -

! 14 turn assured through extensive maintenance and surveillance i

15 efforts, which is being implemented through the maintenance  !,

! 16 depcrtment of TU Electric for the life of the plant. And it  !

l'7 is a very extensive progrum' requiring very frequent  ;

t i 18 surveillances as well as maintenance requirements.

3  !

19 In the equipment qualification area, I'd like to 20 again give you an overview of tne equipment qualification l i i

. 21 program, again to briefly discuss the extent of Which the i  !

] 22 validation has b-- completed and again.to overview some of j

! 23 the major issues that we have considered during the validatior  !

! l j 24 of'the equipment qualification scope, 1 ( f

' l

, 25 The objective of the equipment qualification program  :

) '

i Carmen.Gooden, CSR, RPR, Metro 429-5532 l

T~

52- i 1 is to demonstrate that the installed equipment is able to.

d[ 2 perform,its required function in accordance with licensing 3 commitments under the following conditions of normal service 4 environment, postulated seismic events, as Hell as environment 5 caused by postulated accident environment, 6 The question comes out: What is equipment i 7 qualification? Equipment qualification demonstrates that the 8 equipment Hhich is required to be qualified can perform its 9 design function when subject to seismic accelerations and 10 environmental conditions. It also includes the assembly of 11 required documentation to demonstrate the basis'of this -

12 qualification.

( 13 Seismic qualification of equipment inc'udes l the 14 consideration of not only the seismic acceleration which may P

15 be imposed on them but also the normal operating loads such as 16 pressure and temperature in which the equipment-must operate, 17 as well as other external ~loods such as piping reoctions and 18 nozzle loads on the equipment.

19 Environmental qualification of equipment includes on 20 evaluation of the equipment's ability to function Hhen 4

i 21 subjected to such environment and pressure normal and elevatec  !

22 temperature, normal and postulated accident radiation values,

23 humidity, flooding, spraying.

24 As presented previously, He have a similar floH chart

(

25 of the Corrective Action Program for equipment qualification, Carmen Gooden, CSR, RPR, Metro 429-5532

53 -

1 and again, it's a simplification of the overall block diagram  ;

4 ( 2 whien you've previously seen, 3 I'd like to again 90 into the licensing commitment I 4 identification.. development of Design Basis Documents and the  ;

i 5 overall validation effort completed for equipment 't 6 qualification,  ;

7 The identification of licensing commitments, as true  !

1 8 in the fire protection area, included the identification of 9 licensing commitments through an extensive review of the CPSES  !

. i 10 licensing documents, including the final ~ Safety Analysis  !

11 Report, safety evaluations and their supplements, TV Electric I i

12 and NRC correspondence, as well as regulatory guides.

j 13 Approximately 250 equipment qualification licensing

] (

l 14 commitments have been identified, and11n addition, as was true  !

i 15 in the fire protection area, He have incorporated current day I

16 equipment qualification methodology and basis through the i
f l'7 review of various industry codes and standards, as Hu11'as i  :

i 18 applicable industry equipment qualifications event reports, l 19 One thing I'd like to mention here, that there has  ;

20 been a significant evolution for equipment qualification i

l 21 knowledge during the late '70s and early '80s. This evolution  :

l 22 has expanded the level of required qualification, the methods )

23 by which this qualification should be completed, as well as 4

24 the degree which this qualification should be documented. .

~

25 This enhanced knowledge has been documented through various l

1  !

\ i

?

Carmen Gooden, CSR, RPR, Metro 429-5532

54 1 documents, including industry papers and standards, regulatory I 2 guides, bulletins and notices, as well as federal laws, such 3 as 10 CFR 50, 4 These licensing commitments, as Hell as current 5 industry knowledge, have been assembled in the Design Basis 6 Document into two design validation areas of seismic equipment 7 qualification as Hell as environmental equipment 8 qualification.

9 o In addition, He have assembled the CPSES plant 10 specific data to define the qualification parameters, 11 pressure, temperature, humidity, radiation, flooding and 12 sprcying. This information is captured within the equipment

( 13 qualification Design Basis Documents, including seismic 14 qualification of equipment, environmental qualification of 15 safety-related mechanical equipment, environmental 16 qualification of safety-related electrical equipment and 17 postulated environment for equipment

  • qualification.

18 We have also enhanced the procedures'to add design 19 and design control procedures to implement the Design Basis 20 Documents within the DBDs to include the basis itself, 21 resolution of the CPRT issues, industry experience, as well as 22 regulatory and professional society guidance.

23 The design validation scope of equipment 24 qualification, t

25 Validated that the safety related function for all Carmen Gooden, CSR5 RPR, Metro 429-5532

55 1 equipment required qualification is not impaired by the

( 2 seismic and/or environmental condition to Hhich they may be 3 subjected.

4 Design validation was completed through the 5 development of the Equipment Qualification Master List which I 6 Hill define in a second, 7 Establishment of environmental qualification records 8 and documentation.

9 And establishment of seismic qualification records 10 and documentation.

11 The Equipment Qualification Master' List includes l

12 system identification which was completed through an EOML 13 basis report which defines the system needed for safe shutdoHr

{

14 and systematically goes through and defines the basis by whict 15 He would identify those pieces of equipment which require

~

16 qualification.

17 Development of"E0ML analysis was completed through '

18 design and design control procedures which dictated the 19 systematic CPSES design document review and identification of

)

's 20 approximately 17,000 components and subcomponents requiring i

21 qualification.

l I

22 This information is contained Hithin a controlled 4 23 listing of equipment requiring qualification and also includes  ;

24 an identification of specification, the system, component 25 type, piant location, model and manufacturing number, i

Carmen Gooden, CSR, RPR, Metro 429-5532

56 15 1 functional category.

( 2 Environmental qualification included the assembly anc 3 review of approximately 100 existing qualification records, 4 files and test documentation.

5 This information has been segregated into 6 environmental categories of Class 1E equipment located in 7 harsh environment, Class 1E equipment located in mild 8 environment, and active safety-related equipment located in 9 harsh environment. A harsh environment are those environments 10 that are postulated to occur due to hypothetical accident 11 scenarios such as pipe break, which Mr. OdJr mentioned 12 earlier. Typically, it Hould occur inside a Containment and

( 13 isolated areas outside the containment.

14 Mild environment, on the other hand, are those 15 environments that are outside the harsh area and therefore are ,

16 not exposed to the postulated accident environment. -

17 Through validation efforts we have developed i

18 approximately 150 comprehensive environmental' qualification 19 packages that validate the environmental qualification of  !

20 equipment.

21 In addition, He have identified all maintenance 22 requirements necessary to maintain that. qualification status, l

23 Seismic qualification equipment included the assembly i

24 and review of approximately 150 existing qualification 25 specificat. ion files and qualification documentation.

Carmen Gooden, CSR, RPR, Metro 429-5532

.. ~

57 1 We have developed approximately 500 seismic Category

( 2 I qualification packages that validate the seismic 3 qualification of equipment.

4 Three Design Validation Packages have been developed 5 for equipment qualification area that include the Equipment 6 Qualification Master List, environmental equipment 7 qualification, and seismic equipment qualification.

8 The design validation and equipment qualification is 9 nearing completion and is scheduled for year-end.

10 These results Hill be integrated into a Project 11 Status Report, which is scheduled for submission in the near 12 future.

( 13 The results of this design validation indicate a 14 conservative level of qualification for equipment requiring 15 very little modification overall.

16 Of the 17,000 items that require qualification, only 17 approximately 500 items"required modification and/or 18 J Here to ensure the replacement, where in most cases the mo's 19 existing qualification levels of conservatism and a 20 replacement Hhich would implement required maintenance

)

l 21 intervals to assure qualified life.

l 22 Some of the specific issues which we dealt Hith 23 during the equipment qualification area were resolved through 24 the Corrective Action Program in which the CPRT issues 25 included such items as the identifie.ation and classification,  !

1 Carmen Gooden, CSR, RPR, Metro 429-5532 j

58- ,

1 environmental conditions and requirements, environmental  !

( 2 documentation, seismic documentation, generic regulatory 3 concerns, maintenance and surveillance, cable slack and 4 flexible conduit issues. i 5 Some of the specific issues that were identified 6 during the performance of our design validation effort that 7 are currently being evaluated-for potential reportability 8 under the provisions of 10 CFR 50.55(e) include fan oil unit

9 nozzle load evaluation, heat exchanger support structure and 10 mid-lug modification, lube oil unit pressure strainer clip ,

11 angle modification and Lim 1 torque actuators.

12 That ends my presentation on equipment qualification.

13 I'd like to field whatever questions you may have.

(

14 MR. D0YLE: I have no questions on that, i 15 MR. WAWRZENIAX: With that I'd like to turn it back j

1F to Enver Odar to discuss the six items that we wanted covered

~'

, 17 under the PSR concerning HVAC.

i 18 MR. ODAR: Validation of heating, ventilation and air l l

19 conditioning systems, as well as structural component design 2v is among the corrective action scopes of work directly l

21 assigned to Ebasco.

, ]

I The structural components include HVAC ducts, duct 22 23 supports, air handling units, plenum, and equipment supports, 24 which encompass all structural portions of HVAC.

25 I'll provide an overview of +he systematic process of 4

Carmen Gooden, CSR, RPR, Metro 429-5532

59 i

i i

1 this design validation effort which is being performed by i

( 2 Ebasco.

3 The objective of the Corrective Action Program 1 4 implemented by Ebasco on-HVAC structural components and HVAC 5 systems is to demonstrate that the design of HVAC structural 6 components and HVAC systems comply with the licensing i 7 commitment, and to demonstrate that the existing HVAC  :

8 structural components and HVAC systems comply Hith the design,  !

9 or develop modifications necessary to bring them into l

10 compliance with the design.

11 Ebasco again is achieving the objectives of this  !

r 12 Corrective Action Program through a systematic validation I

( 13 process which is schematically shown on this flow chart. You l 14 have seen this a number of times. It's o simplified chart for  !

15 our use.

  • 16 Once again, I will cover the design validation  !

t 1

17 related activities which include the-identification of [

1 18 , licensing commitments, development of Design Basis Documents 19 and performance of this design validation in a little more 20 detail.

I 21 The licensing commitments for the HVAC structural 22 components and HVAC systems Here identi.fied through an 23 extensive revieH of CPSES licensing documents, which included:

l 24 FSAR, Safety Evaluation Reports and its supplements, NRC ,

! I 25 regulatory guides and correspondence Hith NRC and TU Electric. i l

Carmen Gooden, CSR, RPR, Metro 429-5532

- . . , . ~

60 1 More than 130 HVAC systems and more than 50 HVAC

$ 2 structural components related to the commitment were so 3 identified.

4 The identified licensing commitments formed the basis 16 L 5 for the establishment of a set of Design Basis Documents whict 6 were developed for HVAC systems, as Hell as HVAC structural

$ 7 components for the design validation to ensure compliance witt 8 these licensing commitments.

9- One Design Basis Document for HVAC structural design 10 validation and one each for each of the 14 HVAC systems were

]

r i 11 developed, i

12 In addition, detailed Design Validation Procedures

{ 13 were also developed for the imp.1.ementation of the design basis 14 and validation process. These orocedures incorporate the CPRT  ;

15 and external issue resolution results, regulatory and 16 professional society guidance, industry experience and the 17 results of engineering studies and tes'ts'which Here performed 18 to form the basis for the De. ton Validation P'rocedure, 19 As Ralph mentioned earlier, there are a number of 20 interfaces that HVAC design validation must have for other 21 disciplines. We utilize the information from other discipline 22 Hork, notably electrical and mechanical, and we provide +

information as a result of our work to some others.

23 For i 24 example, the EQ, in order to establish engineering conditions j 25 in on area where equipment 1s being qualified. l 4

Carmen Gooden. CSR, RPR, Metro 429-5532_

i -

61 4-I i 1 HVAC systems and HVAC structural component designs ,

( 2 are validated to demonstrate conformance to the design basis ,

t 3 requirements. For HVAC systems design they're validated by 4 the completion of the as-built heat load calculations, and 5 review of the technical performance of HVAC equipment to l 6 assure that the indoor ambient environmental conditions 7 committed to in licensing documents are met.

8 Once again, I'd like to define environnantal as beins 9 temperature and humidity that must be maintained or is 10 committed to be maintained in a given area. -

4 11 HVAC structural component design, Which once again t

12 includes ducts, du.c supports, air handling units, plenums anc i

( 13 equipment supports, are validated to demonstrate the 14 conformance of the installed configurations to the design i 15 basis req"irements. -

a 16 The design validation is performed on as-built 17 cor. figurations which are then analyzed"utilizing detailed 18 structural systems as well as stress analysis.

19 HVAC systems or HVAC structural components which are 20 found to be not in caqformance with the design are identified a

21 and the design changes are being implemented.

22 To give you an idea of the scope of this effort, 14 l

23 HVAC systems have been design validated. As part of the l I

24 structural component validation effort, approximately 4,000  !

25 seismic Category I and II duct supports were as-built and 1 Carmen Gooden, CSR, RPR, Metro 429-5532

i 62 4'

1 design validated.

( 2 .As-built and design validation is also applied to 3 about 3900 duct segments.

, 4 There are approximately 90 air handling units, 5 plenums and equipment supports which are being as-built and 6 design validated.

7 We are Hell along in the design validation effort onc 8 expect to finish in the very near future, i 9 There Here a number of specific issues that are 10 applicable to design validation effort of HVAC systems and  ;

11 HVAC structural component validation effort. -  !

t 12 These issues which are related to systems, to .

-i

( 13 structural component design and to construction are shown on I 14 this one and the next pages, and include the issues that came '

from CPRT and other external sources.

15

, +

16 These include tHo CASE issues on the HVAC program l'7 which were identified eartier. **

18 I would like to -- I'm not going to 90 through

^

19 details of each, although I would like to point out that CYGNA 20 conduit and cable tray issues and CASE /CYGNA cable tray issues 21 shown in the bottom of the list are actually issues that we

22 ourselves found to be applicable by reviewing the issues on

) 23 similar applications such as cable trays and conduits, and He 24 included them for evaluation in an issue related to HVAC

(' r 25 structural components.  ;

, l' i

Carmen Gooden, CSR, RPR, Metro 429-5532  !

j ~

63 1 The technical revieH resolution and corrective and

( 2 preventive actions for the above specific issues will be 3 presented in the subappendix to the HVAC Project Status Report 4 Hhich will be issued in the near future.

5 MR. D0YLE: I don't have any questions on what these 6 gentlemen have said. I do have, however, o question that's 7 more of a clarification, 8 During the hearings, if you recall, He had three 9 different organizations involved using three different sets of 10 criteria, particularly in the area of allowables. Apparently l

11 He resolved that, and He now have three major organizations  :

12 all folloHing a similar floH pattern. It might have been 13 mentioned then and I might not have been paying attention, but

{ ,

14 how did you achieve a situation at Comanct.d Peak where three 15 separate, independent organizations were all following the 16 same flow pattern?

l'7 MR, NACE: I'd like to answer ~that, Jack. In fact, I '

18 was going to talk about that in my closing remarks for this  !

19 panel. One of the things He wanted to impress you on is that 20 the current day design programs, including uesign interface, ,

21 are very sophisticated and are very much a formal control l

22 measure. . ,

i 23 Yes, He do have three major contractors involved in l

24 the project: Stone & Webster, Ebasco and Impell. We like to

( '

25 think that the only time they recognize themselves as l Carmen Gooden, CSR, RPR,' Metro 429-5532

1 64 17 1 different contractors is when they get their paychecks and I- 2 when He.have meetings such as this where they have to mention 3 their name. And you knoH that's not true. People do have 4 organization association. However, to control that technical 5 interface, which is most important, What we have developed 6 over the course of the years is a very sophisticated set of 7 design interface procedures which Mr. LoHe maintains. In our 8 stable they are called task descriptions. Each task, such as 9 HVAC or equipment qualification, contains a very detailed 10 description of the scope of Hork and the identification of 11 technical interfaces and leads to subtier procedures that 12 control the floH of information back and forth between those contractors.

( 13 I hope that you saw through this presentation 14 that they Here all using the same set of controlled design ,

15 information, whether it's allowables, whether it's 16 environmental conditions which one contractor developed and 17 dissemination of the control procedures to the other for 18 application. Mr. Odar talked about determining the effects of 19 pipe break, pipe whip, Which adds environmental factors to a 20 civen cubicle area. That information is included within the 21 control set of environmental factors. Impell uses that same I l

22 set of control information as a basis of qualifying equipment l

23 for effect and so forth.

24 We hope He have impressed upon you that the current i~

25 day interface control and design control procedures are very Carmen Goodan, CSR, RPR, Metro 429-5532

65 1 formal and very much current, and He like to think in the Ib 2 forefront of the state of the art within the industry toduy.

3 MR. D0YLE: All right.

4 MR. NACE: While this presentation Has, in fact, an 5 overview, I have detected in the past that Mrs. Ellis has 6 expressed some questions concerning what it is We're doing in 7 some of these other areas. We hope this has explained this tc 8 you as best He can in this short presentation.

9 We have introduced some new faces to you which you 10 Hill see at later meetings such as this. We hope He have 11 given you a full overview picture of Hhat it is He're about ir 12 the Corrective Action Program itself.

13 MRS. ELLIS: I think, of course, He'll have some

(

14 more detailed questions, I'm sure, as He get into even more 15 detail, but I think Hhat's been presented has been helpful, 16 certainly to this point, and He appreciate it.

17 When we get into it in more-detail, He'll get back in 18 touch and maybe we can have another meeting like this, or do 19 it in writing, Fiatever it takes. But I'm sure that He H111 20 have more detailed questions on several of these.

21 We need to take some time noH to set up for the 22 remaining three scopes of work, starting Hith cable tray 23 hangers, and since it's near the lunch hour, I propose that He 24 adjourn now for lunch and come back at 1:00 o' clock and He'll 25 start Hith the cable tray hangers a'i that time.

Carmen Gooden, CSR, RPR, Metro 429-5532

66 1 (A break was taken for lunch.)

( 2 . MR. NACE: The meeting Hill come ba;X to order. The -

3 panel at the table now is going to start the discussion, a 4 detailed issue discussion, on the cable tray.and cable tray .

5 hanger scope of Work under the Corrective Actio,n Program.

6 I'll introduce Jim Muffett and he Hill introduce the 7 remainder of the panel.

8 Jim is a TU Electric manager of civil engineering for 9 the Comanche Peak engineering organization.

10 MR MUFFETT: Before I introduce my'associatcs here, 11 I'd like to mention my background. I've been in this industry 12 about 17 years and am a member of ASME, American Nuclear i

{ 13 Society, and have Worked on many more plants than I can 14 remember to tell you right now.

15 Prior to this Job I Was Hith the NRC in Region III, 16 and I was the chief of the Plant Systems Section. So I have 17 pretty intimate knowledge'of the accep'tance standards in these 18 areas of NRC.

19 To my right is Greg Ashley who is the technictt 20 manager and assistant manager with Impell for the Cable Tray f

21 Hanger Program.

22 MR. ASHLEY: Yes, I'm technical manager with Impell.

23 I've - ith Impell for about six years, During that time 24 I've worked on numerous nuclear proJacts involving about 10 25 nuclear plants. My involvement with those projects has been l l

l Carmen Gooden, CSR, RPR, Metro 429-5532 l

gy 1 predominantly structural design, structural analysis,

( 2 including previous seismi~c nnalysis.

3 To my right is Kevin Warapius from Impell.

4 MR. WARAPIUS: I'm Kevin Harapius. I am the Project 5 Director for Impell for all scopes of work being performed by 6 Impell on this project, including cable trays, MCs, conduits 7 and varying eqLipment qualification and fire protection.

8 I've been in this industry approximately nine years.

9 My entire career in this industry has been with Impell 10 Corporation. I have Horked on.over 15 plants, domestic as Hell 11 as the Far East, in areas ranging from seismic analysis 12 and design of structures and systems to equipment

( 13 qualification and pipe rupture protection. Over the past two 14 and a half years I've been Horking on the Comanche Peak 15 project.

16 I'm a registered professional engineer and a member 17 of the American Society"of Civil Engin'eers. l 18 MR MUFFETT: To my left is Rene Alexandru.

19 MR. ALEXANDRU: I am Rene Alexandru. I am a senior i 20 supervising engineer with Ebosco Services. I graduated in 1

21 civil / structural engineering 27 years ago. I've had 15 years 22 experience at nuclear engineering, of Hhich 13 Here With 23 Ebasco. I've participated in the design of 10 nuclear power 24 plants, all operating, of which seven are in the United

'f 8 l

25 States. In Ebasco I have been in charge of a specialized l Carmen Gooden, CSR, RPR, Metre 429-5532

~~ '

68 ;

1 group dealing Hith some of the most complex problems of

( 2 nuclear powerplants called Special Analysis Group. You're i 3 going to see the SAG denomination in some of the Ebasco 4 criteria, which stands for Special Analysis Group. ,

5 I am a registered professional engineer and I am a I 6 member of the American Society of Civil Engineers where I 7 participated in various working communities, one of them 8 dealing with establishment of the writing of standards for 9 seismic design of nuclear safety structures, which has been 10 published about a year now.

11 MR. MUFFETT: And to his left is Pat Harrison, lead 12 engineer for Ebasco.

( 13 MR. HARRISON: I'm Pat Harrison, lead engineer for 14 Ebosco technical support for cable tray hangers. I have 11 '

15 years of experience in this industry with Ebasco. I've worked 16 on five nuclear plants, and I have a professional license.

17 MR. MUFFETT: I'd-like to get* started Hith the issues 18 now, and I have a little introduction that gives an overview.

4 19 As He stated before, cable trays and cable tray l 20 hangers are part of the Corrs:tive Action Program.

21 First, a little bit about the scope. The scope of l 22 this effort in Unit 1 and common areas,.. Seismic Category I o?.d 4

i 23 Seismic Category II cable trays and cable tray hangers. All l 24 these have been design validated. As you know, a PSR has been i'

25 issued in this area.

Carmen Gooden, CSR, RPR, Metro 429-5532

)

69 :

1 The primary features of the Corrective Action Progran

( 2 for cabl.e trays and cable tray hangers are the establishment 3 of the licensing commitment and design criteria; development 4 of the Design Basis Document; implementation of design and 5 hardware validation, including identification and  !

implementation of necessary modifications; resolution of the  !

6 l design and hardware-related issues for these commodities; 7

8 compilation of validated design documentation to form the 9 basis of configuration control.

10 Going a little bit deeper, in identifying the l 11 commitment the basic documents that we used are the FSAR, 12 applicable reg guides and ISE bulletins and applicable codes 13 and standards,

{

14 To establish the design validation criteria and 15 procedures, numerous engineering studies have been performed

! 16 about the behavior and response of these, i

17 In addition, extensive testing has been performed, l 18 and He'll get to see that, a little bit of thbt, in a second.

19 We have tested full scale dynamic representative systems, and l 20 He've also tested components, i 21 The overall goal -- another goal of this program is 3

22 to provide assurance that all external source concerns have 23 been resolved. There's been an extensive review by the CPRT i

)

i 24 Third Party, which Has performed by TENERA, and it's I

(

25 documented in DAP Results Report, which is DAP Results Report  !

~

Carmen Gooden, CSR, RPR, Metro 429-5532

70 1 C/S-001.

$ 2 In performing the design validation, there's a 3 collection of the as-built data. Design validation is built 4 on as-built data to validate the design of the system. Where 5 those designs are not appropriate, there's a design validatior 6 of each and every r.able tray hanger, there's a design 7 validation for trays and clamps. It is said in certain cases 8 hardware modifications result.

9 The last thing is a final reconciliation process 10 which incorporates the results from the post construction 11 hardware validation. It closes to make sure that all the oper 12 items, Hherever they come from, are closed, and it compiles

( 13 the Design Validation Packages that have been mentioned 14 before.

15 I'd like to refer next to a floH chart Which covers 16 this process. This flow chart shows the same steps that I 17 Just talked about, and listed are the procedures that control t i 18 that process in the design validation.

19 The next slide, which is one He have seen before, is

. 20 the overall flow chart for how the Corrective Action Program i

21 is performed. It's basically put in here to give you an idea 22 conceptually of how the Corrective Action Program is 23 performed, and you've seen it before with prior ones. You'll j 24 get to see it again.

25 The next thing I'd like to do is He have a tape that

' 1 Carmen Gooden, CSR, RPR, Metro 429-5532

.j y q 1 was produced by ANCO Labs where He did the full scale shake

([

2 table tests of the cable trays and conduits.

3 We'd like to take five minutes ond show you this 4 tape. I think it's very interesting.

Those in the audience on the left-hand

~

5 MR. NACE:

6 side may want to move to the wall on the right to give you on J

7 opportunity to see the TV monitor.

8 MR. MUFFETT: This yellow is the actual shake table 9 space frame. You'll see the conduits -- here are the 10 conduits. Here are the cable trays.

11 (The folloHing is from a video tape ,

P j 12 presentation.)

j 13 In 1985 TU Electric conducted a major program of

(

14 seismic tests to demonstrate the earthquake design adequacy of 15 the cable tray and conduit systems installed in the Comanche t 16 Peak Steam Electric Station.

17 Cable tray and conduit systems carry electrical ,

18 cables important to plant peformance distributing many miles .

19 of cable throughout the poHerplant.

20 The cables not only provide power to internal 21 equipment but also serve to direct and monitor equipment 22 performance during powerplant operation, 23 The two-year-long test program evaluated six l ,

24 different cable tray systems and 18 different conduit systems.

9

's '

j 25 This videotape presents the methods used in testing, shows

) l 3

l Carmen Gooden., CSR, RPR, Metro 429-5532

i 72 i

\

i some of the testing, and summarizes key results.

( 2 The approach used in conducting this seismic 3 demonstration program was to install representative Comanche 19 4 Peak plant equipment on large earthquake shake tables and ther 5 to shake that equipment to earthquakes of various sizes, 6 Equipment was not only tested with a safe 7 shutdown earthquake, or an SSE, the largest magnitude 8 earthquake anticipated for Comanche Peak, but testing to 9 levels of shaking Hell above the safe shutdoHn earthquakes was 10 also conducted to provide additional evidence of design 11 adequacy, 12 TU Electric selected ANCO Engineers located in

{ 13 the Los Angeles, Californio, crea as the engineering company 14 responsible for the earthquake testing. ANCO Engineers owns 15 and operates one of the largest earthquake test facilities in 16 the United States and has been conducting earthquake response 17 projects for nearly 20 years. -

18 Its shake table is a 20-foot long steel i 19 structure mounted on hydraulic actuators. It is the actuators 20 powered by highly pressurized hydraulic fluid that shake the 21 steel frames and produces the earthquake-like shaking of the

~

22 conduits and cable trays.

23 For the Comanche Peak test the cable tray and

, 24 conduit systems were suspended from'the ceiling of the shake i :

4 25 table similar to their installation at Comanche Peak.

Carmen Gooden, CSR. RPR, Metro 429-5532  !

j -

73 1 Sixty-four instruments Here attached to the Comanche Peak

( 2 equipment on the shake table to measure the shaking motion 3 achieved during testing. These shaking motions caused the 4 instruments to produce electrical signals that Here 5 transmitted through small cables and signal processes to a 6 nearby computer system Hhere they were recorded and analyzed.

7 The initial phase of the test program focused or 8 the cable tray systems. These systems consist of shallow 9 steel troughs filled Hith electrical cables and supported by 10 Helded steel structures that hang from the ceilings or Halls.

11 The cable tray systems installed on ANC0 shake 12 tables were about 40 feet long. They were made up of either a

( 13 single ldvel or double level of cable trays.

14 (Simulated earthquake snoHn on screen.)

15 The cable tray earthquake testing demonstrated 16 that all the typical designs testea performed Hell throughout 17 the range of earthquak's STzes and number of earthquakes 18 imposed on each. ~ Performed Hell" means that none of the 19 cable tray specimens showed significant distortion or other 20 debilitating behavior.  ;

1 21 All of the tested specimens remained intact and 22 stable despite repeated shaking with earthquakes up to about l

1 23 two times severe as ever anticipated to occur at Comanche  !

l 24 Peuk. In fact, some of the cable tray systems Here shaken l 25 Hith as many as a dozen severe earthquakes With no significant Carmen Gooden, CSR, RPR, Metro 429-5532 l

l 74 1 effect.

( 2 . Conduit systems also carry electrical cable -

3 throughout Comanche Peak, although the cables are much smaller 4 diameters than cable trays. The conduits have steel pipes 5 through which electric wire is run. The conduits are attachec 6 to structures with hardware consisting of U-shaped steel 7 conduit clamps and fasteners. This attachment hardware, the 8 clamps, fasteners, studs and bolts, were tested along with the 9 conduit pipe to demonstrate their ability to Hithstand severe 10 earthquakes.

11 Fastened to the top of the shake table, the 12 conduits were tested three at a time, sometimes in straight

( 13 runs and sometimes in runs ending with a curved section.

14 At times extra weights were affixed to the i

15 conduits to increase the seismic loads imposed on the conduit i

16 attachment hardware.

l'7 (Simuluted earthquake shown on screen.)

i' 18 The conduits seismic tested included for the 19 specimens tested six or more earthquakes equal to or more 20 severe than the maximum earthquake expected to occur at J

21 Comanche Peak. Results showed that the conduit systems could 22 successfully tolerate all the seismic loads to which they were l ,

1 23 subjected.

i i 24 Furthermore, no attachment failures were

('

! 25 obtained for earthquake inputs up to or more than two times l

l i

Carmen Gooden, CSR, RPR, Metro 42.0-5532

I -75 1 the most severe earthquake anticipated for the Comanche Peak

( 2 area.

3 The seismic test program subjected six cable 4 tray systems and 18 conduit systems to severe earthquakes up 5 to and greatly exceeding the maximum earthquake. anticipated tc 6 ever occur at Comanche Peak. The results of this test progran 7 successfully demonstrated that large earthquake. safety margins 8 exist in the cable troy and conduit systems designed for TU 9 Electric's Comanche Peak Steam Electric Station.

10 (End of tape presentation.)

11 MR. MUFFETT: Before He move on, I'd like to know if 12 you have any questions about the tape; testing in general.

( 13 MR. D0YLE: The only question is: Could you define 14 the "two times"?

15 COURT REPORTER: I don't believe your mikes 16 are Horking. I'm having trouble hearing this side.

17 MR. MUFFETT: Well, that's a very good question. As 18 you know, defining Hhat one earthquake means to another is --

19 because of the peaks and spikes -- a someHhat Complicated 20 question. I believe that that's tHo times the peak and a 21 higher multiple of the ZPA, but I'll get that information for 22 you. We had some discussion how to characterize that and get 23 it in a way that the narrator could discuss it successfully 24 also.

. 25 MRS. ELLIS: I have a feeling He'll have some more Carmen Gooden, CSR, RPR, Metro 429-5532

I 76 1 questions about that. Would it be possible to get a copy of I 2 that tape? Can He make arrangements to do that?

3 MR. COUNSIL: Just so you don't ask for a VCR, too.

4 Yes, He can get you o copy of the tape, 5 MR. MUFFETT: Before'He move on, I'd like to Just 6 emphasize two points, one which was covered and one that 7 Hasn't. Those cable trays are built exactly the same way as 8 the ones at the site; same procedures, same design. And, in 9 fact, they incorporate construction discrepancies. Those He 10 didn't make goldplated perfect cable trays for these tests.

11 They incorporated construction deficiencies that have been 12 mentioned. And, in fact, He did test some since He had the

( 13 tests set up worse than the discrepancies. We tested a very

, 14 long member with a KL over R, 15 MR ALEXANDRU: In excess of 300.

16 MR. MUFFETT: In excess of 300. And He also tested i 17 ore of those that Has bent.

  • 18 MR ASHLEY: With an intentional bend Just to see hob 19 it would behave since He had the test cet up there.  !

20 MR. MUFFETT: The other point I'd like to make on the 21 conduit is that the conduit He actually had to add Height to ,

22 the conduit to get some of the clamps to fail. This is the 23 biggest, most poHerful shake table He Could get hold of, and 24 He couldn't get some of the conduit clamps to fail on it so He f

25 added weight; and in some cases He Hound chain on the conduit Carmen Gooden, CSR, RPR, Metro 429-5532

3 --

77 1 for added mass. And those little square black pieces that yot

( 2 saw on the conduit were added Heights to get the seismic loads 3 up.

4 Any questions about that?

5 MRS. ELLIS: HoH long -- you said it at the very 6 beginning but I Just didn't catch it -- over how long a 7 period of time were these tests done? ,

8 MR. ASHLEY: Physical time, or how long Here the 9 earthquakes? l 10 MRS. ELLIS: I think they said like over a two-year 11 period --

12 MR. MUFFETT: Approximately over a two-year period.

, 13 MRS. ELLIS: Were these all like the original designs

{

14 then?

15 MR MUFFETT: No. These are like -- in some cases l 16 they incorporate modifications. In some cases they j l'7 incorporate construction teficiencies.-

18 MR. ALEXANDRU: Like the ones you will find at the 19 plant.

20 MR. MUFFETT: That's the best answer.

21 MRS. FLLIS: Did they have --

22 MR. D0YLE: In the present plant.

23 MR. ALEXANDRU: Right.

24 MRS. ELLIS: They have -- What? -- thermolco i'

l 25 included?

1 Carmen Gooden, CSR, RPR, Metro 429-5532

78 1 MR. MUFFETT: These did not have thermolog.

( 2 MR. D0YLE: I didn't see-any.

3 MRS. ELLIS: We may have some more, but --

4 MR MUFFETT: At this point I'd like to-get into the 5 issues, and I believe He'd like to skip ahead Jnd do Issue 30, 6 31. We'd like to do Issue 30 right now.

7 Kevin Warapius is going to present that.

8 I misspoke myself. Greg Ashley is going to present 9 this.

10 MR. ASHLEY: This external source issue which was 11 brought up by CASE is the validity of four-percent and 12 seven-percent damping for the OBE and SSE seismic evaluation

{ 13 of cable tray systems. These damping values have been 14 questioned.

15 This issue is resolved by the full scale dynamic 16 tests of representative cable tray systems. The results are l'7 documented in Report 09-I210-1107 and ANCO final summary 18 report for Comanche Peak cable tray tests.

19 These tests have demonstrated the validity of using 20 four-percent and seven-percent damping in the evaluation of 21 OBE and SSE seismic loads, respectively.

22 Actual damping values Here determined to be greater 23 than four percent for OBE and greater than seven percent for 24 SSE. In fact, a large number of cases had damping values

('

25 substantially higher, for example, OBE seven to 10 percent,

, Carmen Gooden, CSR, RPR, Metro 429-5532

~

79 1 and SSE 15 to 20 percent.

( 2 .We have a figure that He'd like to put up Which shows  !

3 one of the typical configurations that was tested. As Jim 4 mentioned, these Here tested using hanger configurations 5 typical of what's installed in the plant. They're full scale 6 systems. The spans betHeen hangers were generally nine feet.

7 We tested fittings, flat bends and vertical bends, and as you 8 see, this system Has also a multi-tiered system, meaning that 9 it had more than one level of tray.

10 MR. D0YLE: It's really rather difficult for me to 11 ask any questions on this until I have a chance to read this 12 over, so I have no questions right now.

13 MR. MUFFETT: We understand. The next one that He

{

14 believe you'll be interested in is Issue 31, and the reason 15 that it has that number is from the PSR.

16 MRS. ELLIS: The document that Jack Has Just l'7 referring to: Is that br chance that big stack of stuf f ?

18 MR. COUNSIL: I believe it is.

19 MR. ASHLEY: It is a reference to the PSR -- that 20 document -- there are two documents referenced there. One is 21 a report Hhich includes correlation studies, analysis and test

! 22 correlation studies. That is the report 017. The other )

23 report is the final report produced by ANCO Laboratories which

, 24 presents the raw results of the test data.

1 ( )

i 25 MR. MUFFETT: The next one is 31. Greg Ashley  !

l  !

Carmen Gooden, CSR, RPR, Metro 429-5532

y' 80 1 Hill also make the presentation on this one.

( 2 MR. ASHLEY: This external source issue was also a ,

3 CASE issue. Concerns were raised regarding anchorage boundar) 4 conditions, including the effects of oversized bolt holes and 5 the techniques used to represent anchorage behavior in 6 analytical models.

7 This issue has been resolved since the design 1

8 validation includes anchor bolt stiffness and base plate 9 flexibility in modeling boundary conditions of support i 10 anchorages. These have been determined in Volume I, Book 12, 11 and Calculation M-04, 12 The effect of bolt hole size on anchorage behavior is

{ 13 not explicitly considered in design validation. The cable 14 tray system dynamic tests have shown that dynamic response of  :

l j 15 a cable tray system is not sensitive to minor variations in 16 the anchorage.

17 This also has beVn presented i'n ANCO final summary 18 report for Comanche Peak Cable Tray Test, 19 MR. D0YLE: Here again, He have a statement, and 20 it's very difficult to ask a question about a statement that

21 doesn't have the parameters defining them.

I 1 22 MR. MUFFETT: Obviously. And one purpose of these is 23 to show you what He've done and point you to the report to '

I 24 look at rather than Just picking up the report cold. And I

('

25 believe Hhen you look at it, you'll see that this response Carmen Gooden, CSR, RPR, Metro 429-5532

l -

81 1 is -- in fact, sometimes with a slightly ' discrepant anchor

( 2 bolt the. response is less, but - .

3 MR. D0YLE: I know there can be a variation one Hay 4 or the other, 5 Additionally, in these reports will they state 6 whether or not the concern was valid or invalid --

7 MR. MUFFETT: Let me address that in a. broad picture  ;

8 on that specific one. In a number of these instancess we have 9 expended resources to determine the validity of an issue. In ,

10 many cases He have Just fixed it. In those cases those issues 11 became moot. They may have been valid, they may have not beer 12 valid. Where we have removed that and made that moot, He did

{ 13 not, as I said, expend any resources on that effort.

14 MR. D0YLE: I don't understand that answer, because 15 Why would you remove it?

16 MR MUFFETT: Because as you Hell know; it may cost a l'7 lot of money to do an anctysis -- -

l 18 MR. D0YLE: In other Hords, what you're saying this 19 is prudent, expediency, et cetera, et cetera, et cetera.

20 MR MUFFETT: As you Hell knoH, there is recourse to 21 a lot of analytical methods that we could have employed and 22 spent a lot of time and manhours. We Honted this plant to be 1

23 as conservatively built, conservatively designed, as He Could. l j 24 In those cases He didn't expend resources to make those 25 determinations. We Just, what I would say, fixed it, l

Carmer. Gooden, CSR, RPR, Metro 429-5532 l

i 82 1 MR. D0YLE: Also you don't go into an esoteric check

( 2 of the system and you also have simplicity and somebody in the 3 future backchecking what has been done.

4 MR. MUFFETT: Obviously. Five years from noH He 5 Houldn't Hant to pick up a history analysis of all the cable 6 trays and try to decipher that.

7 MR. D0YLE: Or claim they know Hhether the model was 8 left -- '

9 MR. MUFFETT: Exactly. In those cases He fix those.

10 And I think as He 90 through the issues, that will come 11 through.

12 MR. WARAPIUS: An example of that is the damping

( 13 issue which He Just presented, whereas the test results 14 demonstrate the damping two to three times higher than what is l

15 in our licensing commitment at Comanche Peak, He selected to i

1 16 stay with our licensing commitment at Comanche Peak.

I 17 MR. D0YLE
Damping is probab1'y one of the bigger 18 problems in finite analysis. No one really has a thorough 19 handle on precisely what it is, and even under an equivalent i 20 set of circumstances it can differ.

21 MR. MUFFETT: Damping is a very complex subject and 22 there's different types. There's a structural damping 23 related to the effects. We recognize that. That's one reason I 24 that He feel very good about Hhat we're doing because of the

('

25 tests, rather than getting into a very detailed theoretical i

Carmen Gooden, CSR, RPR, Metro 429-5532

1 ~

83 1 analysis. We have a good handle on it.

( 2 .MR. D0YLE: Same procedure but --

3 MR MUFFETT: Exactly.

4 COURT REPORTER: Mr. Doyle, could you move up to the 5 mike whan you're talking?

6 MR. MUFFET: The next one He'd like to talk about is 7 number one, and Kevin is going to present that..

8 MR. WARAPIUS: PSR Subappendix Al entitled 9 Controlling Load Case for Design.

10 The external source issue is that the original desigr 11 of cable tray hanger system may not have properly considered 12 both OBE and SSE load combinations by assuming that a

( 13 60-percent increase in SSE allowables was applicable to all 14 hanger components.

15 Project resolution of this issue is that cable tray ,

16 hangers have been design validated for the effects of OBE and l'7 SSE loads separately in accordance with Design Validation 18 Procedures PI-02, PI-03, PI-07, SAG.CP3, -4, -11 and -34.  ;

19 Appropriate OBE and SSE allowables were used for cable tray 20 hanger system components including structural steel, Helds, 21 anchorages, Richmond inserts and Hilti-KHik bolts.

22 Cable tray and cable tray clamps are design validated 23 in accordance with Design Validation Procedures PI-06,

(

(

24 SAG.CP18 and -19 by the comparison of the higher SSE loads 25 to the factored component ultimate strength. The factors Carmen Gooden, CSR, RPR, Metro 429-5532 t

]

84 1 which have been used are appropriate for both the OBE and SSE

( 2 level of earthquake.

3 I believe that these are all PSRs.

4 MR. D0YLE: I have no questions.

5 MR. MUFFETT: The next one He would like to present 6 is number 2, A2, and again, these numbers that I'm using are 7 from the PSR subappendix to help when you look at it. This has to do with seismic response combination method.

8 2

9 MR. ALEXANDRU: Subappendix A2 of the PSR. The issue 10 deals with seismic response combination method. This is an 11 external issue which identified the original design did not 12 properly combine seismic response in the evaluation of cable

( 13 tray hangers for the following conditions:

14 Closely spaced modes as required by Comanche Peak 15 FSAR and NRC Regulatory Guide 1.92.

16 The deadHeight load for the seismic loading using the l'7 square root sum of the squares method.'

18 Both issues are resolved by the Design Validation 19 Procedures PIO-2, SAG.CP3, CP4, CP11 and CP34, Hhich required 20 that the response spectra analyses combine responses 21 considering closely spaced modes in accordance Hith the 22 Comanche Peak FSAR and NRC Regulatory Guide 1.92.

23 Also, this validation procedure requires that the 24

(

dead load not be included within the SRSS of the seismic. loads

~

25 but added separately to the resultant seismic load.

l , Carmen Gooden, CSR, RPR, Metro 429-5532

~

85 l

1 MR. MUFFET: We have a slide that He're going to put '

( 2 up because describing mathematical equations is somewhat 3 confusing. So you can see the original and hoH it's performec 4 there.

5 MR. D0YLE: I have no questions with that.

6 MR. MUFFETT: With that, He'll move on to number 3, 7 which is an issue concerning anchorage bolt design.

8 MR. ASHLEY: This issue is related to anchor bolt 9 design. The issue was that incorrect assumptions and 10 inconsistent design criteria may have been used in the 11 original design of cable tray hanger anchorages.

12 Specifically, base angle / base plate geometry Has not

( 13 evaluated to determine appropriate anchorage stiffness, 14 eccentricities and prying action factors.

15 OBE was considered as the governing load case for 16 anchorage design Hithout sufficient Justification.'

17 Anchorage design-did not adequately consider as-built 18 conditions, i.e., anchor substitutions and installation 19 tolerances.

20  ; Anchorage designs may have used inappropriate anchar 21 bolt design allowables.

22 And lastly, there Has inconsistent use of the ACI 23 349-76 Appendix B design specification,

, 24 This issue has been resolved by the following:

25 The Design Validation Procedures listed on this slide Carmen Gooden, CSR, RPR, Metro 429-5532

86 i

1 require that cable tray anchorages be evaluated considering

( 2 anchorage stiffness, eccentricities, and the additional anchor 3 bolt tension resulting from prying.

4 The anchorage stiffness and prying action factors 5 which are incorporated in the procedures were developed in 6 engineering studies M-04, M-25, Volume I, Books 3, 11 and 12, 7 which considered as-built base angle / base plate geometries.

8 Design Validation Procedures SAG.CP3, -4, -34 and 9 PI-02 require the evalatulon of cable tray anchorages for the 10 effects of OBE and SSE load separately. ,

1 11 Design Validation Procedures SAG.CP3, -4 and PI-07 12 contain the OBE cnd SSE design allowables used for design

( 13 validation of anchor bolts, both Hilti expansion anchors and 14 Richmond inserts.

15 Design Validation Procedures SAG.CP 3, -4, -34, PI-02 16 and PI-07 require the use of as-built data for the design l

17 validation of cable tray hanger anchor' ages.

18 The Design Validation Procedures listed here require I 19 the use of anchor bolt design allowables as provided in the 20 concrete embedment Design Specification 2323-SS-30. The  ;

21 requirements for the design of concrete anchor bolts are basec 22 on capacities determined from tests and. utilize appropriate  !

23 factors of safety. These allowables are being validated in j 24 the civil / structural Corrective Action Program.

1 1 25 MR. D0YLE: I have one question. In the analysis of  ;

i i  !'

i Carmen Gooden, CSR, RPR, Metro 429-5532-

4 1 -

87 1 the anchor bolts, did they treat them Hith the independent

( 2 cones, or did they also look into the shear plane problem?

3 MR MUFFETT: The separation problem Where the cones 4 overlap.

5 MR. D0YLE: Yes.

6 MR MUFFETT: Yes, He are evaluating for that.

7 Where they do overlap, He're evaluating for that.

8 MR. NACE: I'd like to interject a thought, Jack.

9 Back to the last remarks I made prior to breaking for lunch.

10 I hope that here you begin to see the integration of design 11 activities. The civil / structural discipline which Has talked 12 about this morning, of course, is involved also in

( 13 reconciliation of these loads.

14 And tHD different Contractors sitting here at the 15 table are using the same design base input / output information.

16 MR MUFFETT: And one more unifying effect to this is 17 that the specification that He mentioned here, SS-30, 18 2323-SS-30 Hill be developed by Stone & Webster civil /

19 structural action plan, and everyone else Hill use that.

20 There Hill be no independent anchor bolt design criteria 21 employed by different contractors.

22 MR. D0YLE: Very good. .

1 23 MR. MUFFETT: "Has been," not "Hill be". '

l i j ,

24 MR ASHLEY: In addition to that, the Design Basis  !

! \_ i 25 Document provides the requirements that you Just spoke of, the - '

i Carmen Gooden, CSR, RPR, Metro 429-5532

i \

88 1 requirement for spacing and what the engineer does if those

([ 2 spacing. requirements have been violated.

3 The next part of this package He Just provided a 4 figure showing you, in case you Heren't familiar, the typical 3

5 anchorages that are used for the cable tray hangers; the base 6 angle, the expansion anchor plates and the embedded plates.

7 MR. D0YLE: No questions.

8 MR. MUFFETT: The next one Greg is also going to 9 give, which is A4, and it has to do Hith the design of 10 compression members, i

11 MR. ASHLEY: This issue is related to the design of 12 compression members. It has several parts. The first port:

( 13 The original design calculation used improper member lengths 14 and end conditions for determining the slenderness ratio of 15 channel section compression members in trapeze-type hangers.

16 This issue has been resolved. The Design Validation 17 Procedures SAG.CP9, -34,*PI-03 and PI-11 provide the 18 requirements for the appropriate unsupported lengths of cable 19 tray hanger members to be used to calculate ccmpression member 20 slenderness ratios, KL over R.

21 Engineering studies have been performed to es',ablish 22 effective length factors for the installed cable tray hanger 23 designs.

24 These studies are documented in Volume I Book 6, t'

25 Report 01-0210-1470 and Calculation B-04.

, Carmen Gooden, CSR, RPR. Metro 429-5532

i ~

83 '

1 Effective length factors have been used with b 2 appropriate unsupported member lengths to calculate 3 slenderness ratios of compression members.

4 The next couple of slides He Just wanted to provide I 5 you pictorially several of the critical parameters whi.ch Here 6 included in the development of those effective length factors.

7 The next slide shows the vertical load. distribution, 8 meaning you have multi-tiered hengers where you have a tray or 9 each of the tiers, multi-level. That distribution of load HaS 10 important in developing those effective length factors, I 11 The next partmeter, rotational stiffness. As He <

12 talked about with regard to issue 3, He vigorously developed i

13 rotational stiffnesses for the typical base members, base

{

14 anchorages. Those stiffnesses were important in developing 15 its effective length factor.

16 The next slide shows you longitudinal restraints.

l'7 That longitudinal restraint provided through the connection of 18 frictional-type connection of the hanger to the tray, j 19 The next slide shoHs you the distribution of stress 20 due to transverse loads, once again, in effect which results i

21 from the multi-tier hangers.

22 The next part of this issue - ,

23 MR D0YLE: I'm taking for granted that the moments i

24 were included with the axials.

Yes.

25 MR. ASHLEY: These were rigorous analyses; I

i 2

Carmen Gooden, CSR, RPR, Metro 429-5532

I 90 1

l 1 three-dimensional analyses considering forces and' moment. '

i

( 2 MR. MUFFETT: I guess, Jack, the point He're trying ,

3 to make, as you Hell know, the KL over R equation, the R 4 everybody knows what that is, and the L everybody knows What l 5 that is. It's determining what the right K is. That's what f 6 a lot of these studies pointed to.

7 MR. D0YLE: I just noticed that they had a i

8 compression diagram here. I took it for granted that --

9 MR. MUFFETT: Yes, and He have some issues like that 10 Which He'll get to farther along.

~

11 MR ASHLEY: Essentially, maybe to clarify that a i 12 little bit, the input here Has a transverse over a vertical l 13 displacement. This was done using large displacement, meaning

{ )

1 14 considering the P Delta effect in these frames, resulting in l 15 that input displacement were both looked closely at the moment 16 in the hanger members.

I 17 MR. D0YLE: No =a I assumed that.

18 MR. ASHLEY
The next part of this issue is the l 1

i 19 original design ca^,culations for determining the slenderness 20 ratio of compression members in trapeze hangers did not verify  ;

21 the effectiveness of in-plane sidesHay restraint for various J

J 22 designs.

1 23 This issue is resolved by Engineering Studies, Volume '

! 24 I, Book 6, in Report 01-0210-1470 and Calculation B-04, which 4

(

25 have been performed to develop the effective length factors j ,

Carmen Gooden, CSR, RPR, Metro 429-5532

l -

g1 I

l 1 for the installed cable tray hangers. These studies include  !

( 2 consider.ation of sidesHay restraint for both transverse and 3 longitudinal trapeze-type hangers. These effective length j 4 factors are used in cable tray hanger validation in accordance  ;

5 Hith Validation Procedures SAG.CP9, -34 and PI-03 and PI-11 6 The next part. In the original design calculation I

7 for cantilever hangers used a distance from the, concrete face  ;

8 to the tray centerline for cantilever length instead of the 9 distance to the outside clamp.

l 10 Additionally, original design calculations for 11 determining the slenderness ratio of members in' cont 11ever l

12 hangers assumed the cable tray provided lateral bracing at the l

13 tray clamp location without proper Justification.

{

14 The issue has been resolved by Design Validation 15 Procedures SAG.CP9, CP34, PI-03 and PI-11 Which provide 16 requirements for the appropriate unsupported length of  ;

l'7 cantilever hanger memberr'to be used to calculate compression i

18 member slenderness ratios. l l

19 Engineering studies have demonstrated that cable '

20 trays provide sufficient lateral bracit ; and developed 21 effective length factors for installed cable tray cantilever l 22 hanger designs. These effective length. factors are used in 23 cable tray hanger validation in accordance with Design 24 Validation Procedures. And those effective length factors k 25 were developed in the same studies that I mentioned earlier.

l Carmen Gooden, CSR, RPR, Metro 429-5532

i 92' 4 1 The next slide Hill show you a schematic of what the

(. 2 issue Hos talking about in terms'of the loadine point to the

! 3 tray centerline, rather than the point of application of the 4 axial loads, 5 MR. MUFFETT: To be conservative we move it out to '

6 the outside of the connections; makes it a little longer and 7 the calculation slightly more conservative.

8 MR. D0YLE: No questions.

9 MR. ASHLEY: The next part of this issue: Original 10 design calculations did not consider reduction of section 11 propertiPs due to Held undercut at in-plane brace attachment i 12 points.

( 13 Also, installation specifications allow a tolerance -

14 on plumbness of vertical members. The original design did not 15 consider the effect of out-of-plumbness on compressive 16 allowables.

17 This issue has buen resolved s'ince the cable tray

?.8 hangers have been inspected as specified in NQA-3,09-10.01. Ar 19 engineering study contained in Volume I, Book 20, the base 20 metal defects identified by these QC inspections has been 21 performed and concluded that the effects of Held undercut on 22 cable tray hanger capacity are not significant and need not be 23 explicitly considered, 24 Tests and studies which are contained in Volume.I,

(~

25 Book 16, and Report 09-0210-0017 demonstrate that the tHO 6

Carmen Gooden, CSR, RPR, Me'.ro ',29-5532

i -

93 1 degree out-of-plumbness tolerance for cable tray hangers has

( 2 no effec.t on design adequacy.

3 Out-of-plumbness greater than two degrees is noted or 4 as-built hanger drawings as required by walkdown procedures 5 CPE-FVM-CS-001, TE-FVM-CS-003 and TE-FVM-CS-036 and is >

6 considered in design validation as required by the Design  ;

7 Validation Procedures SAG.CP34 and PI-02.  !

8 Additionally, I might mention on the out-of-plumbness 9 I believe that Jim mentioned that we tested configurations 10 that had very long slender members. I believe the -

11 slenderness ratios were anywhere from 360.  !

12 Additionally, He built out-of-straightness and 13 out-of-plumbness to those hangers. They were the input motior l

{

14 of the SSE events, and those hangers demonstrated no loss of 15 function or gross defamation. +

16 MR. D0YLE: I would agree with that. In the first 17 place you're only talkinQ~tHo degrees out-of-plumbness, about  :

18 three percent.

19 MR. ASHLEY: In fact, the one He installed was even I 20 greater than two degrees. It looked like a crooked dog's l

21 leg; about four degrees out-of-straightness. l 22 MR D0YLE: But, again, coming.back to the previous l 23 one. In the slide you mentioned that this was conservative.

24 It was actually compounded conservative because it's also

( ~

25 going to (Inaudible).

Carmen Gooden, CSR, RPR, Metro 429-5532

1 94 1 MR. MdFFETT: Yes. And I'm sure when you have time

( 2 to look.at all this, you'll see that there are many compoundec 3 conservatisms here.

4 MR. ASHLEY: The next part to this issue: In the 5 original working point deviation study, a reduced unsupported 6 length for trapeze hangers was used based on an invalid 7 assumption of regidity of the base angle leg relative to the 8 hanger.

9 The original design calculations for braces in 10 compression considered the highest load as a function of brace 11 slope, and checked for this slope Hithout considering cases 12 with lower loads where capacity is reduced due to longer

( 13 member lengths.

14 This issue has been resolved since in design 15 validation the appropriate length including the outstanding 16 base angle leg Has used as required in SAG.CP34; PI-02 and 17 PI-03. ~" "

18 The effective length factor is documented in Volume 19 I, Book 6, and Report 01-0210-1470 and Calculation B-04 20 consider the effects of anchorage flexibility. We're back to 21 that slide that I showed you.

22 Additionally, design validation is not based on the 23 original design calculation. The design validation of 24 bracing members has been performed using as-built information k

25 in accordance with Design Validation Procedures SAG.CPil, -34, Carmen Gooden, CSR, RPR, Metro 429-5532

95 1 PI-02 and PI-03.

( 2 ,MR. D0YLE: No questions.

3 MR. MUFFETT: The next one we'd like to give is issue 4 number five, which has to do with veritical transverse loadins 5 on longitudinal type supports. Pat Harrison is going to 6 present this one.

7 MR. HARRISON: Issue number five, vertical and 8 transverse loading on longitudinal type supports.

9 The original issue Has the original design for 10 longitudinal trapeze type cable tray hangers did not include 11 the vertical and transverse seismic cable tray loads.

12 The issue resolution is as folloHs: Design 13 Validation Procedures SAG.CP11, SAG CP34 and PI-02 require the

{

14 siraultaneous application of seismically ind.ced loads in three 15 orthogonal directions on all cable tray hangers.

16 The figure that folloHs Just indicates what the three 17 directions are in relationship to the cable tray hangers.

18 MR. D0YLE: could I ask a question about this figure 19 A57 The lower present design has a white line coming into 20 the web of a channel. Is the effect of the stiffness at that 21 Joint considered in the analysis?

22 MR ALEXANDRU: Yes, it is considered in the 23 analysis. Yes, it is.

24 MR. D0YLE: That's almost simple.

(' 5 25 MR. ALEXANDRU: Well, He have -- in our calculation Carmen Gooden, CSR, RPR, Metro 429-5532

I 96-1 He do frame unalysis which automatically considers the'effect

( 2 of that Joint and moment distribution. Mostly you have to 3 understand that all the analyses are three dimensional 4 cnolyses which takes into account the rigidities in all these 5 directions.

6 MR. MUFFETT: Which is -- I'm sure you're aware on a 7 lot of dockets they have not analyzed these structures that 8 Hay. This is an increase in the technology and an increase ir 9 conservatism.

10 MR. D0YLE: I agree with that. I was Just asking the 11 question to see if it had been done here.

12 MR. MUFFETT: The next one He'd like to present is 13 number six and it has to do with support frame dead and

(

14 inertial loads. Pat Harrison is also going to present this 15 one.

16 MR. HARRISON: Issue number 6, support-frame dead anc 17 inertial loads. The oricTnal design di'd not consider the 18 out-of-plane inertial loads -- this is the load that is 19 parallel to the cable tray -- on the transverse type cable 20 tray hangers. This issue was also that the out-of-plane loads 21 transmitted from the transverse type cable tray hangers 22 through the cable trays were not considered in the member and 23 anchorage design for longitudinal cable tray hangers.

24 The second issue was the original design did not t,

25 properly consider the contribution of the Height of the cable Carmen Gooden, CSR, RPR, Metro 429-5532

~

37 1 tray members. -

([ 2 The resolution to the issue is as follows:

3 Out-of-plane inertial loads due to cable tray hanger dead 4 Height has been considered in design validation of all cable 5 tray hangers as specified in Design Validation Procedures 6 SAG.CP3, SAG.CP4, -11, -34 and PI-02.

7 Further discussions are contained under Issue 18 ,

8 regarding the distribution of load between hangers.

9 The second part of the issue: The entire cable tray 10 hanger dead Height has been explicitly and consistently 11 considered in design validation as specified in Design 32 ' Validation Procedures SAG.CP3, -4, -11, -34 and PI-02.

13 MR. D0YLE: No question.

{ ,

14 MR. NACE: Since Mrs. Ellis is standing up to take a 15 rest, He'd like to take a rest now, too. Let's resume at i 16 2:20.

17 (A break Has taken.P .

l 18 MR. NACE: The meeting will come back to order. I

)

19 would like to set the record straight on something that was  !

20 said during the last session. We said you have the Design 21 Validation Procedures. We also have trouble keeping track of 22 who has our paper. What He meant to say is those Design 23 Validation Procedures have been sent to the reading room which 24 was provided Hith notification of the availability of the PSR.

k' 25 So I do not believe He had transmitted those to you cli*ectly,Ii I

Carmen Gooden, CSR, RPR, Metro 429-5532

i 98 1 We Hill provide you three copies.

( 2 MRS. ELLIS: Thank you.

3 MR MUFFETT: Before He get started with the next 4 issue, I managed to acquire the detail that you asked about 5 before where on the tape they said it was tHo times the SSE.

6 MR. EVANS: It's twice the peak from where they 7 mentioned two times. And if you look at the ZPA sometimes 1

8 it's four, four and a half times the ZPA, but He took the ,

9 smaller. So it's a very healthy increase.

10 MR. D0YLE: What was the point? I couldn't determine  ;

11 from the tape? What was the duration of input pulses that 12 those tests run?  ;

{ 13 MR. ASHLEY: The Hay each test sequence is put 14 together Has taking three earthquakes in series, three 10- to l 15 11-second earthquakes in series. That's why you noted a 16 slight pause and then it started to shake again. Each test 17 sequence for the seismic-test had those three earthquakes in +

18 series for a total of roughly 35 seconds of earthquake of i 19 input motion. Many of those tests -- for example, one case  ;

20 saw over an hour of total earthquake input during the Whole 21 series of tests in varying field levels, in installing the 22 construction deviations as Jim talked about, and running .

23 fragility level tests, those tests where the input motion was ,

24 amplified the two times.

25 MR. D0YLE: The total run Has all cumulative. There Carmen Gooden, CSR, RPR, Metro 429-5532

i -

99 1 Here no modifications or corrections.

( 2 MR. ASHLEY: The only modification was to install 3 those deviations. There Has no correction of the system in 4 terms of a repair or modification.

5 MR. D0YLE: Thank you.

6 MR. MUFFETT: Moving along, the next issue He have is 7 Issue 7, which has to do Hith design of angle braces, and Rene 8 Alexandru is going to present that issue.

}

9 MR. ALEXANDRU: Subappendix A7 deals with the design 10 of angle braces neglecting loading eccentricity.

11 These external source issues are in the original 12 design the induced bending stresses in double angle braces due l

{ 13 to eccentric end connections Here not considered, and double 14 angle braces without filler plates were incorrectly considerec 15 as composite members.

16 The cecond part of the issue is in the original 17 design the induced bending stresses in the single angle braces 18 due to eccentric end conditions were not considered, and 19 design calculations did not evaluate the stress considering 20 the principal axes section moduli.

21 These issues are resolved procedurally because the 22 Design Validation Procedures SAG.CP34 cod PI-03 and 23 Engineering Study M-12 considee eccentric member end 6

24 connections on all hanger members. Design Validation

(

25 Procedures SAG.CP34 and PI-02 allow double angle braces to be Carmen Gooden, CSR, RPR, Metro 429-5532

i 100 1 analyzed as composite members only if the requirements of AISC

( 2 Specification Section 1.18.2.4 regarding intermittent' filler 3 plates are satisfied.

4 In addition to the resolution discussed in item A 5 above, the Design Validation Procedures require that the 6 principal axes flexural stresses be accounted for in checking 7 member stresses.

8 We have a slide showing the intermittent filler plate 9 relative to the issue discussed.

10 Another part of the issue is in the original design 11 the potential for twist buckling was not evaluated for single 12 angle braces where members attach to opposite lengths at each

{ 13 end.

14 The resolution of this issue is achieved because the 15 Design Validation Procedures SAG.CP34 and PI-02 and 16 Engineering Study M-12 require the evaluation of the potential 17 for flexural buckling, torsional buckli'ng and combined 18 torsional-flexural buckling resulting from eccentrically 19 applied axial loads. These requirements include the 20 consideration of the design condition described in the 21 original design.

22 We have a slide showing how the Held is on the 23 opposite side of the angle.

24 MR. D0YLE: This is not necessarily related to this

('

25 - particular point; however, there was a concern, I believe, of-Carmen Gooden, CSR, RPR, Metro 429-5532

  • ~

101 1 CYGNA's and that is for the Held that you show up there at the I 2 gusset plate at the top, the rate of action is eccentric to 3 the Held group. Is that considered in the design?

4 MR. ALEXANDRU: That's part of the -- that's similar 5 to this issue. Yes, it was considered in the design. It's 6 also covered in the extensive verification of loads on 7 eccentricity of loads on the Held connection.

8 MR. D0YLE: And also I Hould assume that is true for 9 the pipe support group.

10 MR. KLAUSE: Yes, that's true.

11 MR D0YLE: No other questions.

12 MR. MUFFETT: Moving along to Issue 8, Which is going

( 13 to be presented by Rene, concerns dynamic amplification 14 factors.

15 MR. PLEXANDRU: This external source issue deals witt 16 the finding that the original cable tray hanger design which 17 used the equivalent static method, the"seismic load was not 18 increased to account for a dynamic amplification factor, nor l

19 were the additional system effects considered.

20 The issue is resolved by the Design Validation I

21 Procedures SAG.CP3, CP4, CP28 and CP34 Hould require the use 22 of at least 1.25 multimode response multiplier, MRM, When the 23 equivalent static method is used, to account for dynamic 24 amplification effects and continuous system load distribution

( '

25 effects. These Design Validation Procedures assure the proper 1

Carmen Gooden, CSR, RPR, Metro 429-5532

~ '

102 1 use of this multiplier in conjunction with' spectral

( 2 accelerations, tributary cable tray span and hanger dead 3 Height. The validity of this multiplier has been 4 substantiated by engineering studies documented in Volume I, 5 Book 9, 10, 15 and 23.

6 The Design Validation Procedures' SAG.CP28 and -34 7 Here developed to properly analyze the cable tray system 8 configurations for which the engineering studies have shoHn 9 that the 1.25 MRM is not sufficient to account for the load 10 distribution effects in addition to the multimode effects.

11 Another part of this issue deals with the original 12 design which did not include the effects of the missing mass

{ 13 but a higher frequency response.  !

14 The issue is resolved because the Design Validation 15 Procedures CP3, CP4, CP11 and PI-02 require a missing mass l

16 correction for response spectra analysis to be performed for' l l

17 cable tray hanger design validation."'-

18 MR D0YLE: I couldn't ask any auestions on that 19 right now, so --

20 MR. MUFFETT: The next one we'd like to present is 21 Issue 9, which has to do Hith reduction in channel section 22 properties due to clamp bolt holes, and.Rene Hill present this 23 one.

24 MR. ALEXANDRU: This issue says that the original i

25 design for channels did not properly consider the reduction ir Carmen Gooden, CSR, RPR, Metro 429-5532

. ~

103 1 moment of inertia due to bolt holes, as required by AISC

( 2 specification.

3 This issue resolution is achieved because the reducec 4 member section properties resulting from bolt holes were 5 developed per Engineering Studies, Volume I, Book 25, and M-65 6 in accordance with the AISC specification. The size of the 7 bolt holes considered Has three quarters of an inch, based on 8 a statistical evaluation of the as-built cable tray hangers.

9 The Design Validation Procedures CP34 and PI-11 10 require the use of these reduced properties in the design 11 validction of cable tray hanger tiers to account for the 12 presence of both used and unused bolt holes.

( 13 MR. D0YLE: No questions on that.

14 MR. MUFFETT: The next issue we'd like to present is 15 Issue 10. This has to do with the system concept, and Greg 16 Ashley will present this issue 17 MR. ASHLEY: The system concept', which was used to 18 Justify the original design, assumed the moments resulting 19 from the beam to hanger connection eccentricities in the cable 20 tray and the cable trcy hanger were balanced by load couples 7

21 between adjacent cable tray hangers. This behavior requires 22 compatibility between trays and hangers.via the tray clamps.

23 Sufficient Justification for this assumption was not provided.

24 This issue has been resolved since compatibility

's' 25 betHeen trays and hangers has been used in design validation.

Carmen Gooden, CSR, RPR, Metro 429-5532

( .

104 1 The study used to Justify the original design was not used in

( 2 design validation. The design validation of cable tray 3 hangers Has performed Considering the load eccentricities

4. specified in Design Validation Documents SAG.CP3, -4, -9, 5 -11, -34 and PI-02, PI-07. Engineering Studies Volume I, 6 Books 2 and 7, M-12, and Report 09-0210-0017 Justify the 7 modeling techniques contained in these procedures. The 8 behavior of cable tray clamps is discussed in PSR Subappendix 9 A18 which He Hill talk about later.

10 MR. D0YLE: No questions.

11 MR. ASHLEY: The second part to this issue was the 12 system concept used to Justify the original design assumed

{ 13 cable trays provided lateral bracing for the cable tray 14 hangers without Justification.

15 The resolution is Justification has been provided 16 with the assumption that cable trays provide lateral bracing 17 in the cable tray hangers.- Detailed engineering studies 18 developed effective length factors and established the 19 effectiveness of bracing provided by the cable trays to the 20 cable tray hangers. As He talked Gbout under Issue 4, these 21 studies are documented in 01-0210-1470, 09-0210-0017 and 22 Volume I, Book 6. ..

23 Design Validation Procedures SAG.CP34 and PI-03 24 incorporated the results of the engineering studies. The

('~

25 effectiveness'of bracing provided by cable trays was also Carmen Gooden, CSR, RPR, Metro 429-5532

105 1 demonstrated in a full scale dynamic test program.

(' 2 MR. D0YLE: Let me see if I understand this.

3 SomeHhere in the system is a brace?

4 MR. MUFFETT: Absolutely.

5 MR. D0YLE: What you're saying is, the cable tray 6 transferred the axial load until it gets to that brace.

7 MR. MUFFETT: Right.

8 MR. D0YLE: The same as a platform in a regular 9 structure Hith a horizontal brace at the opposite end.

10 MR. MUFFETT: Exactly.

11 MR. D0YLE: Okay.

12 MR. MUFFETT: And as He mentioned before, because 13 it's statically indeterminate, some of those hangers that

{ l 14 Hould have originally been installed there only for Heights, 15 He analyze them for those minor axial loads that they could 16 see, even though the main one really carries the vast majority 17 of the load.

18 MR. ASHLEY: Maybe to clarify a littie bit, one large 19 major difference betHeen the Hork being performed under the 20 CAP and the original program is that He're treating these 21 things as complete systems.

22 MR. D0YLE: No, I concur. My problem is I Hasn't 23 involved too much Hith cable trays so I have to visualize what 24 the problem is myself. Then I listen to what you say and ther

(

~

25 I have to determine does that fit With Hhat I knoH Hithout' Carmen Gooden, CSR, RPR, Metro 429-5532

106 1 knowing too much about the cable trays, if that makes sense.

( 2 MR. MUFFETT: If He can draw a picture or have 3 recourse to the blackboard, don't hesitate to ask.

4 The next one He'd like to --

5 MR. ASHLEY: Excuse me. The next part of this issue 6 Has in the original design of longitudinal trapeze-type cable 7 tray hangers, transverse and vertical loads Here not 8 considered.

9 This issue has been resolved since all cable tray 10 hangers were design validated considering the simultaneous 11 application of all seismically induced loads, i.e., three 12 orthogonal directions, on each hanger as described in Design

( 13 Validation Procedures SAG.CP3, -4, -9, -11, -34 and PI-02.

14 MR. D0YLE: No questions, j 15 MR. ASHLEY: The next part of this issue is in the l 16 original design additional tensile forces and anchor bolts due i l

17 to the rotation of base"angles about-the' bolt pattern axis 18 Here assumed to be mini.7.1 zed by the attached cable tray.

19 This issue has been resolved since the effectiveness l 20 of bracing orovided by cable trays Has demonstrated in a full 21 scale dynamic test program. Detailed Engineering Studies, 22 Volume I, Book 3 and M-25, developed prying action factors by 23 conservatively not accounting for tray resistance.

24 Modeling procedures to effectively account for I

25 anchorasge eccentricities and additional tensile forces caused I

Carmen Gooden, CSR, RDR, Metro 429-5532 i

107 1 by anchorage rotation have been incorporated into the Design

( 2 Validation Procedures SAG.CP34 and PI-07.

3 MR. MUFFETT: Let me clarify that. There's a lot of 4 Jargon throHn in. I'm going to paraphrase it. What we found 5 in the test is that the cable tray hangers really don't 6 grossly rotate and have this prying action effect.

1 7 Nevertheless, He analyze the anchor connections as if they dic 8 to be conservative.

9 MR. D0YLE: I don't ouite understand the 10 configuration He're talking of.

11 MR. MUFFETT: This is a trapeze-type support.

12 MR. ASHLEY: We could 90 to the board on this.

( 13 MR. D0YLE: Yes.

14 MR. ASHLEY: Looking at the trapeze-type support the 1 l

15 base angle attaches to the concrete. There's then a post i

16 Helded to this base angle. At some point there are tiers Hitt l

17 the tray sitting on these tiers. In'the* original design it 18 Has assumed that there would be no prying -- by prying He mear 8

19 rotation of this and prying of bearing points on the concrete, 20 that momer.t resulting in additional tensile force in the 21 bolts. The original design assumed that because the tray 22 provided restraints, there would be no Totation resulting in 23 additional tensile loads.

24 For our design He have assumed these to be systems,

(

25 meaning that the tray does provide some restraints. However, Carmen Gooden, CSR, RPR, Metro 429-55?2

i 108 1 He've evaluated these base angles separately to develop pryins

( 2 action factors, meaning if I Here to apply rotation, it'd 3 result in some increase due to prying.

u We then amplified the tensile force produced in that 5 anchor by that prying action factor.

6 MR. D0YLE: But you have taken into account the fact 7 that you do have prying in the anchor as a result of the 8 angle.

9 MR ASHLEY: That's correct. That is correct.

10 MR. D0YLE: I thought somehow it Just wasn't being 11 included.

12 MR. MUFFETT: It is being included, and I think

( 13 that's why the slide Has a little bit confusing. What He 14 found out, there is not a lot of rotation up there When He dic  !

15 those tests. But nevertheless, He still account for this 16 effect in the design.

17 MR. D0YLE: But He could still"have -- n>ide f rom i

18 rotation, without considering rotation at all, the mere fact  !

l 19 that you are transferring the load from the vertical over inte l 20 the angle of the flexibility of the --

21 MR. MUFFETT: Exactly.

22 MR D0YLE: Okay. That has been taken care of.

)

23 MR. MUFFETT: That's taken care of.

24 MR D0YLE: I Just misunderstood what I was --

(

25 MRS. ELLIS: You',e going to love this one.

l Carmen Gooden, CSR, RPR, Metro 429-5532

j -

109 1 MR. NACE: You Hent a copy of that.

( 2 MRS. ELLIS: Well, I know in the hearings whenever He 3 had anything like that, the Judge would usually ask that 4 somebody draw it and it be attached to the record. But it 5 should be somebody definitely besides me.

6 MR. MUFFETT: In the interest of completeness, He 7 have people Hith skill in drawing out there and they Hill make 8 this and give it to Carmen.

4 9 MRS. ELLIS: That Hould be much better. I think that l 10 Hould be better than if I did it, believe me. For the record, 1

11 it's always helpful.

12 MR. NACE: Draw a copy of that exactly as it is on I l

( 13 the blackboard and insert it at this point in the record.

14 MR. D0YLE: We probably ought to give it a number in 15 case there is a second or third one.

16 MR. NACE: At the risk of confusing the numbering 17 system that exists here, ~could you suggest a number? A10-5A? )

18 MR. MUFFETT: I would call it -- 10-4A Hould be good.

19 MR. ASHLEY: The next part to this issue Has in the l 20 original design longitudinal cable tray hanger design did not 21 consider out-of-plane seismic inertial loads for trapeze-type 22 cable tray hangers.

23 Once again, the resolution to this is that all cable 24 tray hangers have been design validated considering the 25 simultaneous application of all seismically induced loads, Carmen Gooden, CSR, RPR, Metro 429-5532

j 110 1 three orthogonal directions, of each hanger as described in

( 2 the design -- all the ceismically induced loads are combined 3 on each hanger as described in the Design Validation 4 Procedures SAG.CP3, -4, -9, -11, -34 and PI-02.

5 MR. D0VLE: No questions.

6 MR. ASHLEY: The next part to this issue is the 7 original cable tray hanger design did not adequately address 8 additional moments introduced by the eccentricity between the 9 neutral axes of cable tray hanger tier members and post 10 members Joined in lap Joint connections.

11 This issue has been resolved since cable tray hanger 12 design validation was performed considering hanger Joint

{ 13 eccentricities specified in the Design Validation Procedures 14 SAG.CP3, -4, -9, -11, -34 and PI-02 and PI-07. The 15 eccentricity betHeen the neutral axes of cable tray tier 16 members and post members is one of the eccentricities 17 considered. Engineering ~ Studies, Volume I, Book 2 and 7, 18 Report 09-0210-017 and Calculation M-12 Justify the modeling 19 techniques in the Design Validation Procedures, which are 20 CP9, -11, -34 and PI-02.

l 21 MR. D0YLE: This brings up another point. Again, 22 it's an unrelated point because it's Helding. But there's an 23 AWS provision where you have opposite, opposing faces of a 24 common plane where you don't make an all-around Held. At 25 CPSES they did have some of these when I was out there and I Carmen Gooden, CSR, RPR, Metro 429-5532

i -

111 1 Has Just Hondering, is there a provision noH Hhereby that is

( 2 precluded from occurring?

3 Do you know what I'm referring to?

4 MR. ASHLEY: Maybe you could draw it.

5 (Mr. Doyle draws example.)

6 MR NACE: Do He have a copy of that last one drawn?

7 Does the reporter have it?

8 UNIDENTIFIED SPEAKER: We're getting it. We're going 9 to shove it right into the bundle right now.

10 MR. D0YLE: Where you have a pair of channels, for 11 example, if you take the code alloHed to the Held like this, 12 but you can't connect opposing faces of a common plane.

( 13 MR. ASHLEY: Are you referring to Helds on the back 14 side as well as Helds top and bottom? l 15 MR. D0YLE: Right. .

l 16 MR. ASHLEY: What is the cuestion?

17 MR. D0YLE: In current procedures do you allow 18 all-around Helding or do you follow the AWS? Not connecting 19 points; the point where you transfer around the corner.

20 MR. NACE: Do you recall or do you --

21 MR. MUFFETT: We didn't -- He'll have to get someone 22 to answer that question for you. We obviously Just brought 23 that up. We Hill get an answer for you.

9 24 MR. D0YLE: I got that out of place even. .B u t aa s l

( '-

25 soon as you mentioned the eccentricity it came to mind. This Carmen Gooden, CSR, RPR, Metro 429-5532

112 1 is an eccentricity situation, but it was a weld that I was

( 2 concerned with. It has almost no effect on the property' of 3 the Held itself, but it could have a side effect on the 4 physical property of the member.

5 MRS. ELLIS: What number are we going to give that .

6 one?  :

7 MR. NACE: That will be A10-5A; is that right?

8 A10-7. '

9 MR. MUFFETT: Any more questions, Jack?

10 MR. D0YLE: If somebody has an AWS handy, I can show 11 you the section and save us worlds of time.

12 MR. MUFFETT: I usually carry one with me, but I

{ 13 didn't bring it today.

14 UNIDENTIFIED SPEAKER: We have that right behind the 15 blackboard.

16 MR. MUFFETT: All right. We'll find one, I think on 17 the break, and you can shUH us. "

18 MR. D0YLE: No other questions.

19 MR. MUFFETT: The next issue He have is Issue 11, k 20 which has to do with the validity of NASTRAN models -- .

21 (DraHing 9.15.2 included as a part of this 22 transcript at this point.)

23 MR. NACE: We'll get back to you on that question 24 probably at the next meeting.

( i 25 MR. MUFFETT: The next issue He haVe is Issue 11. It Carmen Gooden, CSR, RPR, Metro 429-5532

~

113 1 has to do with the validity of the NASTRAN models, and

( 2 NASTRAN,.for those of you who are not familiar Hith it, is a 3 computer program, finite element computer program.

4 The issue was that some NASTRAN models used in 5 support of the original design may not have included 6 sufficient variations in hanger type and tray span to 7 represent the as-built conditions.

8 The issue resolution is that those models, those 9 NASTRAN models, are not used in the cable tray and cable tray 10 hanger design validation.

11 And touching back on something you mentioned before, 12 Jack, was the issue valid or not? This would be a classic

( 13 example. We didn't go back and do anything with those models.

14 Obviously there were questions about them. We Just as-built 15 the hangers, analyzed them properly. They have been valid, 16 they have not been valid. That was what I was trying to say 17 originally.

18 MR. D0YLE: I can relate to that in.this particular 19 case. It Hould be an aHesome task.

20 MR. MUFFETT: Any questions?

21 MR. D0YLE: No questions. 1 22 MR. MUFFETT: The next issue was Issue 12 concerning 23 working point deviation study. The issue was that the working 24 point deviation study which was intended to provide allowable

.~

25 tolerances on the working point locations for the original

{

Carmen Gooden, CSR, RPR, Metro 429-5532 l

i 114 1 cable tray hanger designs -- and you see parenthetically "to

( 2 account.for eccentricities which were not considered in the 3 original design,~ close parenthesis -- may not have included 4 sufficient variation to represent the as-built conditions.

5 Additionally, sufficient Justification was not provided in the 6 study for modeling assumptions such as tray and hanger 7 boundary conditions and connectivity, or for selection of 8 particular hanger configurations or components to develop the 9 general working point location tolerances.

10 The results of this working point deviation study are 11 not used in the design validation of cable tray hangers. The 12 cable trays have all been design validated based on as-built '

So this type of a grouping or a s'tudy about

( 13 information.

14 saying that construction tolerances on working points doesn't 15 apply to our design validation. It is only interested in 16 historical contents. And this is for the cable tray hangers.

17 The next issue was Issue 13, Which concerns reduced 18 spectral accelerations. The issue was that reduced seismic 19 accelerations were used in the original design basis using the 20 original design based on calculated frequencies of cable tray 21 system models which Here not representative of the as-built l 22 conditions, configurations. .

23 The results of the original design calculations which 24 used reduced spectral accelerations are no longer used in the

('

25 design validation, Here never used in the design validation.

Carmen Gooden, CSR, RPR, Metro 429-5532

~

  • 115 1 As-built data is used to develop cable tray hanger frequencies

( 2 as speci.fied in SAG.CP and PI-02.

3 As you said, those three issues are similar. Those 4 are things before which people questioned that are no longer 5 employed.

6 MR. D0YLE: I have no questions on that.

7 MR. MUFFETT: The next issue He would like to present 8 is 14. This concerns nonconformance With AISC specifications.

9 It's going to be presented by Greg.

10 MR. ASHLEY: This issue has several parts. The first 11 part Was there Has a Concern With the slenderness limit used 12 for cable tray hanger compression members.

13 This issue has been resolved as folloHs: Provisions

(

14 of Section 1.8.4 of the AISC specification have been applied 15 in the fo11 ohing manner:

16 Classification of a vertical post member in a cable l

17 tray hanger as a compression or tension member is based upon

- i 18 the magnitude of the axial load component.

19 In particular, if there is any static compres'sive 1 1

20 force or if the combined static plus dynamic load exceeds 50 l

21 percent of the design compressive strength, the member is 22 classified as a compression member. A maximum slenderness i 10 23 ratio limit of 200 is applied to these members.

l 24 Secondly, if vertical post member is subject to i 25 static tension, and if the combined static plus dynamic load l

l Carmen Gooden, CSR, RPR, Metro 429-5532 4

I 116 l

1 does not result in a compressive force greater than 50 percent

( 2 of the design compressive strength, the member is classified 3 as a tension member. The maximum slenderness ratio, L over R, 4 limit of 300 is applied to these members.  ;

5 Thirdly, regardless of the member classification or 6 the nature of the load, a full compressive stress check is ,

7 performed in accordance with the AISC specification for 8 members subject to compressive loads.

9 A more detailed discussion of the slenderness ratio  !

10 limit is applied to the Comanche Peak cable tray hanger. It's i 11 provided in SAG.CP34 and Report 09-0210-0018. -

l 12 I might add that there has been numerous l correspono( 1ce with AISC to provide additional assurance that

( 13 14 our nuclear code is correct.  !

15 MR. D0YLE: I'm having a little trouble back here at l

16 A1. I don't quite understand the --

17 MR. MUFFETT: tet me backtrack and then we can lead 18 into it. If you remember, if you look in the AISC code in 19 regard to this slenderness ratio, it gives you two limits; one ,

20 for compression member and one -- ,

21 MR. D0YLE: That's not the point. '

22 MR MUFFET: No, I'm Just leading into a little 23 history here. One for compression member, one for tension l 24 member. But the code'doesn't tell you what that definition L 25 is. And there has been some discussion What constitutes a .;

~

Carmen Gooden, CSR, RPR, Metro 429-5532

~

~

117 1 tension member and what constitutes a compression member

( 2 because.these members that are primarily in tension 3 occasionally in-the earthquake may see compressive loads.

4 What you see here has been some definitions He-have worked out 5 to classify.them as a compression or a tension member, and He 6 have received the concurrence from AISC on this approach.

7 MR. D0YLE: So this is something beyond what I 8 normally Hork Hith.

9 MR. MUFFETT: Yes. Well, not knowing what you 10 normally work with, it's something over and beyond what's 11 normally done.

12 MR. D0YLE: Because I had always -- in all the type 13 of work that I do, compression is compression.

{

14 MR. ALEXANDRU: Jack, he did mention under earthoucke i 15 conditions the code is not specific for dynamic load 16 conditions, and since He do have dynamic compression, that's 17 Where the issue had to be-clarified, or* interpretation 18 H1th --

19 MR. D0YLE: Because there':. a ret '- -v period --

20 MR. ALEXANDRU: Because there ' res sal, a very 21 short time in compression.

22 MR. D0YLE: Are He going to get to see something on 23 the AISC -- l 24 MR. MUFFETT: The correspondence with the AISC?

25 MR. D0YLE: Yeah.

4 Carmen Gooden, CSR, RPR, Metro 429-5532

S 118 1 MR. MUFFETT: You certainly can. We'll make that I 2 available to you. In fact, there's an interchange of letters, 3 blit you certainly can see those.

4 MR. D0YLE: Because I know there has been over time c 5 confusion over that because it's just a slight duration of 6 compression and in some cases there's no guarantee it ever 7 does achieve compression, 8 MR. MUFFETT: That's correct. And also, the latest 9 edition of this code, load resistence factor design, changes 10 these compression limits and makes them should instead of 11 shall --

12 MR. D0YLE: I have a copy and haven't even read it.

( 13 MR. ASHLEY: The next part to this issue related to 14 tha original design AISC equation 1.5-7 for determining 15 bending stress allowables in channels was not considered or 16 Has improperly used.

17 Additionally, reductions in section properties of 18 beams due to bolt holes in flanges Here not Considered.

19 We already discussed that in Issue 9.

20 The resolution for this issue was the Design 21 Validation Procedures SAG.CP34, PI-03 and PI-11 require the '

22 use of AISC equation 1.5-7 for validation of cable tray hanger 23 channel members and provide direction for its proper 24 application. '

('

25 Additionally, reduced member section properties Carmen Gooden, CSR, RPR, Metro 429-5532

j -

119 1 resulting from bo]t holes were developed for Engineering

( 2 Studies Volume I, Book 25 and M-65 in accordance with tne AISC 3 specification. The size of the bolt holes considered Has 4 three quarters of an inch; based on statistical evaluation of 5 as-built cable tray hangers. Design Validation. Procedures 6 SAG.CP34 and PI-11 require the use of these reduced properties 7 in the design validation of cable tray hanger tiers'to account 8 for the presence of both used and unused bolt holes.

9 MR. D0YLE: I take it this means a deal Hhere you 10 have to extend the bolt holes.

11 MR. ASHLEY: That's correct. It's a reduced --

12 basically a reduced modulus is used in the evaluation.

13 MR. D0YLE: 1.5.7 Where D over EM and length of the

{

14 controlling factors on the allowables.

15 MR. ASHLEY: That's correct.

16 MR. D0YLE: No other questions.

17 MR. ASHLEY: The-next part to this issue was double 18 angle braces Here designed as composite members, but adequate 19 filler plates were not provided.

20 Additionally, design of cable tray hangers using 21 single angle braces did not consider connection l 1

22 eccentricities. ..

23 This issue has been resolved by the Design Validatior 11 24 Procedures SAG.CP34 and PI-02 which allow double angle braces l s"

25 to be analyzed as composite members only if the requirements l

1 Carmen Gooden, CSR, RPR, Metro 429-5532

I 120 1 of AISC specification Section 1.18.2.4 regarding interniittent

( 2 filler plates are satisfied.

3 Additionally, single angle brace connection I

4 eccentricities have been considered as specified in the Desigr 5 Validation Proceduress SAG.CP3, -4, -34, PI-02 and Engineerins 6 Study M-12.

7 MR. D0YLE: No questions.

8 MR. ASHLEY: The next part to this issue was in the ,

9 original design oversized bolts holes Here.used for anchor 10 bolts and tray clamps without adequcte Justification.

11 This issue has been resolved since for steel to 12 concrete connections AISC bolt hole environments are not 13 applicable. There is an AISC letter to Mr. Nace dated August

{

14 24, 1986. The effects of bolt hole sizes were evaluated 15 through analytical studies, Ebasco position paper entitled 16 "Effects of Bolt Hole Oversize in CTH System and Conduit 17 System Adequacy," Volume-I, Book 22. Steel to concrete 18 connections with the existing holes Here concluded to be 19 acceptable.

! 20 Secondly, for clamp connections, which include cold

21 formed components, the AISC AISI code is applicable. In 22 addition, cold formed steel components are not governed by i
23 AISC.

24 AISI allows testing as a means of establishing the

( 25 capacities and allowables., Cable tray clamp connection Carmen Gooden, CSR, RPR, Metro 429-5532

~ l 121 1 capacities were established based on tests which included I

( 2 appropriate consideration of hole size. The reference there i 3 is CCL Report Numbers A-717-86, A-721-86 ond A-743-87. )

Thirdly, for connections betHeen structural steel l 4 1 5 members to ensure compliance with the AISC code, appropriate j 6 corrective action is being taken in the Post Construction 7 Hardware Validation Procram. In that program He Hill ensure l l

8 that the requirements of the AISC specification are met.

9 MR. D0YLE: I ought to direct this to Larry. This l 10 letter they refer to, August 24th of '86, is that related to 11 the Fisher paper on bolt holes, anchor bolt holes?

12 MR. NACE: No -

( 13 MR. MUFFETT: If you will allow me to intercede here.

14 I don't believe that it is. It's a comment from the code that 15 they don't believe the code covers the connections of steel tc 16 concrete. We can certainly make that letter available to you l'7 with the other one. ~'

  • l 18 MR. D0YLE: Uh-huh.

19 MR. ASHLEY: The next part to this issue is 20 longitudinal braces rr.av have been improperly designea for 21 compressive stre. as a second member.  !

22 Additionally, in the original design cable tray 23 hanger members subjectd to oxial and flexural loads may not j 24 have been properly evaluated in accordance Hith equation 25 1.6-1A of the AISC specification.

Carmen Gooden, CSR, RPR, Metro 4?9-5532

i 122 1 This issue has been resolved since all bracing

( 2 members.are design validated using the AISC specification 3 primary member stress allowables as specified in the Design 4 Validation Procedures SAG.CP34 and PI-03. l 5 Members subjected to oxial and bending loads are 6 evaluated in accordance with equation 1.6-1A of the AISC 7 specification using a conservative combination of 8 coefficients.

9 MR. NACE: I think it Hould be appropriate to take 10 about a 10-minute break.

11 (A break Has taken.)

12 MR. NACE: The meeting Hill come back to order. Due

(' 13 to the lateness of the hour, fatigue is starting to set in at 14 the head table. I thought perhaps He could go until 15 approximately 4:15, and then de'll give CASE an opportunity to 16 make any comments or ask any questions on the material that 17 has been presented. That-"which has not yet been presented by 18 that time we will cover at the next meeting.

19 MR. MUFFETT: The next issue is Issue 15. This issue

! 20 has to do Hith member substitution. The issue was that in the 21 original cable tray hanger installation specification they 22 Here alloHed the substitution of a structural member at the 23 loHer section maduli than the members specified by the design.

24 Documentation of member substitutions was inadequate.

L 25 Resolution is that the cable tray hanger Design Carmen Gooden, CSR, RPR, Metro 429-5532

1- ._

123 a

1 Validation Procedures SAG.CP34 and PI-11 require the use of .

( 2 the as-built member sizes for design validation. Member 3 substitution permitted by the original design Hhich may have 4 resulted in a lower section moduli Has considered in the 5 design validation where necessary.

! 6 MR D0YLE: So in other Hords, if you found a sectior 7 that was a lower section modulus, that's the number you 8 used --

9 MR. MUFFETT: That's what we used, and sometimes the) 10 Hould pass and sometimes they would not pass and He would fix 11 them. -

12 MR. D0YLE: No other questions.

( 13 MR. MUFFETT: The next issue is Issue 16 which has to 14 do Hith Weld design and Held specifications, and Rene is going l

15 to present this one.  ;

16 MR. ALEXANDRU: There are a multitude of subissues on -

l'7 Helds, of which the first~two are the original design drawings t 18 for several cable tray hangers did not provide Held details.

f 19 And Held sizes shown on the original assembly 20 drawings difered from those on the design drawings and those 21 in the original Held calculations.

22 The issue resolution of these.two subissues is r 12  !

23 achieved because design validation of cable tray haager Helds  !

24 was performed using as-built Held dJta os required in Design  ;

) (~ i

25 Valiaation Procedures SAG.CP3, CP4, CP34, and PI-03. As-built '

i Carmen Gooden, CSR, RPR, Metro 429-5532

i 144 1 hanger drawinns which-include Held details have been developec

( 2 for each. cable tray hanger.

3 The next subissue is that the eccentricities were not 4 considered in the original design of welded connections.

5 We have resolved this issue because the effects of 6 eccentric loads on Helds are considered in design validation 7 using as-built data as required in Design Validation 8 Procedures SAG.CP3, CP4, CP34 and PI-03, i

9 This external source issue says that the base metal i

10 thickness of connected r. embers was not considered in the 11 original Held designs. Specific designs may have considered i

i 12 excessive Held throat. , l

(; 13 This issue resolution is achieved because the Design 14 Validation Procedures SAG.CP3, CP4, CP34 andPI-03 require the 15 assessment of the as-built Held and base metal thicknesses in 16 accordance with the AISC specification.

I l'7 The next subissus deals with original design [

18 calculations which assumed an incorrect minimum Held length 19 for beam / hanger base angle connection because the radius of 20 the angle leg Has neglected.  ;

i 21 We resolved this issue in the design validation of  ;

22 cable tray hangers because the Held design validation was f

23 performed using as-built Held length data as required in the  !

l 24 Design Validation Procedures SAG.CP3, CP4, CP34 and PI-03.

(.

i 25 This subissue identified that several cable tray i

f i

Carmen Gcoden, CSR, RPR, Metro 429-5532

j -

125 1 hangers have Helds Hhich violated the minimum Held size

( 2 requirements as specified by the AISC specification.

3 And the issue is resolved because the Helding l 4 procedures which produced the Helds in question have been 5 qualified in accordance with AWS D1.1, Section 5.3, as 6 directed by the AISC Section 1.17.2.

7 MR. NACE: Excuse me, Rene, that's Section 5.2. You 8 said 5.3.

9 MR. ALEXANDRU: Pardon me. Am I all,Ht ' to continue?

10 MR. NACE: Yes.

11 MR. ALEXANDRU: Thank you. Both Helds'Here checked 12 for compliance with AISC stress allowables based on axial loads and axial Held size. We have to empha*1ze that no

( 13 14 credit is taken for structural fillet Helds less than one 15 eighth of an inch.

16 MR. D0YLE: I don't really have a question. I'm Just 17 going to have to look into that D1.1 and 17.2.

18 MR. MUFFETT: Let me volunteer something here.

19 Again, we have a letter from the AWS about an interpretation 20 that what He're doing is correct, and He Hill gladly forward 21 that along with the other ones.

22 MR. D0YLE: That saves me from. reading and 23 interpreting.

24 MR. MUFFETT: Right.

25 MR. ALEXANDRU
The next subissue found that the --

l Carmen Gooden, CSR, RPR, Metro 429-5532 l ,

1 i 126  :

1 1 the external source found that several cable tray hanger.

( 2 designs employed composite sections joined using intermittent  ;

3 fillet Helds which were not evaluated in the original design 4 calculation.

5 During our program the intermittent fillet He3ds 6 connecting components of a composite section are design 7 validated using as-built Held data as specified.in Design ,

8 Validation Procedures SAG.CP3, CP4, CP34 and PI-03.

9 Following is a slide showing the intermittent Helds  ;

10 He Here talking about.

11 MR. D0YLE: Let me see if I understand this. They 12 did a B0 over I --

{ 13 MR. ALEXANDRU: They didn't do anything.

R 14 MR. D0YLE: They didn't do anything?

15 MR. ALEXANDRU: Make it very simple, 16 MR. D0YLE: Okay.

j 17 MR. ALEXANDRU: He do one, Hhat you Just said.

1' 18 The next issue, the externcl source.also found that 19 the original cable tray hanger design calculations did not i 20 evaluate the Helds used to attach base angles to embedded 21 plates.

. 22 The issue is resolved since all Helds between base 2

23 angle and embedded plates have been design validated using j 24 as-built Held data as specified in Design Validation  :

1 (,

25 Procedures SAG.CP3, CP4, CP34 and PI-03.

Carmen Gooden, CSR, RPR, Metro 429-5532

i 127 1 The following subissue deals with the cable tray

(

2 hanger calculation which evaluated partial penetration groove 3 welds using prequalified Held tests that may not be 4 representative of as-built conditions.

5 We have looked at that and based on the physical 6 examination of the configuration, the prequalified weld tests l

1 7 used in the evaluation of partial penetration groove Helds arE 8 representative of the as-built condition, 9 The next slide actually shows -- the top 10 configuration is the one which was prequalified. The bottom 11 configuration is the one which occasionally occurred during 12 the installation and they are from a welding standpoint

{ 13 similar.

14 MR. D0YLE: No questions.

15 MR. MUFFETT: Moving along, the next issue we'd like l

16 to present is 17, which has to do Hith embedded plate design.

17 The following concerns were raised on the original 18 embedded plate design. I'm going to go down.the list here.

19 Effect of prying action on tension in Nelson studs 20 may not have been considered.

l 21 Pipe support designers and cable tray support 13 22 designers used inconsistent design practices on stiffening of 23 moment attachments to embedded plates.

24 Design calculations for supports attached to embedded 25 plates did not consider capacity reductions given in design Carmen Gooden, CSR, RPR, Metro 429-5532

128 1 specifications for specific locations.

( 2 , Inspection procedures for supports did not require a 3 check of attachment separation. ,

T 4 Some L ' cort anchorage details may resist loads from  :

5 larger tributary .roy spans than Here assumed in the design  ;

6 calculations, the original design calculations.

! 7 Design specifications did not address minimum spacins 8 for Hilti expansion anchors installed on concrete surfaces 9 perpendicular to embedded plates.  !

t 10 The resolution: The design adequacy of embedded  !

s 11 plates is being evaluated as part of the civil / structural 12 Corrective Action Program, which was mentioned this morning.

( 1? The cable tray hanger loads on embedded plates are >

14 being transmitted to SWEC, the lead contractor for '

15 civil / structural, for validation of the embedded plates.

16 I'd like to reemphasize a point here, that this is I

1'7 another way that we unifr'it. Although many people have loads

]

18 that come on embedded plates, there's only one contractor who  ;

19 controls that and validates those so that there's not multiple i 20 methods being used on the site, t

. 21 MR. D0YLE: What I'm understanding here is that the 22 original contractor treated the cable trays as a multiplicity >

23 of simple supports rather than doing the moment distribution

, 24 and finding the precise loads?

l

(~

25 MR. ASHLEY: If I'm understanding you, I believe that Carmen Gooden, CSR, RPR, Metro 429-5532  !

I ~

129 1 that is correct. We are using, you know, systems considering

( 2 the cable tray as a system as related to this particular 3 issue. That means that we will generate loads in each and 4 every hanger. If thet hanger is attached to embedded plates, 5 then we take those loads at that attachment point and transmit 6 them to Stone & Webster for volidation of that embedded plate.

7 MR. D0YLE: What I'm getting at, in first 8 determining What the load is at the support, if you have a 9 multiplicity of supports in a continuous beam, you Hill get 10 higher loads in the interior supports and a lesser load in the 11 end supports due to negat2ve moments that occur.

12 MR. MUFFETT: Right, and that's the system effect.

( 13 You model these systems, all hangers are modeled for that 14 effect.

15 MR. D0YLE: Okay, I was just trying to get it 16 clarified.

17 MR. ALEXANDRO: Yes. We menti'oned this before in tHa 18 of the issues, the system concept issue and the dynamic 19 amplification factor issues. We have mentioned that.

20 MR, MUFFETT: But all these things that you see here 21 on A17.1 have been addressed. We have unified our approach 22 under one contractor that's using a conservative --

23 MR D0YLE- We noted this several times during the 24 hearings where somebody Hill take something like a continuous

(' 25 beam and they Hill assume, Hell, I'll treat it as a simple Carmen Gooden, CSR, RPR, Metro 429-5532

I 130 i beam, and Hhile they save on the one hand, they lose on the l

( 2 other, and you have to look at all of the effects of the 3 procedures you're using.

4 MR. MUFFETT: Exactly, and that's why He have system t 5 models that inherently take care of that.

6 MR. D0YLE: I Just Hanted to get it clarified.

7 MR. MUFFETT: Right. And What you'll see is these 8 models in concept are very similar to a piping system model.

9 MR D0YLE: No more questions.

10 MR MUFFETT: The next one He'd like to present is 11 A18 concerning tray clamps. Greg Ashley is going to present 12 that, t I

( 13 MR ASHLEY: The original design may have included  ;

14 unjustified assumptions regarding rotational and displacement 15 connectivity between trays and supports. Specific assumptions  !

16 were the following:

1~7 Cable trays proVTde out-of-plane bracing to cable l 18 tray hangers.

19 Cable trays provide lateral bracing to the hanger 20 tiar compression flange. ,

l 21 Cable trays provide moment resistance capability 22 between thi trays and the tiers. .

23 This issue was resolved since connectivity was  :

1 i 24 ' confirmed through a full scale testing program done by ANCO, i 1 ('

i 25 and associated analytical correlation studies, Report

1 Carmen Gooden, CSR, RPR, Metro 429-5532 l

1 _

131 3

4 V

1 09-1210-0017 and Calculation M-28.

( 2 Engineering Studies, M-10 and M-19, developed the 3 methodology for modeling cable trays to hanger connectivity, a Cable trays are not assumed to provide. lateral 5 bracing in the hanger tier compression flange.

6 In the next slide He Just provided a ficure to show 7 you the typical types of clamps that He're talking about.

8 MR. D0YLE: No questions.

9 MR. ASHLEY: The next issue that we'd like to present 10 is Issue 19, which has to do Hith FSAR load combinations.

11 This issue was that LOCA associated loads were not 12 considered in the original cable tray support designs.

13 This issue has been resolved since LOCA pipe Whip anc

{ '

14 Jet impingement loads that we talked about this morning are 15 addressed by the CPSES system interaction portion of the 16 Corrective Action Program. All safety-related cable trays anc

, l'7 cable tray hangers identified as pipe ship or jet impingement 18 targets have either been relocated or shielded from the pipe 19 whip and Jet impingement load.

20 Additionally, the effects of accident thermal loads 21 Here considered in a detailed engineering study, M-27, 22 Results shoHed that the cable tray hanger systems, including 23 their anchorages, are sufficiently ductile to accommodate 14 24 accident thermal displacement Hithout reduction in seismic 25 load resistance or loss of function.

Carmen Gooden, CSR, RPR, Metro 429-5532

7 132 1

1 MRS. ELLIS: Is that study one of the ones that II 2 might be in the stuff that He Just got? '

3 MR. COUNSIL: No.

4. MRS. ELLIS: Can He get that?

5 MR. MUFFETT: Certainly.

6 MR. ASHLEY: It's also referenced in the PSR.

7 MR. NACE: There Hill be a truck arriving next Heek.

8 MR. ASHLEY: The next issue He'd like to present is 9 A20, Which deals with differences between installation and 10 design construction drawings without appropriate 11 documentation.

12 There are three issues here. The first issue was l

( 13 that undocumented discrepancies between the as-built and as-14 designed cable tray hanger configurations Here identified.

15 Secondly, the issue was that instances of violation 16 of operation or clearance requirements between cable tray 17 systems and other componehts were identified.

5 18 The third issue was that in certain instances anchors 19 were installed in concrete With tHo-inch thick topping. Since 20 the topping integrity cannot be assured, the effect of reducec 21 embedment must be considered.

22 The first issue resolution: Cable tray and cable 23 tray hanger design validation Has based on as-built 24 information collected for Field Verification Method, FVM-001, I

(' l 25 003, 019, 036, 048, 050, 084, 098 and 100. Therefore --

I l

l ,

Carmen Gooden, CSR, RPR, Metro 429-5532 ,

'{ -

133 1 MR. NACE: I Hould like to interrupt. You do have

( 2 those.

3 MRS. ELLIS: Thank you.

4 MR. ASHLEY: Therefore, these discrepancies do not 5 affect the design validation of the components.

6 MR. MUFFETT: The components He validate are as exist 7 in the field, 8 MR. ASHLEY: The second issue: Clearance 9 requirements betHeen Cable tray systems and other commodities 10 are being addresstJ by Stone & Webster Engineering.Corporatior 11 in the mechanical Corrective Action Program under the Post 12 Construction Hardware Validation Program. Clearance

( 13 ,

discrepancies identified for cable trays and cable tray 14 hangers Hill be resolved by Impell and Ebosco.

15 Third issue: Design Validation Procedures SAG.CP34 16 and PI-07 require a two-inch rr,. duction of bolt embedment 17 length for anchors mounted in concrete"Hith topping. Anchor 18 bolts embedded only in concrete topping and those that do not 19 meet the acceptance criteria are being replaced.

20 MR. D0YLE: No questions.

21 MR MUFFETT: Issue 21, A, B, C, E and I -- and this 22 Hill make sense to you When you refer to the GIR or PSI. I l 23 realize that looks a little strange. l 24 As-built information was not properly considered in

'. ~

25 the overall evaluation of cable tray hangers. l Carmen Gooden, CSR, RPR, Metro 429-5532 l

134 1 Resolution: Cable trays and cable tray hanger Desigr

( 2 Validation Procedures CP3, -4, PI-02 and PI-03 require the use 3 of as-built information as design input. 1 4 MR D0YLE: I can understand the second statement, 5 but I don't understand the first statement. Where Hould they 6 get as-built information to do the originals? ,

7 MR. MUFFETT: They did not change their calculation 8 in response to what I'll call as-built changes, which I think 9 you're aware that that went on.

10 MR. D0YLE: Yeah. I'm Just a little confused by the 11 statement.

12 MR. MUFFETT: When we mean original design, He mean i

( 13 under the prior system of doing things.

l 14 MR. D0YLE: Original -- okay. It could be the end l 15 product.

16 MR. MUFFETT: Of the prior group.

f 17 D. The issue H0Y that the original evaluation of

{

18 cable tray hangers did not properly consider the relevant  ;

19 Height of thermolog fire protection, cable tray covers and l 20 side rail extensions.  ;

21 The resolution is that the Height of thermolog fire 22 protection material and cable tray covers are considered in 23 the design validation of cable trays and hangers as specified i 24 in the Design Validation Procedures SAG.CP3, -4, -34 and '

( '

25 PI-02. The effect of side rail extensions has been addressed l Carmen Gooden, CSR, RPR, Metro 429-5532  :

135 f l

[

1 in Sag.CP34 and calculation M-39. l i

( 2 MRS. ELLIS: I guess in those tests cable tray 3 covers and side rail extensions weren't included on there  !

l 4 either, were they? i 5 MR. ASHLEY: Side rail extensions were. They were i

6 tested with varying fill levels and to accommodate the highest  !

7 fill level, which we call a hundred percent fill, which is 35 ,

8 pounds per square foot, side rails were installed so that the i 9 cables didn't fall out of the trays, which is typical of ,

10 what's done in the field, j 11 MRS. ELLIS: Okay.  !

! l

12 MR. MUFFETT
When you get the tests, you'll see j 13 that there's a lot of variation in the fill and configuration.

{

]

14 MR. ASHLEY: To clarify, covers -- they Here not l 3

15 tested Hith Covers on the trays, r i

16 MR. D0YLE: Wouldn't that be conservative? l 1

l'7 MR. MUFFETT: YWs, exactly.  ;

l 18 MR. D0YLE: Because you Hould have more Continuity j 19 Hith the thermolog and the covers in there, j

20 MR. MUFFETT: F and G: The issue was that certain

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21 original cable tray hanger design calculation sets did not  :

l 22 properly address design change notices issued against the  !

l I j 23 hanger design and calculations Here not adequately Controlled, f

4 24 Resolution: Cable tray and cable tray hanger Design  !

I

('  ;

a 25 Validation Procedures require that calculations and drawings t i

l ,

Carmen Gooden, CSR, RPR, Metro 429-5532 '

i 136 1 be controlled in accordance with quality assurance procedures,

( 2 Ebasco manual procedures for Comanche Peak and Impell quality

) 3 assurance manual. Procedures as contained in the Ebasco i 4 manual procedures for Comanche Peak and Impell instruction  !

5 PI-12 have been developed to control design changes and to I 6 assure that cable tray and cable tray hanger modifications are 7 incorporated into design calculations.

8 We have very tight procedural control of these 15 9 aspects.

i 10 MR NACE: I would like to emphasize also that those i

11 Ebasco and Impell design change procedures interact and 12 intersect with the TV Electric design change procedures, so i

( 13 it's all one integrated program.

14 MR. MUFFETT: H: The issue was that the original 15 design criteria were inadequate to assure consistency and l

16 compliance with the FSAR and the appropriate addition of AISC. I i i l l'7 Resolution: CabTe tray and cable tray hanger design i 18 validation criteria and procedures SAG.CP3, -4, -34, PI-02 l 19 and -03 are consistent with the requirements of the FSAR and 20 AISC specif1' . ions. Their reauired use assures compliance 1

21 with the licensing commitments, i

)

i 22 The next one He'd like to present is A22, and this is  :

23 a little bit different in nature, This deals with a specific i 24 support, 3136, and Rene is going to present this one, i

( l 1-25 MR. ALEXANDRU: The external source found that in the l

4 f

. ,e . _ , , . . _ _ _ , - ~ ._ _ . - . . - -

gy 1 original design, the support number 3136, which is detail 5 of

( 2 drawing 2323-S-0905, which is embedded in a fire Hall, the 3 following discrepancies were noted:

4 Support is seismic Category I while fire Hall is 5 seismic Category II, 6 Errors were found in finite element model and 7 calculations, 8 And tornado depressurization loads were not 9 considered, 10 This issue resolution is achieved as follows:

11 Cases of cable tray hangers attached to seismic 12 Category II structures were identified and evaluated on a 13 case-by-case basis,

{

14 Original design calculations were not considered in ,

15 design validation,

) 16 The structural adequacy of seismic Category II j 17 structures including tornado depressurization load effects is 18 being addressed by SWEC civil / structural Corrictive Action 19 Program, Criteria requiring that load from cable trays and i l i

20 cable tray hangers on seismic Category II structures be j 21 reported to SWEC have been established in the cable tray and 22 cable tray hanger Design Basis Document, DBD-CS-082,

{

j 23 MR, D0YLE: I have a minor question on that. It seems

! 24 that somebody else is generating the information and they turn I i r 25 it over to SWEC, SWEC resolves the problem. Does SWEC returr

{  ;

l

138 1 the information to the originator?

( 2 MR, ALEXANDRU: It's not quite this Hay, 3 In this particular case, there is a Category I support which 4 was the cable tray hanger support, and this was in Ebasco's 5 scope of work. We dealt With supports and with all the masses 6 and all the information we designed completely --

7 completely -- the Category I support. We did not need any 8 other information from SWEC, On the Category II part of it, 9 the entire Category II part of the Hall is desdaned and desigr 10 validated under SWEC's program, 11 MR, MUFFETT: I think you're talking in general, 12 right?

( 13 MR. D0YLE: Right, 14 MR, MUFFETT: The interface between contractors, 15 MR. D0YLE: Right, 16 MR MUFFETT: Yes. They get back information that 17 they need to complete their design, th'eir process, 18 MR, D0YLE: And all that they're concerned Hith is 19 that their information was properly 1y handled, 20 MR. MUFFETT: Right.

21 MR. ASHLEY: A good example of that Hould be a cable 22 tray hanger attached to an embedded plate. If He have a 23 hanger attached to an embedded plate, He transmit loads to 24 Stone a Webster. If they come back and tell us that the 25 embedded plates cannot handle that load, then we're required Carmen Gooden, CSR, RPR, Metro 429-5532 l

139 1 to move that hanger or essentially reanchor it.

( 2 MR. D0YLE: I'm sure this was what was going on. I 3 Just wanted to make sure.

4 MR. MUFFETT: One thing we pride ourselves on is 5 interface control. My experience in the NRC tells me that 6 that's one of the easiest ways to get into trouble. I think 7 your experience probably tells you that, too. We've gone to 8 great lengths to control that, and we have a very tight 9 program for that now.

10 MR. D0YLE: I have no questions.

11 MR. MUFFETT: The next one is A23, Issue 23, 12 concerning loading in stress models. Rene is going to present 13 Issue 23.

(

14 MR. ALEXANDRU: Issue 23 deals with loading in stress -

15 models. This original issue had the following Concerns on 16 the original computer program stress models used for standard 17 or generic cable tray hanger designs which were noted as 18 follows:

19 The application of tray loads did not reflect actual 20 tray locations.

21 The design loads did not consider tray span 22 installation tolerances permitted by the design drawings.

23 And frame heights did not reflect the distance to the 24 tier centroidal axes, t

25 The issue is resolved because cable tray honger Carmen Gooden, CSR, RPR, Metro 429-5532

140' i 1 Design Validation Procedures SAG.CP3, CP4 and PI-02 required -

( 2 the use of as-built information as design input which include:

! 3 The actual tray location on the tier.

  • 4 The actual cable tray span.

~

5 And the actual frame heights which are modeled to the 6 tier centroidal axes. ,

7 MR. D0YLE: No questions.

8 (A break Has taken.)

9 MR. NACE: The meeting Hill come back to order.' Jim 10 has some closing comments he Hanted to make for today, then I 11 Hould like to make some comments and then turn the floor over -

12 to CASE.

(

I '

13 MR. MUFFETT: Just two quick things I Hanted to 14 bring up. One, yesterday you asked about CYGNA review. By l 16 15 and large all these issues except the first two that we talked

]

l 16 about today are CYGNA issues. We are pursuing closure on all

! 17 the CYGNA issues, as you are aware, from the RIls. These -- l j 18 primarily issues come from there.

4 19 The other thing I Hanted to say is He believe He have 20 a really excellent program in these areas. We're very proud f

21 of it, and He're anxious to show it to you tomorroH. We have 1 22 a short tour of this lined up if you have time after you look j 23 at the piping and pipe supports.

1 24 MR. NACE: I guess my regret is that the days Heren't 25 longer or that our stamina Hasn't greater, because I Hould Carmen Gooden, CSR, RPR, Metro 429-5532

141 1 like to have gotten through the remaining cable tray hanger

( 2 issues plus the two conduit support issues.

3 I Hould like to leave you Hith the impression that 4 the some quality of controls and resolution of issues that I 5 hope you have seen to date extend to those programs as well.

6 The concept of the integration of the design activities and 7 the concept of the controls over the erection process 8 uniformly apply to all those activities as Hell.

9 So He would look forHard to another set of 10 discussions to complete the issue presentations, but He know 11 you're going to be happy with them.

12 For the record He do look forHard to your site tour

( 13 tomorroH and He Hill be Haiting on site by the time you show 14 up in the morning at 9:00 o' clock.

15 Does CASE have any questions?

16 MR. D0YLE: The reason He probably didn't get through 17 all the issues is I asked too many que'stions.

18 One of the main points I'd like to make is all 19 through the hearings one of my chief concerns was not the 20 specific concern but it was with the cumulative effect of a 21 vast number of concerns. A Dr. Landers -- I believe that Has 22 his name -- Hith Teledyne that was Horking with the NRC, that 23 Has his chief concern also. And it was one of the reasons i

24 that at a meeting back in February 1985, I think -- I'm losing t

' l 25 track of time -- there were some minor issues, and they asked l

Carmen Gooden, CSR, RPR, Metro 429-5532 l

142 l

1 me if I Hould concede. The reason-I Houldn't concede was that l

( 2 very point, that it was Just so many issues that cumu14tively 3 even the most minor one became serious.

4 In the meeting in March and the meeting today it's -

5 rather obvious that not only Here you not faced.With the 6 cumulative effect, but apparently, at least up in the front -

7 end -- I keep emphasizing the front end -- most of these 8 problems have been solved, Hith a feH exceptions of a few oper

. 9 items He have. And beyond that I think that the presentation 10 today Has particularly Hell done, and I also think it was 11 rather productive.

12 That's about the only comments I have.

(, 13 MR. NACE: We're going to convince you that He have 14 the back end Just as much under control.

15 MRS. ELLIS: I'd like to say something on the record 16 that I think I have c1 ready said to you off the record,.and

.I 17 that is He Hould love to be convinced.' And I think that this

^

! 18 session has been a productive one, as I think the previous one 19 Has, as Hell. And I think this informal or less formal 20 atmosphere of engineer to engineer is far preferable to having

21 to 90 through the grueling process of a hea-ing. And I hope 22 He Hill continue this sort of dialogue back and forth.

1 j 23 And also I hope that both DAP and the NRC staff are l'  ;

24 not in such a hurry to get things done that we Hon't have time  !

(

4 25 to adequately do this, because I think this is really a much 1

l den, , Meu 429-5532 1

1- ._- -

143 i

i superior method of handling this sort of issue. These

(- 2 detailed technical issues like this really lend themselves so 3 much better to this sort of atmosphere.

4 Another thing that I feel I have to say in fairness 5 to our witnesses. First, of course, Jack, I think, deserves a 6 great vote of thanks, not only from CASE, but from the 7 applicants and the NRC staff as well, because I think he's 8 been instrumental in bringing to light many, many issues whict 4

9 really needed looking at badly and which without his 10 persistence would never have been looked at until perhaps 11 something happened of a more drastic nature, perhaps even an 12 accident, or at any rate, outages and downtime of the plant or

( 13 line.

14 So I want to recognize that. And also I Hont to

~

15 point out -- you mentioned, I think, that all except two of 16 the issues on the cable tray supports Here CYGNA issues. I ,

17 know that you probably have no Hay of being aHare of this, but 18 Just for the record I think we have to give a'little credit 19 there to Mark Walsh because Hhen CYGNA came to the hearings ir i 20 May of 1984 they were basically ready to sign off on all the 21 cable tray support issues. So it Hosn't until those hearings 1 22 and his effort in that regard that those issues began to come i 1

23 to light and CYGNA began to really look closely at those 1

1 24 things. I feel that I must in fairness to our Hitnesses J ('

) 25 express appreciation for that, i

1

)

Carmen Gooden, CSR, RPR, Metro 429-5532

I 144 i

\

l 1 And I Hant to also express appreciation for all of (I 2 your hard work, because it shows. It's obvious that you have .

3 done an awful lot of work for these presentations here, and HE 4 really appreciate that. And He appreciate Mr. Counsil and Mr.

17 5 Nace, everybody, having us down here and having-Jack have the 6 opportunity to get together on this. I think it's very 7 fruitful, and He've all got a lot of work to do.yet. We'll be 8 doing a lot of reading, and I'll be looking forward to the 9 truck backing up in front of the house. And we'll be gettins 10 back with you on the cable tray supports. We'll probably 11 have some questions on that after He have had time to really

. 12 look at some of these other documents. I'll try to give you j

{ 13 some advance notice on some of the questions maybe before our I

, 14 next meeting so that you con be a little better-prepared in j 15 advance and we won't catch you off guard, l 16 MR. D0YLE: Could I make one correction to what she i i 17 said? She said she would like these meetings to continue. I 18 hope she doesn't inean ad infinitum.

] 19 MRS. ELLIS: Let me clarify that. I don't mean ad  !

1

! 20 infinitum.

, 21 MR. COUNSIL: I appreciate your comments very much.

4 22 One item: After the holiday season I Hill be in

23 touch Hith you to try to schedule a continuation of the

]

24 meeting when Jack is available again.  ;

(.

25 And speaking of the holiday season, I probably Hill l

i l Carmen Gooden, CSR, RPR, Metro 429-5532

7 I -

145 i

i t i i not see any of you. Have a Merry Christmas and a Happy New I (I- 2 Year. -

j 3 MRS. ELLIS: Thank you.

4 MR. NACE: Since I will be seeing most of you, I will ,

5 not wish you a Merry Christmas now, but I do wish a Merry

, 6 Christmas to CASE and Jack. We'll see you tomorrow. ,

7 This meeting is closed.

8 9 (The meeting was closed at 4:15 p.m.)

l .

10 I 11

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14 i 2

15

i

, 16 .

I

17 -- -

i l j 18 i j l i

19 l

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25 .

a e Carmen Gooden, CSR, RPR. Metro 429-5532

I 146 1 STATE OF TEXAS )

([ 2 . )

3 COUNTY OF TARRANT )

4 5 I, Carmen Gooden, Certified Shorthand Reporter of the 6 State of Texas, certify that the foregoing proceedings were 7 reported stenographically by me at the time and place 8 indicated, and that it is a true record of the proceedings hac 9 at that time.

l 10 Given under my hand and seal of office on this the 22nd 11 day of December, 1987, 12 13 /

(.

14 h vN / l Carmen Gooden, Notary Public anc ,

15 Certified Shorthand Reporter in and for the State of Texas. ,

17 Certificate No.: 2353 Expiration Date: 12-31-87 l 18 Notary Expires: 08-10-91 -

19 20 21 22 23 24

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25

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Carmen Gooden. CSR, RPR, Metro 429-5532

_