ML20149L382

Rev 0 to HVAC, Project Status Rept

ML20149L382
Person / Time
Site:	Comanche Peak
Issue date:	02/18/1988
From:	Fitzgerald K, Rao R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20149L332	List: ML20149L330 ML20149L382
References
TAC-R00291, TAC-R291, NUDOCS 8802240208
Download: ML20149L382 (125)

Text

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i O CouANCHE peAg STE AM ELECTRIC STATION

, UNIT 1 and COMMON i

CORRECTIVE ACTION PROGRAM l

O PROJECT STATUS REPORT l

HEATING, VENTILATION AND AIR CONDITIONING i (H V A C)

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i l _4 C/l O/D/O l 64 I I I 'ulRJv 1

O Generating Division

! ggg22gggg gggg s A DCD

1 Revision 0 TV ELECTRIC COMANCHE PEAX STEAM ELECTRIC STATION UNIT 1 AND COMMON EBASCO SERV!CES INCORPORATO PROJECT STATUS REPORT HEATING, VENTILATION AND AIR CONDITIONING (HVAC)

O L AcWM K Fitzgerald

HVAC Program Manager R Rao HVAC Systems lead Discipline Engineer O

TABLE OF CONTENTS Section lillg Ejtgg EXECUTIVE

SUMMARY

iii ABBREVIATIONS AND ACRONYMS vii

1.0 INTRODUCTION

1-1 Figure 1-1 Corrective Action Program (CAP) - HVAC 2.0 PURPOSE 2-1 3.0 SCOPE 3-1 4.0 SPECIFIC ISSUES 4-1 l l

5.0 CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS 5-1 5.1 METHODOLOGY AND WORK PERFORMED 5-1 5.1.] Licensing Comitments, Design Criteria, 5-1 Procedures and Design Basis Documents (DBDs) .

5.1.1.1 Verification of Design Criteria, Procedures 5-2 and Design Basis Documeni:s (OBDs) 5.1.2 Design Validation Process 5-4 5.1.2.1 Design Validation Input Data for HVAC Duct O 5.1.2.2 and HVAC Supports 5-4 Analytical Methods for Design Validation of 55 HVAC Duct and HVAC Supports 5.1.2.3 Validation of HVAC Systems Design 5-7 5.1.2.4 Resolution of HVAC Duct, HVAC Supports and 5-9 HVAC Systems Related Design Issues 5.1.2.5 Interfaces 5-9 5.1.2.6 Final Reconciliation Process 5-10 5.1.3 Post Construction Hardware Validation 5-10 Program (PCHVP)

} 5.2 RESULTS 5 16 5.2.1 Design Validation Results 5-16 5.2.2 Post Construction Hardware Validation Program 5-17 (PCHVP) Results i

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faction Title Elg.t 5.3 QUALITY ASSURANCE (QA) PROGRAM 5-18 5.3.1 Sumary of Ebasco Quality Assurance 5-20 (QA) Audits 5.3.2 Sumary of Audits by TV Electric Quality Assurance 5 21 (QA), by NRC-VPB and Inspections by NRC-OSP 5.4 CORRECTIVE AND PREVENTIVE ACTIONS 5-22 Figure 5-1 Corrective Action Program (CAP) Technical Interfaces - HVAC i Figure 5-2 Post Construction Hardware Validation Program  !

(PCHVP)

Table 5-1 HVAC Design Procedures and Design Basis Documents (DBDs) '

Table 5 2 Post Construction Hardware Validation Program (PCHVP)

HVAC Attribute Matrix Table 5-3 Summary of Audits l

6.0 REFERENCES

6-1 l APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) AND A-1  :

EXTERNAL ISSUES .

t APPENDIX B ISSUES IDENTIFIED DURING THE PERFORMANCE B1 i 0F THE CORRECTIVE ACTION PROGRAM (CAP) {

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EXECUTIVE

SUMMARY

This Project Status Report (PSR) sumarizes the systematic validation O arac ss for =>r tv-r 1 lt'd " ti"9 v "t" tioa "d ^'r co"dit'aa'as (HVAC) duct, HVAC supports and HVAC systems implemented by Ebasco ServicesIncorporated(Ebgsco)atComanchePeakSteamElectricStation (CPSES) Unit I and comon . This Project Status Report (PSR) presents '

the results of the design validation and describes the Post Construction Hardwire Validation Program (PCHVP). Ebasco activities are governed by

, the TV Electric Corrective Action Program (CAP) which required Ebasco to:

1. Establish a consistent set of CPSES safety related HVAC duct, HVAC supports and HVAC systems design criteria that complies with the CPSES licensing commitments.

2. Produce a set of design control procedures that assures compliance with the design criteria.

3. Evaluate safety-related systems, structures and components, and l direct the corrective actions recomended by the Comanche Peak Response Team (CPRT) and those determined by Corrective Action Program (CAP) investigations to be necessary to demonstrate that safety-related systems, structures and components are in conformance with the design criteria.

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1 Unless otherwise noted, HVAC duct includes the HVAC plenums I and HVAC air handling units; and HVAC supports includes HVAC i duct supports and HVAC equipment supports. l 2 Comon refers to areas in CPSES that contain both Unit 1 and Unit

?. systems, structures and components.

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! 4. Assure that the validation resolves the safety related HVAC duct. l

'- HVAC supports and HVAC systems related design and hardware issues-  !

identifjedbytheComanchePeakResponseTeam(CPRT), external  !

sources and the Corrective Action Program (CAP).  !

l 5. Validate that the design of safety related HVAC duct, HVAC l supports and HVAC systems is in conformance with the licensing  ;

commitments and that the installed hardware is in conformance with  ;

I the validated design. i

6. Produce a set of consistent and validated design documentation.

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A consistent set of design criteria for CPSES Unit 1 and Common l

safety-related HVAC duct, HVAC supports and HVAC systems has been  !

developed and used by Ebasco for the design validation process. This set i

of design criteria is in conformance with the CPSES licensing  !

commitments. To provide added assurance of the conservatism of the  ;

j analytical methods, design criteria and of the design adequacy of the HVAC i

duct and HVAC supports, engineering studies were performed and a j

comprehensive testing program was conducted. ,

l Ebasco established design control procedures to implement the design criteria and engineering methods and to govern, the work flow and technical 4

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interfaces with other disciplines for both the design and hardware l i validation processes. These procedures specify the processes which have .

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been implemented throughout the HVAC portion of the Corrective Action  ;

j Program (CAP).

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a 3 External source issues are identified by the following:

l 1 o NRC Staff Special Review Team (SRT-NRC)

} o NRC Staff Special Inspection Team (SIT)  ;

o NRC Staff Construction Appraisal Team (CAT) i o Citizens Association for Sound Energy (CASE) j o Atomic Safety and Licensing Board (ASLB) e o NRC Region IV Inspection Reports o NRC Staff Technical Revtew Team (TRT) [SSERs 7-11) ,

o CYGNA Independent Assessment Program (LAP)  ;

l Comanche Peak Response Team (CPRT) issues are identified by the following:

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! o Design Adequacy Program (DAP) l o Quality of Construction Program (QOC) i l

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I Ebasco has performed analyses to validate the design of as-built CPSES Unit I and Common HVAC duct and HVAC supports. The results are documented i in the HVAC structural Design Validation Package (DVP) which includes 4109 Q supports and 3873 duct segments, plenums and air handling units. Ebasco has performed analyses to validate the design of CPSES Unit 1 and Ctmon i

j HVAC systems. The results are documented in the HVAC systems Design i Validation Package (DVP). The as-built hardware for safety related HVAC l duct, HVAC supports and HVAC systems is being validated to the design by the Post Construction Hardware Validation Program (PCHVP).

Engineering methodologies have been incorporated into the Ebasco design ,

procedures and the Post Construction Hardware Validation Program (PCHVP) procedures which have resolved the HVAC duct HVAC supports and HVAC systems related design and hardware issues identified by the Comanche Peak Response Team (CPRT) and external sources. Consequently, the validated design of the CPSES safety related HVAC duct, HVAC supports and HVAC )

l systems has resolved these issues. The resolution of issues which were '

identified during the performance of the HVAC portion of the Corrective Action Program (CAP), which were determined to be reportable under the provisions of 10CFR50.55(e), are described in Appendix B of this Project Status Report (PSR).

The Post Construction Hardware Validation Program (PCHVP) assures that the safety-related HVAC duct, HVAC supports and HVAC systems are installed in conformance with the validated design. Ebtsco has reviewed and revised .

the CPSES Unit 1 and Common HVAC duct HVAC supports and HVAC systems related installation specification, and reviewed the revised construction procedures, and Quality Control (QC) inspection procedures to assure that the validated design requirements are implemented. The Post Construction O sire r viiid tioa erosr m (acava) ror r tv-r i t o avAc duct. svac supports and HVAC systems, including the inspections, engineering walkdowns and engineering evaluations, implements the corrective actions recommended by the Comanche Peak Response Team (CPRT), as well as those required by the Corrective Action Program (CAP) investigations.

Ebasco will provide te TU Electric a complete set of validated design documentation for CPSES Unit 1 and Common safety-related HVAC duct, HVAC '

supports and HVAC systems including calculations, specifications, drawings, design changes, inter discipline transmittals and hardware modifications. This '

configurationcontrolgocumentationcanprovidethebasisforCPSES to facilitate maintenance and operation I throughout the life of the plant.

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4 Configuration control is a system to assure that the design and hardware remain in compliance with the licensing connitments throughout the life of the plant. l v

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In-depth quality and technical audits performed by Ebasco Quality Assurance (QA), TU Electric Quality Assurance (QA), and the independent i Engineering Functional Evaluation (EFE) verify that the implementation of l s the Corrective Action Program (CAP) is in conformance with the applicable l 10CFR50, Appendix 8 quality assurance requirements. j The CPSES Unit 1 and Common HVAC portion of the Corrective Action Program

(CAP) validates

o The design of the safety-related HVAC duct, HVAC supports and HVAC systems complies with the CPSES Unit 1 and Common licensing cornitments.

o The as-built safety related HVAC duct, HVAC supports and HVAC systems comply with the validated design.

o The sa'ety-related HVAC duct, HVAC supports and HVAC systems comply with the CPSES licensing commitments and will perform their safety-related functions.

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ABBREVlATIONS AND ACRONYMS AISC American Institute of Steel Construction

] ANI ANSI ARS Authorized Nuclear Inspector American National Standards Institute Amplified Response Spectra ASLB Atomic Safety and Licensing Board AWS American Welding Society

- CAP Corrective Action Program CAR Corrective Action Request CASE Citizens Association for Sound Energy CAT Construction Appraisal Team (NRC) -

CCL Corporate Consulting and Development Company, Ltd.

, CFR Code of Federal Regulations CPE Comanche Peak Engineering CPRT Comanche Peak Response Team CPSES Comanche Peak Steam Electric Station CYGNA CYGNA Energy Services

.; DAP Design Adequacy Program DBCP Design Basis Cnnsolidation Program DBD Design Basis Document DIR Discrepancy Issue Report (CPRT)

DR Deficiency Report DVP Design Validation Package Ebasco Ebasco Services Incorporated .

EFE Engineering Functional Evaluation ERDA Energy Research and Development Administration ESM Equivalent Static Method FSAR Final Safety Analysis Report O FVM HVAC Field Verification Method Heating, Ventilation and Air Conditioning IAP Independent Assessment Program (CYGNA) i Impell Impell Corporation i

IR Inspection Report IRR Issue Resolution Report

, ISAP !ssue Specific Action Plan  !

J NCR Nonconformance Report i 1 NRC United States Nuclear Regulatory Comission NSSS Nuclear Steam Supply System NUREG NRC Document OBE Operating Basis Earthquake OSP Office of Special Projects (NRC)

] PCHVP Post Construction Hardware Validation Program l

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PSR Project Status Report QA Quality Assurance QC Quality Co.itrol a

O QOC RIL Quality of Construction and QA/QC Adequacy Program (CPRT)

Review Issue List RSM Response Spectra Method SDAR Significant Deficiency Analysis Report (TV Electric)

SER Safety Evaluation Report (NRC, NUREG 0797)

SIP Systems Interaction Program SIT Special Inspection Team (NRC)

SMACNA Sheet Metal and Air Conditioning Contractors National Association -

SRSS Square Root of the Sum of the Squares SRT Senior Review Team (CPRT)

SRT NRC Special Review Team (NRC) i SSE Safe Shutdown Earthquake SSER Supplemental Safety Evaluation Report (NRC, NUREG-0797)

SWEC Stone and Webster Engineering Corporation  ;

SWEC-PSAS Stone and Webster Engineering Corporation-Pipe Stress and Support Project TAP Technical Audit Program (TV Electric)

TERA Tenera, L.P.

TRT Technical Review Team (NRC)

VPB Vendor Program Branch (NRC)

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1.0 INTRODUCTION

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' In October 1984, TU Electric established the Comanche Peak Response Team-O (crat) ta v 1u t 4 =# > ta t a v 6 a rais d at casts ad to Pr Par -  !

i plan for resolving those issues. The Comanche Peak Response Team (CPRT)  ;

-program plan was developed and submitted to the NRC.  !

l j In mid-1986, TU Electric performed a qualitative and quantitative review j of the preliminary results of the Comanche Peak Response Team (CPRT) l (References 52 and 53). This review identified that the Comanche Peak i l Response Team (CPRT) findings were broad in scope and included each i

discipline. TV Electric decided that the appropriate method to correct l 1

the issues raised and to identify and correct any other issues that  !

potentially existed at CPSES would be through one integrated program  !

rather than a separate program for each issue. TU Electric decided to l

! initiate a comprehensive Corr I

! CPSESsafety-relateddesigns.ycgiveActionProgram(CAP)tovalidatethe

• The Corrective Action Program (CAP) j

!, has the following objectives: l j o Demonstrate that the design of safety related systems, structures  ;

j and components complies with licensing commitments. l o Demori'; rate that the existing systems, structures and components  !

i are in compliance with the design or develop modifications which i will bring systems, structures and components into compliance with . l 1 design. j j ,

, o Develop procedures, an organizational plan and documentation to l l maintain compliance with licensing commitments throughout the life 3

of CPSES.

! The Corrective Action Program (CAP) is thus a comprehensive program to  ;

i validate both the design and the hardware at CPSES, includin resolution j of specific Comanche Peak Response Team (CPRT) and external ssues, j

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] 1 Portions of selected non-safety related systems, structures and l i components are included in the Corrective Action Program (CAP). 1

] These are Seismic Category !! systems, structures and components, l

{ and fire protection systems.

2 NSSS design and vendo- hardware design and their respective QA/QC programs are reviewed by the NRC independently of CPSES and are

, not included in the Corrective Action Program (CAP) as noted in i SSER 13; however, the design interface is validated by the CAP.

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! TU Electric contracted and provided overall management to Stone & Webster  !

Engineering Corporation (SWEC), Ebasco Services Incorporated (Ebasco), and j Impe11 Corporation (Impe11) to implement the Corrective Action Program  ;

-(CAP), and divided the CAP into eleven disciplines as follows: i i

l Diteinline gaggonsible Contractor i Mechanical SWEC l - Systems Interaction Ebasco  :

- Fire Protection Impe11 l l Civil / Structural SWEC t Electrical' SWEC Instrumentation & Controls SWEC ,

1 1.arge Bore Piping and Pipe Supports SWEC-PSAS

! Cable Tray and Cable Tray Hangers Ebasco/Impe11 Conduit Supports Trains A, B. & C > 2" Ebasco l Conduit Supports Train C 1 /" Impell l Small Bore Piping and Pipe Supports SWEC PSAS  ;

Heating, Ventilation and Air Conditioning Ebasco i 1

(HVAC) l j Equipment Qualification Impe11 l

! A Design Basis Consolidation Program (DBCP) (Reference 10) was developed l to define the methodology by which Ebasco performed the design and -  !

i hardware validation. The approach of this Design Basis Consolidation  !

l Program (08CP) is consistent with other contractors' efforts and products.

A The design validation portion of the Corrective Action Program (CAP)

J V identified the design related licensing commitments. The design criteria  ;

{ were established from the licensing commitments and consolidated in the j Design Basis Documents DBDs). The 080s identify the design criteria for  !

the design validation e fort. If the existing design did not satisfy the i design criteria, it was modified to satisfy the des'gn criteria. The i design validation effort for each of the eleven Corrective Action Program l I

(CAP) disciplines is documented in Design Validation Packages (DVPs). The  :

DVPs provide the documented assurance (e.g., calculations and drawings) I 1 that the validated design meets the licensing commitments, including j

! resolution of Comanche Peak Response Team (CPRT) and external issues. ,

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The design validation effort revised the installation specifications to reflect the validated design requirements. The validated installation specifications also contain the inspection requirements necessary to .

assure that the as built hardware complies with the validated design.

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l The hardware validation portion of the Corrective Action Program (CAP) is implemented by the Post Construction Hardware Validation Program (PCHVP),

which demonstrates that existing systems, structures, and components are O in compliance with the installation specifications (validated design), or identifies modifications that are necessary to bring the hardware into compliance with the validated design.

The results of the performance of the Corrective Action Program (CAP) for t each discipline are described in a Project Status Report (PSR). This PSR describes the results for the HVAC portion of the Corrective Action Program (CAP).

Ebasco has performed a comprehensive design validation of safety-related HVAC duct, HVAC supports and HVAC systems for CPSES Unit 1 and Common in order to demonstrate that the design complies with licensing comitments.

Ebasco is performing the Post Constructfon Hardware Validation Program (PCHVP) to demonstrate that the as-built safety related HVAC duct, HVAC d

supports and HVAC syttems comply with the validated design. The validation process was conducted in accordance with the Ebasco Design ,

Basis Consolidation Program (0BCP), which controls the implementation of the Ebasco portion of the TV Electric Corrective Action Program (CAP).

The HVAC portion of the Corrective Action Program (CAP) is shown schematically in Figure 1-1. The design bases for safety related HVAC duct, HVAC supports and HVAC systems are contained within a consolidated set of CPSES Design Basis Documents (DBDs) (References 11 and 28 to 41). .

The methodology used for implementing both the design and hardware related validations for CPSES Unit 1 and Common safety-related HVAC duct, HVAC supports and HVAC systems is presented in this Project Status Report O (PSR). ,

This Project Status Report (PSR) for safety related HVAC duct, HVAC 4 supports and HVAC systems describes the validation effort from the early stages of design criteria establishment through the development and implementation of the detailed design and design control procedures. This i Project Status Report (PSR) traces the updating of the procurement and installation specifL:ations, construction procadures and Quality Control

((C) inspection procedures; the implementation of the Post Construction Hardware Validation Program (PCHVP) used to validate the as built 4

safety-related HVAC duct, HVAC supports and HVAC systems design; and the completion of the CPSES Unit 1 and Common HVAC Design Validation Packages (DVPs).

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i FIGURE 1-1 O ccRRterIvr ^crICH >'oGa>= (cx>>

HVAC IEefrIrl LICDGDG FSAR i CDMrINDfIS CDER L2C2NSDG DOCDENIS  :

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DEVEICP IEEIGN BASIS ExXDENIS (DBDs) o PERFCFM DESI@ =

CPRT (CAP & QOC) ISSUES l

=

VALIDATICH EXTE NAL ISSUIS:

-NRC (SRT, SIT, TRr, CAT)  ;

-CIWA (IAP)  ;

-CASE

" -ASIE  ;

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-NRC DGPECTICH REKRIS

}ODIFICATICN PKUIRED YES _

DESIQi l

? tooIFICATIcts r

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}G I IP j ,.g HARDWARE VAIIDATICH = RJIID/DEFEC'1 i

MCGRAM (PCHVP) }ODITICATICH l

1 i o FINAL [ESIGH RECENCILIATICH i

4 YES ADDITIONAL VALIDATIN

\ REQUIRED 1 7 l 2

fG 9

rDsL txxuaNtmCH

(CESICN VALIDATICH FAC30GES)

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s 2.0 PURPOSE  !

The purpose of this Project Status Report (PSR) is to demonstrate that the  !

1 O safety related HVAC duct, HVAC supports and HVAC systems in CPSES Unit 1 and Common are in conformance with the CPSES licensing commitments,

satisfy design criteria and will satisfactorily perform their i safety related functions. l J  !

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3.0 SCOPE

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The scope of the HVAC portion of the Corrective Action Program (CAP)

\ implemented for CP ,

SeismicCategory1{ESUnit1gndCommoninclujessafetyrelatedand HVAC duct , HVAC supports and HVAC systems; and Seismic Category !! 2 HVAC duct and HVAC supports. The safety related i

4 HVAC systems are as follows: ,

o Containment Ventilation o Containment Air Cleanup ,

o Safeguards Building Ventilation o Diesel Generator Area Ventilation ,

o Electrical Area HVAC i o Mainsteam and Feedwater Area Air Conditioning o Auxiliary Building Ventilation o Fuel Handling Building Ventilation o Control Room Air Conditioning o Uncontrolled Access Area Ventilation o Primary Plant Ventilation  ;

1 l o Safety Chilled Water i o Service Water Intake Structure Ventilation o Uninterruptible Power Supply Area Air Conditioning i

1 Portions of the above systems are non safe'ty-related.

i 1 Systems, structures and components that are designed and i C constructed to withstand the effects of the Safe Shutdown Earthquake (SSE) and remain functional are designated as Seismic  !

Category I in accordance with the requirements of NRC Regulatory Guide 1,29 (Reference 3).

2 Those portions of systems, structures or components whose continued function is not required, but whose failure could reduce t the functioning of any Seismic Category I system, structure or component required to satisfy the requirements of NRC Regulatory Guide 1.29 to an unacceptable safety level or could result in incapacitating injury to occupants of the control room, are i designated as Seismic Category !! and are designed and constructed i so thtt the Safe Shutdown Earthquake (SSE) would not cause such f ailure.

4 3 Unless otherwise noted, HVAC duct includes the HVAC plenums and HVAC air handling units; and HVAC supports include HVAC duct supports and HVAC equipment supports.

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Non safety-related, non seismic HVAC duct and HVAC supports are addressed as part of the Systems Interaction Program (SIP) and are i Project Status Report described (Psa) (a r in the7)Systems (5=aai Interaction "t ^ ta thProgram (SIP)i Psa)-

O r ac " ch "'ci  ;

l The HVAC portion of the CPSES Corrective Action Program (CAP) is shown l schematically in Figure 1 1 and is discussed below. The program required:  !

1. Establishment of HVAC duct. HVAC supports and HVAC systems design criteria which comply with licensing comitments.

2. Development of the Design Basis Documents (080s) for HVAC duct,  !

HVAC supports and HVAC systems, which contain the design criteria.  !

3. Implementation of design and hardware validations, consisting of analyses, identification and implementation of necessary modifications, and field verifications as identified in the Post Construction Hardware Validation Program (PCHVP). The as built ,

configuration of HVAC duct, HVAC supports and HVAC systems is validated to the design by Quality Control (QC) inspections, engineering walkdowns and engineering evaluations.

4. Resolution of the design and hardware related issues of CPSES HVAC duct, HVAC supports and HVAC systems and implementation of a }

Corrective Action Program (CAP) for closure of these issues. .

These issues include Cemanche Peak Response leam (CPRT) and l external issues (See Section 4.0).

5. Development of validated design documentation to form the basis O for configuration control of CPSES Unit I and Common HVAC duct, HVAC supports and HVAC systems. The validated design I

documentation (calculations, design drawings and specifications) and Design Basis Documents (080s) can be utilized by TU Electric ,

to facilitate operation, maintenance and future modifications following issuance of an operating license.  !

Within Section 5.1, Section 5.1.1 describes the methodology by which the l CPSES licensing commitments were identified, the design criteria were  :

established and the procedures and the Design Basis Documents (080s) were developed.

4 Those portions of systems, structures or components whose cr.ntinued function is not required, and whose failure will not reduce the functioning of any Seismic Category I system, structure or component required to satisfy the requirements of NRC Regulatory Guide 1.29 to an unacceptable safety level and will not result in incapacitating injury to occupants of the control room, are designated as non seismic.

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Section 5.1.2 describes the design validation process, interfaces with other disciplines and the final reconciliation process.

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(" Section 5.1.3 describes the Post Construction Hardware Validation Program (PCHVP) prot.ess and the procedures for field validation (inspections, engineering walkdowns and engineering evaluations) being implemented to validate that the as-built HVAC duct, HVAC supports and HVAC systems are in compliance with the dasign documentation.

Section 5.2 presents a sumary of the design validation and Post Construction Hardware Validation Program (PCHVP) resul^.s. including the hardware modifications resulting from the HVAC portion of the Corrective Action Program (CAP).

Section 5.3 describes the Quality Assurance (QA) Program implemented for the validation process, including the Engineering Functional Evaluation (EFE) audits and the TV Electric Quality Assurance (QA) audits.

Section 5.4 describes the transfer of a complete set of the validated design documentation and design procedures to TU Electric Comanche Peak Engineering (CPE). This set of documentation and procedures can provide the basis for CPSES configuration control throughout the life of the plant.

Appendix A of this Project Status Report (PSR) describes the details of -

Corrective Action Program (CAP) resolution of the HVAC related Comanche Peak Response Team (CPRT) and external issues.

1 O Appendix B of this Project Status Report (PSR) describes the details of V resolutions of issues identified during the HVAC portion of the Corrective Action Program (CAP). These are issues that have been determined to be reportable under the provisions of 10CFR50.55(e). These issues are identified in Significant Deficiency Analysis Reports (50ARs) initiated by TU Electric.

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l 4.0 SPECIFIC ISSUES 7 The HVAC Corrective Action Program (CAP) resnived all related Comanche (V Peak Response Team (CPRT) issues and externu issues. This section presents a listing of HVAC related issues aedressed in this Project Status Report (PSR). Technical review, resolution, corrective and preventive actions for Comanche Peak Respcase Team (CPRT) and external issues are described in Appendix A. Technical review, resolution, corrective and

, preventive actions for issues identified during the performance of the Corrective Action Program (CAP), which were determined to be reportable under the provisions of 10CFR50.55(e), are described in Appendix B.

I The issues contained in Subappendices Al through A7 and A19 were raised by the Comanche Peak Response Team (CPRT) (References 49, 50 and 54). Issues A4 and A5 were also raised by the NRC la inspection Reports. The issues contained in Subappendices AS through All were raised by the NRC in Inspection Reports. The issue contained in Subappendix A12 was raised by the NRC Construction Assessment Team (CAT). The issues contained in Subappendices A13 and A14 were raised by CASE. The issue contained in Subappendix A15 was raised by the NRC Technical Review Team (TRT). The issues contained in Subappendices A16 and A17 are included in the CYGNA Energy Services (CYGNA) Review Issde List (RIL) (Reference 51). The first nine issues contained in Subappendix A18 are HVAC issues which were identified by the original HVAC designer to Ebasco. The last issue conta19ed in Subappendix A18 was raised by the Comanche Peak Response Team -

(r.PRT) (Reference 55). The issues contained in Subappendices A2 through Ad, A7, A10 and A12 through A18 were part of the conditions reported as Significant Deficiency Analysis Report (50AR) CP 85 54 in letter number O Txx-so*> dated Saata= der 25 2985 fro = 'u ci ctric to th "ac-Comanche Peak Response Team (CPRT) and external issues are listed below (issue numbers correspond to subappendix numbers in Appendix A):

Issue No, Issue Title Al Determination of Heat Lnads for Equipment Sizing A2 Lack of Construction Details for Fabrication and Installation of Ducts and Plenums l A3 Inaccurate HVAC Duct Support Detail Drawings and Their Effect on the Duct Support Designs A4 Inadequate Program for the Installation and Quality Control l (QC) Verification of HVAC Duct Supports 1 A5 Groove Welds l A6 Lack of Documentation for Re:eipt Inspection by the Original l HVAC Duct Support Contractor i A7 Insufficient Thread Engagement and Pretensioning of Richmond Insert Bolts on HVAC Duct Supports 18 Battery Room Ventilation

, A9 Battery Room Explosion Proof Thermostats l l A10 Inspection Reports Dated Prior to issue of As Built I l Drawings l 4-1 i 1

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Issue No. Issue Title All Welder Qualification

() A12 A13 NRC CAT Inspection Results Seismic Design of HVAC Supports l

A14 HVAC Duct Axial Restraint .

1 A15 Seismic Interaction of HVAC Duct ,

A16 CYGNA Conduit and Cable Tray issues A17 CASE /CYGNA Cable Tray Issues A18 Othor HVAC !ssuet A19 Environmental Conditions and Requirements i

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!ssues identified during the performance of the HVAC portion if the Corrective Action Program (CAP) which have been determined to oe i

reportable under the provisions of 10CFR50.55(e) are listed below (issue  !

numbers correspond to subappendix numbers in Aopendix B):

'1 issue No. Issue Title j j B1 50AR CP 87-124 Xomox Valves B2 SDAR CP 88 08 Class lE Battery xocs l Temperature  !

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5.0 CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS This section of the Project Status Report (PSR) addresses the program O methodology for the HVAC portion of the Corrective Action Program (CAP),

including the establishment of design criteria in conformance with CPSES licensing commitments, the development of procedures, the implementation of the design validation process and the Post Construction Hardware Validation Program (P(HVP), as well as the results of the HVAC portion of the Corrective Action Program (CAP) and corrective and preventive actions implemented to assure that the HVAC design and hardware remain in compliance with the licensing commitments throughout the life of the plant.

5.1 METHODOLOGY AND WORX PERFORMED The methodology and work performed by Ebasco in implementing the HVAC portion of the Corrective Action Program (CAP) for HVAC duct, HVAC supports and HVAC systems are discussed in the following sections.

5.1.1 Licensing Commitments, Design Criteria, Procedures and Design Basis Documents (DBDs)

The licensing comitments for the HVAC duct, HVAC supports and HVAC systems were identified by Ebasco through an e'xtensive review of CPSES licensing documentation (such as the FSAR, CPSES Safety Evaluation Report -

(SER) and its OJpplements (SSERs), NRC Regulatory Guides, NRC Inspection and Enforcement Bulletins, the AISC "Specification for the Design of Steel Structures" (Referer ce 6), and TV Electric /NRC correspondence). Based on these licensing comitments, design criteria were established which set O forth requirements for validation of HVAC duct, HVAC supports, and HVAC systems. The design criteria are documented in the Design Basis Documents (DBDs) (See Table 5-1). In addition, Ebasco developed design procedures for HVAC duct and scnports (See Table 5-1). These Design Basis Documents (DBDs) and design procedures are based on the following:

o Design criteria o Resolution of Comanche Peak Rasponse Team ' ' 'T) and external issues o Ebasco experience gained through the design of HVAC duct. HVAC l supports and HVAC systems for several recently licensed and l operating United States nuclear power plants o Regulatory and Professional Society Guidance such as applicable codes and standards 5-1

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The results of extensive testing cnd engineering stedias (det;iled analytical evaluations) were implemented in the procedures used in the HVAC duct and HVAC support design validation.

5.1.1.1 Verification of Design Criteria, Procedures and Design Basis Documents (DBDs)

To provide added conficence in the conservatism of the analytical methods and design criteria as defined in the Design Basis Documents (DBDs) and design procedures and in the design adequacy of the HVAC duct and HVAC supports, engineering studies were performed, and a comprehensive testing program was conducted. The testing program provides confirmation of the HVAC duct and duct support combined seismic response, design criteria (e.g., duct allowable stresses) and analytical methods. The engineering studies were performed to develop and substantiate the methodology defined in the HVAC design procedures.

Testina Proaram The objectives of the testing program were:

1. To confirm, through correlation with frequency and static testing of full-scale duct and individual duct components, that the duct design parameters, namely the duct stiffnesses'and strength, used in the design validation were conservative; -

2. To provide qualitative and quantitative data on the behavior and load capacity of the duct when subjected to loads up to and above the CPSES design criteria. This data is then used to support the O analytical methods used in design validation.

The duct frequency and static tests were performed on full-scale samples representative of as-built duct spans and configurations. The samples used in the static tests contained gaskets, joints and openings similar to the as-built conditions.

Duct Freauency Tests In 1981, three (3) different test specimens representative of CPSES Unit 1 and Common duct sizes and spans were subjected to random excitation in the two transverse directions of the duct specimen in order to determine their resonant frequencies and mode shapes. The tests were performed at the Corporate Consulting and Development Company, Ltd. (CCL) testing laboratory in accordance with the CCL test procedure (Reference 18). The main objective of the tests was to obtain the parameters that determine the stiffnesses of the duct to be used in the structural analysis of the duct and duct support combination in the design validation. The mathematical representation of the duct properties was derived from the measured duct frequencies to assure their adequacy in predicting the duct frequencies in the analysis. The results of the duct frequency test evaluation were reported in the Corporate Consulting and Development Company, Ltd.

(CCL) Test Report (Reference 19) and have been reviewed and validated by Ebasco (Reference 13).

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Duct Static Tests C-)

'" S$7 '"" c ' d"c' 'a*c'"*"' **r* a r**d which provided data for the determination of the ultimate strength of the duct as constructed at CPSES Unit 1 and Common. These data were used to derive the allowable stress limits for the design validation of the duct. A total of 67 duct specimens were tested to destruction with loads and deformations continuously recorded. The duct specimens included straight, T-branch and elbow configurations. Several specimens had openings similar tn the as-built conditions of duct registers and grills, to simulate the effects of the openings on the dnct strength. The duct specimen sizes were representative of CPSES Unit 1 and Common configurations. The specimens were subjected to bending loads; axial loads with simultaneous application of internal pressure; and combined loading which included the simultaneous appilcation of bending, axial and internal pressure loads. These tests were performed by Corporate Consulting and Development Company, Ltd. (CCL) at their testing laboratory in accordance with the Ebasco specification (Reference 15) and the Ebasco approved CCL test procedure (Reference 4).

The following conclusions were determined from the duct frequency and duct static test results:

1

1. The duct stiffnesses and strength used in the design validation ,

were conservative. '

2. The load capacities and data collected confirmed the analytical Q methods used in the riesign validation.

Enoineerino Studies 1 Engineering studies were performed by Ebasco during the development of the HVAC design procedures and throughout the design validation process. The objectives of these engineering studies were:

1. To establish and document the basis of design criteria; 1

2. To provide the basis, through detailed analytical evaluations, for I engineering assumptions and technical methods;

3. To resolve, through detailed analytical evaluations, specific Comanche Peak Response Team (CPRT) issues and external issues;  !

4. To provide added confidence in the conservatism of the analytical '

methods and design criteria as defined in the procedures.

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In addition, technical audits have been perfo.med to provide additional assurance that tiie design criteria are technically correct and embody the s) HVAC licensing commitments, and that all HVAC related Comanche Peak Response Team (CPRT) and external issues have been resolved. To assure that the licensing commitments related to HVAC design have been identified, and appropriate design criteria have been established, the Ebasco Corporate Quality Assurance (QA) and the Comanche Peak Response Team (CPRT) conducted audits and overview, respectively. Ebasco Quality Assurance (QA) audits were performed as described in Section 5.3. The Comanche Peak Response Team (CPRT) overview is being performed by the Engineering Functional Evaluation (EFE) and TU Electric Quality Assurance (QA) Technical Audit Program (TAP) as described in Section 5.3.

The TV Electric Quality Arsurance (QA) Technical Audit Program (TAP) is auditing the Corrective Action Program (CAP) to assure that the design criteria are reconciled with the licensing commitmonts. Ebasco's resolution of the Comanche Peak Response Team (CPRT) and external issues is described in Appendix A of this Project Status Report (PSR). Ebasco's resolution of the issues identified during the performance of the Corrective Action Program (CAP) is described in Appendix B of this Project Status Report.

5.1.2 Design Validation Process Sections 5.1.2.1 and 5.1.2.2 discuss the validation process for HVAC duct and HVAC supports. Section 5.1.2.3 discusses the validation process for HVAC systems. Section 5.1.2.4 discusses the resolution of HVAC duct, HVAC supports and HVAC systems related design issues. Section 5.1.2.5 pV discusses technical interfaces with other organizations. Section 3.1.2.6 discusses the final reconciliation process.

5.1.2.1 Design Validation Input Data for HVAC Duct and HVAC Supports The following documents were the source of input information for the design validation process:

1. As-Built Drawings: As-built information was obtained by engineering walkdowns conducted by experienced Ebasco personnel ,

trained in accordance with Field Verification Methods (FVMs) )

(References 14 and 23). The results were used to create as-built drawings of the HVAC duct and HVAC supports. To provide additional assurance of the accuracy of the as-built drawings, TU Electric Quality Control (QC) personnel verified these drawings to the as-built hardware on a sample basis as specified in the Field Verification Methods (FVMs) (References 14 and 23) and in i accordance with an approved Quality Control (QC) inspection l procedure (Reference E). These drawings provide information for determining the duct routing, the location of the supports on the I duct run, support identification number, number and size of duct l 5-4 i O

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supported by the support, location of duct transitions (change in direction and/or size), location of in-line components and support geometry (member sizes, dimensions, anchor bolt information, weld J joints and orientation of the support relative to the duct).

2. HVAC Installation Specification: The HVAC installation specification (Reference 1) provides validated design input data including design internal air pressure. This specification also provides installation details used in the design validation process.

3. Amplified Response Spectra (ARS): The ARS (CPSES seismic design information) was used as input to the design validation of the HVAC duct and HVAC supports.

5.1.2.2 Analytical Methods for Design Validation of HVAC Ouct and HVAC Supports The as-built drawings of HVAC duct and HVAC supports were used to develop mathe.aatical models of the supports and/or the supports and duct 6 combination. Hand calculations and/or computer analyses were performed to determine the individual design loads and also the comHned design loads on supports and dact in accordance with the design criteria as specified in the Design Basis Document (DBD) (Reference 11). The loads determined were deadweight loads, pressure loads, thermal loads and seismic loads.

Deadweight loads include the weight (deadweight) of HVAC supports, HVAC duct, and in-line components in HVAC duct, such as dampers. These weights were determined from the as-built drawings and vender documentation (e.g.,

O HVAC duct span length, configuration, insulation).

Pressure loads are derived from HVAC duct internal design air pressures which were determined during the HVAC sy:tems design validation (See Section 5.1.2.3) and are provided in the HVAC installation specification (Reference 1).

The effects of operating thermal loads and accident thermal loads were validated in an engineering study. The result showed that, due to the presence of gaskets, flexible companion flanges and duct expansion joints, combined with the flexibility of base angles and anchorages, the HVAC duct and HVAC supports can accomodate the thermal displacements without reduction in seismic load resistance or loss of function.

The seismic load is produced during the Operating Basis Earthquake (OBE) or the Safe Shutdown Earthquake (SSE) as defined by the CPSES Amplified Response Spectra (ARS). HVAC duct and HVAC support seismic loads were determined by using either of the following analytical methods:

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Eguivalent Static Method (ESM)

The Equivalent Static Method (ESH) utilized an individual model of O each support for support design validation. After generating a three dimensional computer model of the support, which included t contributory duct weight (deadweight), a frequency analysis was performed to obtain the fundamental (lowest) frequency of the support in the transverse,1cngitudinal and vertical directions.

This frequency was then combined with the calculated fundamental frequency of the duct in the corresponding direction to calculate the combined frequency of duct and support.

The combined frequency was used to determine the seismic l acceleration value in each direction from the Amplified Response Spectra (ARS). This acceleration from the ARS was conservatively

increased by 50 percent, t.nd used to determine the equivalent static loads applied to the support in each direction. ,

Resoonse Soectra Method (RSM)

Design validation of HVAC duct and HVAC supports by the Response Spectra Method (RSM) utilized three dimensional models.

. Significant components of the HVAC duct and HVAC supports were modeled in sufficient detfil to accurately predict the combined  !

duct and support response to the design loads. More .

specifically, duct components (including straight ducts, bends,  !

tees, crosses, and reducers) and support components (including ,

, duct-to-support connections, support members, member connections i and support anchorages) were ir.cluded in the models. Significant O

i coaaectioa ecceatricities existias ia HvaC duct aad HvaC suR9erts l 1

were also modeled. A detailed description of the modeling 1 procedures used in the Response Spectra Method (RSM) approach is provided in References 8, 9 and 16.

Using the above model, the dynamic responses of HVAC duct and HVAC 1 supports, due to seismic loading, were calculated. Separate analyses were performed for the Operating Basis Earthquake (062)

I Response includes accelerations, displacements, forces, loads

and stresses.  !

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and Safe Shutdown Earthquake (SSE) load cases using structural damping values in accordance with the design criteria specified in the Design Basis Docurent (DBD) (Reference 11). All frequencies pd of vibrations up to 33 cycles per second were considered in the analyses. The modal responses for each frequency were comoined in accordance with NRC Regulatory Guide 1.92 (Reference 22). The N-S, E-W and vertical directions of earthquake were considered to act simultaneously and the responses were combined using the square root of the sum of the squares (SRSS) method.

The design criteria as specified in the Design Basis Document (DBD)

(Reference 11) were utilized in combining the individual loads for Seismic Category I and Seismic Category II HVAC duct and HVAC supports. The resulting stresses were then compared to the allowable stress limits specified in the Design Basis Document (DBD) (Reference 11). Modifi-cations were developed for the HVAC duct and HVAC supports which did not comply with the allowable stress limits. These modifications assure that these HVAC duct and HVAC supports comply with the allowable stress limits as specified in the Design Basis Document (DBD) (Reference 11). Hardware modifications are being implemented.

5.1.2.3 Validation of HVAC Systems Design The design validation of the HVAC systems was performed by comparison of the design documents (calculations, drawings and specifications) with the -

design criteria specified in the Design Basis Documents (DBDs) (References 28 through 41). Where the existing design did not satisfy the design criteria, it was modified to satisfy the design criteria. Hardware i

] modifications are being implemented. The validation is documented in the HVAC systems Design Validation Package (DVP) which contains the following:

o Design Basis Documents (DBDs) which specify the design criteria and how the criteria have been satisfied i o Design Documents (i.e., calculations, drawings and specifications) o Other related documents (e.g., design interface requirements, Significant Deficiency Analysis Reports (SDARs), and Comanche Peak Response Team (CPRT) and external issues resolution documents).

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Calculations i Seventy-three (73) new safety-related HVAC calculations were developed O

which included: '

o Heat load calculations for the applicable plant operating modes, which included heat loads due to solar transmission and radiation, occupancy, electrical heat losses (including electrical equipment, ,

motors, lighting and cables) and mechanical equipment and piping  :

o Temperature and relative humidity calculations for the applicable l plant operating modes l 1

o Calculations for design air and chilled water flow rates which form the basis for system balancing j o Cooling coil and chiller heat removal calculations l o Refrigeration system cooling requirements o HVAC process set point calculations Drawinos 1

CPSES Unit 1 and Common HVAC Systems flow diagrams and duct layout  !

drawings were reviewed and validated to comply with the design criteria as specified in the Design Basis Documents (DBDs) (References 28 through 41). The following items were considered in the review of the drawings:

O o Consistency with the system design ca,cu,ations  ;

o Nuclear safety classification o Nuclear safety classification boundary isolation configuration o HVAC equipment redundancy, and valve / damper configuration for compliance with the single failure criterion o Interface requirements with other fluid systems Review of HVAC Eautoment Caoacities Procurement specifications and vendor component documentation were reviewed for interface compliance with the validated system design. The heat removal capacities of the HVAC equipment such as cooling coils, air conditioning equipment and refrigeration chillers were validated based on  !

design flow rates and temperatures. The vendor documentation was also reviewed to provide validated design inputs to other organizations for i interfacing activities. I 5-8 j O

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5.1.2.4 Resolution of HVAC Duct, HVAC Supports and HVAC Systems Related Design Issues O The issues listed in Section 4.0 (described in Appendix A and Appendix B) were evaluated by Ebasco. Implementation of the Ebasco design and design control procedures resobed the HVAC issues. The resolutions were incorporated into the HVAC installation specification and the Design Basis Documents (DBDs), as well as the CPSES Unit I and Common Quality Control (QC) inspection procedures and construction procedures. The resolution of these issues was reviewed by TV Electric Comanche Peak Engineering (CPE).

The issue resolution and implementation processes were as follows:

1. For each issue that affected the HVAC duct, HVAC supports and HVAC systems validation effort, Ebasco reviewed the associated documentation to gain an understanding of the background. Ebasco then defined their understanding of the issue;

2. With the issue thus defined, Ebasco developed and executed an action plan to resolve the issue (Reference 43); and

3. The resolutions were implemented in appropriate Ebasco project procedures used for the HVAC portion of the Corrective Action Program (CAP). Compliance with these procedures is assured by the Ebasco Quality Assurance (QA) Program.

Additionally, walkdowns of the HVAC duct and HVAC supports were conducted l to obtain as-built information for CPSES Unit 1 and Common. The walkdowns .

were conducted by experienced Ebasco persor.nel +. rained in the Field O, Verification Methods (FVMs) (References 14 and 23). The as-built l

information was reviewed by Ebasco to determine whether tSere were additional issues related to the functional behavior of the HVAC duct, HVAC supports or HVAC systems that should be evaluated oy the Corrective Action Program (CAP).

i 5.1.2.5 Interfaces The HVAC validation process involved internal interfaces among Ebasco design disciplines, as well as external interfaces with TV Electric and other organizations involved in the Corrective Action Program (CAP).

Organizational interfaces as shown in Figure 5-1 include those with other Ebasco disciplines, TV Electric, SWEC-PSAS, Westinghouse, SWEC and Impell. Interfaces with these organizations are procedurally controlled to assure:

o Consistency of design criteria o Completeness of the information incorporated in each Design Validation Package (DVP) 5-9 0

o Proper transfer of design data between interfacing organizations o Uniform application of design control procedures o Coordination of corrective and preventive actions 5.1.2.6 Final Reconciliation Process The purpose of the final reconciliation process is to consolidate the design validation results, hardware modifications, preoperational test results and inspection documentation to assure consistency of the HVAC design. The final reconciliation of HVAC design incorporates the '

following:

o The Post Construction Hardware Validation Program (PCHVP) results o Resolution of the HVAC hardware related Comanche Peak Response Team (CPRT) and external issues.

Final reconciliation also includes confirmation that the interfacing organizations have accepted the HVAC results as compatible with their validated design. Interfacing organizations are depicted on Figure 5-1.

In addition, open items, observations, and deviations related to the HVAC portion of the Corrective Action Program (CAP) that were identified by the TU Electric Technical Audit Program (TAP) and Engineering Functional Evaluation (EFE) are resolved prior to the completion of the final reconciliation. Open items from TU Electric Significant Deficiency O Analysis Reports (SDARs) (10CFR50.55(e)) are also resolved during the final reconciliation. At the conclusion of final reconciliation, the CPSES Unit I and Common Design Validation Packages (DVPs) are compiled.

5.1.3 Post Construction Hardware Validation Program (PCHVP)

The Pcst Construction Hardware Validation Program (PCHVP) (Raference 12) is the portion of TV Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware.

The Post Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 5-2.

The input to the Post Construction Hardware Validation Program (PCHVP) is contained in the installation specifications. The installation specifications implement the licensing commitments and design criteria of the Design Basis Documents (DBDs), which were developed during the Corrective Action Program (CAP) design validation process.

Final acceptance inspection requirements identified in the validated installation specifications were used to develop the Post Construction Hardware Validation Program (PCHVP) attribute matrix. This matrix is a complete set of final acceptance attributes identified for installed ,

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l hardware. The Post Construction Hardware Validation Program (PCHVP), by.

either physical validations or through an engineering evaluation methodology, assures that each of the attributes defined in the attribute O matrix is validated.

Physical validation of an attribute is performed by Quality Control (QC) inspection or engineering walkdown, for accessible components. Quality ,

. Control (QC) inspections and engineering walkdowns are controlled by appropriate Field Verification Method (FVM) procedures.

The Post Construction Hardware Validation Program (PCHVP) engineering evaluation depicted in Figure 5-2 is procedurally controlled to guide the '

Corrective Action Program (CAP) responsible engineer through the evaluation of each item on the attribute matrix to be dispositioned by the i ongineering evaluation method. Dispositions of each attribute will be clearly documented. If the technical disposition of the final acceptance attribute is "not acceptable" or the attribute cannot be dispositioned based on available information, an alternate plan consisting of additional evaluations, testing, inspections /walkdowns or modifications as necessary will be developed to demonstrate and document the acceptability of the attribute.

Recommendations from the Comanche Peak Response Team (CPRT) effort comprise a significant portion of the evaluation. A major component of the Comanche Peak Response Team (CPRT) program has been the inspection of a comprehensive, random sar.ple of existing hardware using an independently derived set of inspection attributes. The inspection was performed and the results were evaluated by Third Party personnel in accordance with Appendix E to the Comanche Peak Response Team (CPRT) Program Plan (Reference 42). The scope of the inspection covered the installed -

safety-related hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished ,

product). Samples of these populations were inspected to provide ,

reasonable assurance of hardware acceptability in accordance with Appendix l D to the Con nche Peak Response Team (CPRT) Program Plan.

Corrective action recomendations were made to TU Electric based on the I evaluated findings when a Construction Deficiency existed, an Adverse i Trend existed, or an Unclassified Trend existed, as defined in accordance with Appendix E to the Comanche Peak Response Team (CPRT) Program Plan.

The Post Construction Hardware Validation Program (PCHVP) assures that all i Comanche Peak Response Team (CPRT) recommendations are properly dispositioned. L Figure 5-2 illustrates that during the evaluation of a given attribute

! from the Post Construction Hardware Validation Program (PCHVP) attribute matrix, the initial task of the Corrective Action Program (CAP) responsible engineer is to determine if any of the following statements l

are true I '

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a. The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT)

b. Design validation resulted in a change to design or to a hardware final acceptance attribute that is more stringent than the original acceptance attribute or the Comanche Peak Response Team (CPRT) did not inspect the attribute

c. Design validation resulted in new work, including modification to existing hardware If the Comanche Peak Response Team (CPRT) had no recommendations and Items

b. or c. above do not apply, the attribute under consideration will be accepted. This conclusion is justified by the comprehensive coverage of the Comanche Peak Response Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective. The attribute matrix is then updated to indicate that neither the engineering walkdown nor Quality Control (QC) l inspection of the attribute is necessary. A completed evaluation package -

is prepared and forwarded to the Comanche Peak Engineering (CPE) organization for concurrence. The evaluation package becomes part of the Design Validation Package (DVP) after Comanche Peak Engineering (CPE) concurrence is obtained.

If any of the three statements above are true, it is assumed that the final acceptance attribute must be further evaluated as follows: )

Determine Attribute Accessibility l O

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The Corrective Action Program (CAP) responsible engineer will '

determine if the attribute is accessible. If the attribute is  !

accessible, a field validation of the item's acceptability will be I performed and documented in accordance with an approved Field Verification Method (FVM).

If the Corrective Action Program (CAP) responsible engineer reaches the conclusion that the attribute is inaccessible, an .

engineering evaluation will be conducted by technical disposition I of available information. l After completing the attribute accessibility review, the Corrective Action Program (CAP) responsible engineer will update the attribute matrix, as necessary, to reflect the results of that .

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Technical Disoosition The Corrective Action Program (CAP) responsible engineer km) identifies the data to be considered during the subsequent technical disposition prccess. Examples of such items used in this disposition may include, but are not limited to: -

o Historical documents (e.g., specifications, procedures and inspection results) o Comanche Peak Response Team (CPRT) and external issues-o Construction practicas o Quality records o Test results o Audit reports o Authorized Nuclear Inspector (ANI) records o Surveillance reports l o NCRs, ors, SDARs and CARS o Inspections conducted to date o Results of Third Party reviews o Purchasing documents o Construction packages l

o Hardware receipt inspections After compiling the data identified as pertinent to the attribute, the technical disposition will be performed. The actual steps and sequence of actions required for each technical disposition will I differ; however, the tangible results from each technical l l

disposition will be consistent. These results will include as a minimum:

o A written description of the attribute; o A written justification by the Corrective Action Program (CAP) responsible engineer for acceptance of the attribute; o A written explanation of the logic utilized to conclude that the attribute nced not be field validated; 5-13 O

o A chronology demonstrating that the attribute has not been significantly altered by redesign; O o 4,1 documents viewed to suP9ert the dispositioai  :

o Concurrence of the acceptance of the attribute's validity by 1 Comanche Peak Engineering (CPE). )

If the Corrective Action Program (CAP) responsible engineer l concludes that the data evaluated represent evidence of the l attribute's acceptability, the conclusion will be documented. The i documentation will be reviewed and approved by Comanche Peak l Engineering (CPE) and filed in the Design Va'lidation Package (DVP). If the Corrective Action Program (CAP) responsible engineer determines that the data reviewed do not provide evidence of the attribute's acceptability, the documentation will explain I why the attribute cannot be accepted and recommend an alternate course of action. The alternate course of action may take various forms such as making the attribute accessible and inspecting it, i or testing to support the attribute's acceptability. This '

alternate plan, after approval by Comanche Peak Engineering (CPE), l will be implemented to validate the attribute.

In summary, the Post Construction Hardware Validation Program (PCHVP) is a i comprehensive process by which each attribute in the PCHVP attribute matrix is validated to the validated <iesign. The TV Electric Technical j Audit Program (TAP) will audit the Post Construction Hardware Validation i Program (PCHVP). This audit program is complemented by the Engineering i Functional Evaluation (EFE) being performed by an independent team O comorised of Stone & Webster, Impell and Ebasco engineering personnel working under the Stone & Webster Quality Assurance (QA) Program and I

subject to oversight directed by the Comanche Peak Response Team's (CPRT)

Senior Review Team (SRT). The Post Construction Hardware Validation Program (PCHVP) will provide reasonable assurance that the validated i design has been implemented for safety-related hardware. ,

1 To provide assurance that the as-built hardware complies with the i validated design, the Post Construction Hardware Validation Program  !

(PCHVP) for HVAC duct, HVAC supports and HVAC systems developed a matrix i of final acceptance attributes (Table 5-2) based on the validated '

installation specification. The Field Verification Methods (FVMs)

(including those used to obtain as-built information utilized as input for the design validation) were then reviewed to determine whether the final acceptance attributes had been addressed. This review concluded that all final acceptance attributes requiring physical validation were included in the Field Verification Methods (FVMs).

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A brief description of the Field Verification Methods (FVMs) implemented

-in the HVAC portion of the Post Construction Hardware Validation Program

( (PCHVP) is given below:

o FVM-029 Field Verification Method (FVM) CPE-EB-FVM-CS-029 (Reference 14) was developed to control the collection of as-built data for CPSES Unit 1 and Comon HVAC duct and HVAC duct supports. Note: This does not include HVAC air handling units, plenums and equipment supports which is included in FVM-066.

o FVM 066 Field Verification Method (FVM) CPE-EB-FVM-CS-066 (Reference 23) was developed to control the collection of as-built data for CPSES Unit 1 and Comon HVAC air handling units, plenums and equipment supports.

o FVM-068 Field Verification Method (FVM) CPE-SWEC-FVM-CS-068 (Reference 27) was developed to control the clearances between various comodity items for CPSES Unit 1 and Comon.

o FVM-112 Field Verification Method (FVM) CPE-EB-FVM CS-112 (Reference 47) was developed to review the as-built conditions of tornado vent

{ fire dampers for CPSES Unit 1 and Comon.  :

Procedures have been developed by other Corrective Action Program (CAP) organizations who are responsible for the installation specifications for the following CPSES Unit 1 and Comon HVAC features:

o HVAC equipment - Mechanical (References 44 and 45) and Impell (Reference 46) o Pining and Iniine Components - Mechanical (References 17 and 44) 5-15 l l

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5.2 RESULTS O s.2.1 oesi9a v>14d>tioa aesuits The validation of the CPSES Unit 1 and Common HVAC design has been completed as described in this Project Status Report (PSR). This effort included:

HVAC Duct and HVAC Supports o Validation of 4109 HVAC supports o Validation of 3871 HVAC duct segments, plenums and air handling units o Development of 4109 as-built drawings for HVAC supports o Development of 3871 as-built drawings for HVAC duct segments, plenums and air handling units o Developeent of 1074 new calculations '/or HVAC supports o Development of 1074 new calculations l'or HVAC duct segments, plenums and air handling units I

o Resolution of 7 Tenera, L.P. (TERA) Discrepancy Issue Reports (DIRs)

O HVAC Systems o Development of 73 new calculations o Review of more than 2400 design drawings to validate HVAC design interfaces o Validation of 11 installation and procurement specifications o Validation of 16 flow diagrams o Resolution of 126 Tenera, L.P. (TERA) Discrepancy Issue Reports (DIRs)  !

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The HVAC design validation identified the following hardware modifications:

HVAC duct and HVAC supports o More than 800 modifications to HVAC duct and HVAC supports resulting from design calculations HVAC Systems o Addition of a safety-related ventilation system for an area containing a safety-related motor control center o Addition of safety-related electric ur'.t heaters in the Class 1E battery rooms to maintain space temrarature at 70'F minimum under required plant operating condition, including loss of offsite power.

o Modifications to the ventilation system which serves the safety related battery rooms to reduce hydrogen build-up o Modifications to the Control Room Air Conditioning System ductwork to provide design air flow.

The design validation effort, in conjunction with the design modifications, results in a HVAC design and associated documentation that is in conformance with CPSES licensing commitments and provides assurance that the HVAC duct, HVAC supports and HVAC systems are designed to perform their safety-related functions.

5.2.2 Post Construction Hardware Validation Program (PCHVP) Results The Post Construction Hardware Validation Program (PCHVP) is being implemented through the validation of final acceptance attributes for systems and components for CPSES Unit I and Common as discussed in Section 5.1.3.

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5.3 QUALITY ASSURANCE (QA) PROGRAM

^

The activities of the HVAC portion of the Corrective Action Program (CAP) in CPSES Unit I and Common were performed in accordance with Ebasco's Quality Assurance (QA) Program, as applicable.

Ebasco implements its Corporate Nuclear Quality Assurance Program described in Ebasco's Topical Report ETR-1001 (Reference 20) which is in conformance with 10CFR50, Appendix B and has been approved by the NRC.

Ebasco's corporate program, ETR-1001, addresses completion of a nuclear power plant including design, procurement, and construction. The corporate Topical Report has been modified to make it project specific; sections that did not apply to the HVAC portion of the Corrective Action Program (CAP) scope of servi:es were deleted. Ebasco's Nuclear Quality Assurance (QA) Program as modified for CPSES Unit 1 and Common has been reviewed and approved by TV Electric's Quality Assurance (QA) organization.

Ebasco developed and issued a Manual of Procedures (Reference 5) specifically related to TU Electric CPSES work. This manual includes Specific procedu;res to supplement the Ebasco standard Engineering, N clear, Project and Procurement Procedure Manuals. The Manual of Procedures includes procedures for the design validation effort performed under Ebasco's Quality Assurance (QA) Program.

Separate procedures are issued to direct the precise organization and format for documents that validate designs. These procedures are issued so calculation documentation will be provided in a uniform and complete C manner. A design validation checklist was developed for this project and has been ut::d to document Ebasco responses to questions identified for design validation in ANSI N45.2.11 and NRC Regulatory Guide 1,64

(Reference 21).

In accordance with this Quality Assurance (QA) Program, Design Basis ,

Documents (DBDs), detailed procedures, and project specific QA Programs covering the essentials of the HVAC program were developed. These documents were distributed to Ebasco supervisory engineers and were readily available to HVAC design validation personnel. The issuance of design cri 9ria, validation procedures and major revisions thereto was followed with training programs for the applicable personnel. In particular, HVAC design validation personnel on the project received

• training in the design procedures and the design control procedures.

An Ebasco Quality Assurance (QA) Manager, who reports through the Quality Assurance Department to Ebasco's Corporate Quality Programs Vice President and who has management experience in auditing and QA Program procedure development for engineering activities, was assigned to the project in the earliest stages of the project. This reporting responsibility assures independence of Quality Assurance (QA) functions. Quality Assurance (QA) 5-18 O .

personnel provide assurance that the QA Program properly addresses project activities and assist project personnel to understand and properly i implement the QA Program.

To date, more than 11,100 man-hours have been expended by Ebasco in l activities directly attributable to the overall Project Quality Assurance (QA) Program (i.e., training, procedure development, auditing, and the project QA supervisory staff).

The adequacy and implementation of the Ebasco Quality Assurance (QA)

Program was extensively audited internally by Ebasco's Quality Assurance (QA) Engineering Audit Group, and externally by TV Electric Quality Assurance (QA) and the Nuclear Regulatory Commission. A total of 13 audits were performed by these organizations from August 1986 to date for CPSES Unit 1 and Common as follows:

Ebasco - Audit Group -3 TV Electric - QA -9 NRC -1 The Ebasco Quality Assurance (QA) Program, the TV Electric Quality Assurance (QA) Program and NRC audits collectively evaluated the technical adequacy of the engineering product (e.g., calculations, drawings and specifications) and assessed the adequacy and implementation of the Ebasco Quality Assurance (QA) Program.

Ebasco's Quality Assurance (QA) Program requires that QA Audits of safety-related project activities be performed periodically. A summary of the audit details for the Ebasco Quality Assurance (QA) Program is provided in Section 5.3.1.

TVElectricQualityAssurance(QA)conductedgechnicalauditsaspartof the TV Electric Technical Audit Program (TAP) . The details of calculations, drawings, procedural compliance and technical interface were evaluated. These technical audits have resulted in enhancements to the procedures and methods and thus, contributed to the overall quality of the HVAC portion of the Corrective Action Program (CAP) at CPSES Unit I and Cocynon.

In addition to the audits described above, TU Electric has initiated the Engineering Functional Evaluation (EFE). The EFE began auditing the HVAC portion of the Corrective Action Program (CAP) in May 1987. The Engineering Functional Evaluation (EFE) is an overview program which is performing an independent in-depth technical evalution of the Corrective 1

1 2

The TU Electric Technical Audit Program (TAP) has been in effect l since January 1987. Prior to this, the TV Electric Quality Assurance (QA) Department performed audits of selected engineering l service contractors using technical specialists as part of its vendor audit program.

5-19 O

l l

Action Program (CAP) to provide additional assurance that the CAP is effectively implemented. The Engineering Functional Evalution (EFE) is conducted under the SWEC Quality Assurance (QA) Program and is directed by p/

y a Program Manager who reports to the SWEC Chief Engineer, Engineering Assurance. The Engineering Functional Evalution (EFE) is performed by highly qualified and experienced engineers from SWEC, Impell and Ebasco who have not been involved with previous engineering and design work at CPSES. The Engineering Functional Evaluation (EFE) is performed in a formal, preplanned and fully documented manner to provide objective evidence of completion of the planned scope of the evaluation and to provide documentation of its results and conclusions. The Engineering Functional Evaluation (EFE) is comparable in scope, level of effort and personnel qualifications to integrated, independent design inspections and verifications conducted at other nuclear plants.

The audits described above collectively represent very detailed and complete assessments of the following:

l o Adequacy of the Quality Assurance (QA) Program o Implementation of the Quality Assurance (QA) Program o Technical adequacy of the design criteria and procedures o Implementation of the design criteria and procedures '

As such, these audits identified items in design criteria, procedures, I calculations and project documentation and training for which action was j required to clarify or improve the design validation process and assure ,

continued compliance with procedures. Each item identified through the '

audit process was reviewed in detail to determine the extent of the q condition, the cause of the condition and any corrective or preventive b action required. Complete responses were provided for each item l identified. Subsequent audits verify that appropriate corrective and preventive actions are implemented to address the previously identified i audit items. =

in addition to the Quality Assurance (QA) audits, a rigorous Quality Control (QC) inspection program is in place for CPSES Unit I and Common.

The Quality Control (QC) inspection program provides review of the HVAC  !

duct and HVAC support as-built walkdowns. Inspection procedures identify '

the attributes which Quality Control (QC) inspectors must inspect before a particular installation is acceptable.

In summary, an appropriate level of attention has been given to the quality of HVAC activities; the Quality Assurance (QA) Programs are appropriate for the scope of work; project performance has been demonstrated to be in compliance with the QA Programs; and appropriate I corrective and preventive actions were taken whenever they were required. '

l l

l 5-20 0

- .. l

5.3.1 Sumary of Ebasco Quality Assurance (QA) Audits To date, Ebasco Quality Assurance (QA) has performed 3 audits of the HVAC j portion of the Corrective Action Program (CAP). A tabulation of Ebasco Quality Assurance (QA) audits is presented in Table 5-3. The following list of audit subjects describes the depth of auditing that has been performed:

1. Adequacy of the Ebasco Project Design Procedures

2. Adequacy of the Ebasco Project Procedures

3. Calculations - Documentation

4. Compliance with Project Procedures

5. Construction Support Activities

6. Document Control

7. Indoctrination and Training

8. Licensing Activities ,

9. Records Maintenance

10. Maintenance of Project Procedure Manuals

11. Personnel Qualification and Experience Verification

12. Inputs to HVAC Duct, HVAC Supports and HVAC Systems Analyses 5.3.2 Sumary of Audits by TV Electric Quality Assurance (QA), by NRC-VPB and Inspections by NRC-OSP In addition to the Ebasco internal Quality Assurance (QA) Audits, Ebasco was audited by the TV Electric Technical Audit Program (TAP) and the NRC.

To date, TV Electric's Quality Assurance (QA) Technical Audit Program (TAP) has performed 8 audits of Ebasco. Each location performing HVAC duct, HVAC supports and HVAC systems related work for CPSES has been audited at least once. The list of audit subjects in Section 5.3.1 is I representative for these audits. A tabulation of the TU Electric  !

Technical Audit Program (TAP) audits is presented in Table 5-3. 1 In August 1986 the NRC-Vendor Program Branch (VPB) performed an audit of Ebasco's implementation of Ebasco's approved Nuclear Quality Assurance (QA) Program. Their inspection was specifically related to Ebasco's 4

Quality Assurance (QA) Program implementation on the Comanche Peak 5-21 O

Project. Their report, #99900505/86-01, indicated that the NRC inspectors found no instance where the implementation of Ebasco's Quality Assurance (QA) Program for CPSES failed to meet NRC requirements.

The NRC-Office of Special Projects (OSP) conducted inspections (Reference

48) of HVAC systems in the New York office beginning in August 1987. The inspections involved technical evaluations of the design validation process and focused primarily on the review of calculations and Design Basis Documents (DBDs), and their compliance with licensing commitments.

In addition, the NRC-Office of Special Projects (OSP) inspections (Reference 48) included a review of activities performed under the Engineering Functional Evaluation (EFE).

5.4 CORRECTIVE AND PREVENTIVE ACTION Ebasco has developed Design Basis Documents (DBDs) and updated the HVAC installation specification to implement the corrective actions resulting from the HVAC portion of the Corrective Action Program (CAP). These Design Basis Documents (DBDs) contain the design criteria for validating the HVAC design of CPSES Unit I and Common. As a result of the HVAC portion of the Corrective Action Program (CAP), the CPSES Unit 1 and Common HVAC duct, HVAC supports and HVAC systems are validated as being capable of performing their safety-related functions.

This validation is documented in the drawings, calculations and specifications which are contained in the Design Validation Packages (DVPs). This validated design documentation will be provided to TV Electric at the completion of the Corrective Action Program (CAP). The D Design Basis Documents (DBDs) used for validation will also be provided to Comanche Peak Engineering (CPE). The validated design documentation and l Design Basis Documents (DBDs) can provide the basis for configuration control of CPSES HVAC design and can be utilized by TV Electric to facilitate operation, maintenance and future modifications in accordance with licensing commitments following issuance of an operating license.

Interfaces between organizations have been identified and addressed in detail within project procedures. Those HVAC interfaces are discussed in Section 5.1.2.5.

TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from Ebasco to CPE. The program provides for the identification i of those tasks presently being performed by Ebasco which are to be l transferred to Comanche Peak Engineering (CPE) and the identification of ,

all procedures, programs, training, and staffing requirements. The l program is based upon three prerequisites: (a) the Corrective Action Program (CAP) effort to support plant completion is finished for the particular task; (b) the HVAC Design Validation Packages (DVPs) are complete; and (c) any required preventive action taken, as discussed in Appendix A and Appendix B, is complete. , l 5-22 O

l l

FIGURE 5-1 CORRECTIVE ACTION PROGRAM ( CAP)

O TECHNICAL INTERFACES V

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FIGURE 5-2 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM ( PCHVP)

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TABLE 5-1 HVAC DESIGN PROCEDURES AND DESIGN BASIS DOCUMENTS (DBDs)

Document No., lillg SAG.CP23 Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports (Reference 8)

SAG.CP24 General Instructions For Seimic Category I HVAC Duct and Duct Support Analysis (Reference 9)

SAG.CP30 Seismic Design Criteria For Air Handling Units, Plenums, Equipment Supports (Reference 16)

SAG.CP31 Design Criteria For Seismic Category II HVAC Duct and Duct Supports (Reference 4 25)

SAG.CP32 General Instructions For Seismic Category II HVAC Duct and Duct Support Analysis (Reference 24)

DBD-ME-300 Containment Ventilation Systems (Reference 28)

DBD-ME-301 Containment Air Cleanup Systems (Reference 29)  ;

DBD-ME-302 Safeguards Building Ventilation System (Reference 30)

DBD ME 302A Diesel Generator Area Ventilation System (Reference 31)

DBD-ME-302B Electrical Area HVAC System (Reference 32)

DBD-ME-302C Mainsteam and Feedwater Area Air Conditioning System (Reference 33)

DBD-ME-303 Auxiliary Building Ventilation System (Reference 34)

DBD-ME-303-01 Fuel Handling Building Ventilation System (Reference 35) j 1 4

O

1 TABLE 5-1 (Continued) l Document No, 11111 ,

DBD ME-304 Control Room Air Conditioning System (Reference 36)

DBD-ME-305 Uncontrolled Access Area Ventilation -

System (Reference 37)

I DBD-ME-309 Primary Plant Ventilation System ,

(Reference 38)

DBD-ME-311 Safety Chilled Water System (Reference 39)

I DBD-ME-312 Service Water Intake Structure Ventilation System (Reference 40)

DBD-ME-313 Uninterruptible Power Supply Area Air  ;

Conditioning System (Reference 41)  ;

DBD CS 086 HVAC Duct and Duct Supports (Reference

11) ,

Ebasco CPSES Manual of Procedures .

(Reference 5)  !

1 l l i i i

l 4

1 2

4 O

4 l

-.--. y _. -. -. - - - , ..m-.- - . - ---- ,,., . - . - , , , _ ,,_,-.v,. n,-. -

, ,. - ,,r.. ,-. - --, , ,, - , . - , , ,

TABLE 5-2 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)

O HVAC ATTRIBUTE MATRIX Construction Final Acceptance PCHVP Attribute 4

Work Cateoory Attribute Validation Method HVAC Air Handling Units / Longitudinal CPE-EB-FVM-CS-066 Plenums - Configuration Seam Types (Reference 23)

Duct Size CPE-EB-FVM-CS-066 Gage Thickness CPE-EB-FVM-CS-066 Duct Piece Length CPE-EB-FVM-CS-066

, Duct Tee and Branch CPE-EB-FVM-CS-066 Connection Configuration Duct Closure Plate CPE-EB-FVM-CS-066 Configuration Duct Flex Connecto'rs CPE-EB-FVM-CS-066 Location and Length Duct Layout Configuration CPE-EB-FVM CS-066 Duct Support Location CPE-EB-FVM-CS-066

Duct Support Span CPE-EB-FVM-CS-066 1 Reinforcing Configuration CPE-EB FVM CS-066 Reinforcing Size CPF-EB-FVM CS-066 Reinforcing Type CPE-EB FVM-CS 066 (Lapped, Butted) '

Reinforcing Location CPE-EB-FVM-CS-066

, (Spacing) l Tie Rod Location CPE-EB-FVM-CS-066

. Tie Rod Size ECE 9.04-05 (Reference 26)

Gaskets Existence All CPE EB-FVM-CS 066 i Around 1

O l

. l

TABLE 5-2 (Continued) ,

O coastruct4oa Work Catecory ria>' ^cceptaace Attribute ec"ve attribute Validation Method HVAC Air Handling Units / Housing-Bolt Hole Spacing CPE-EB- R4-CS-066 Plenums - Configuration Configuration (Used and (Con't) Unused)  !

Housing-Dimensions CPE-EB-FVM CS-066 Housing-Location and CPE-EB-FVM-CS-066 Configuration of Attachments Housing-Eiectrical CPE-EB-FVM CS-066 i Connection Location '

Housing-Location of CPE-EB-FVM-CS-066 Work Points Housing-Member Length CPE-EB-FVM-CS-066 Housing Member Size CPE-EB-FVM-CS-066  :

Housing-Member Shape CPE-EB-FVM-CS 066 i Housing-Member Location CPE-EB-FVM-CS-066 <

Housing Member Orientation CPE EB-FVM-CS-066 Housing Number of CPE-EB-FVM-CS 066 ,

Bolt Holes in a Cross '

Section '

Housing-Water Connection CPE-EB-FVM-CS-066 Configuration Housing Copes, Cutouts CPE-EB-FVM-CS-066 (Sizes and Locations)

Accessory Mounting ECE 9.04 05 Configuration Component Mounting ECE 9.04-05 Configuration Component Tag Number CPE-EB-FVM CS 066 4

Component and Accessory CPE-EB FVM-CS 066 Locations 2

O

TABLE 5-2 (Continued)

O Coastructioa Mark Cateaory, riaai accePtaace Attribute eCHve attribute Validation Method HVAC Air Handling Units / Extractor Stiffener CPE-EB-FVM-CS-066 Plenums - Configuration Configuration (Con't)

Location of Additional CPE-EB-FVM CS-066 Attachments and Support Spans Other Commodity Attachment CPE EB-FVM 45-066 Configuration HVAC Air Handling Units / Hole to End Distance CPE EB-FVM-CS-066 Plenums-Bolted Base Member tge Dimension CPE-EB-FVM-CS-066 Presence of Gap Between CPE-EB-FVM-CS-066 Base Member and Concrete Bolt Hole Visible CFE-EB-FVM-CS-066 f

HVAC Air Handling Units / Amount of Gap Under CPE-EB-FVM-CS-066 Plenums-Bolting Bolt Head O Boit Size CeE-EB rvM-CS-066 Configuration CPE-EB-FVM-CS-066 Gage Dimension CPE-EB-FVM-CS-066 l

Existence of Hardened i Washers for High Strength ECE 9.04-05 Bolts 1

Hole Location on Member CPE-EB-FVM-CS-066 Hole to End of Member CPE-EB-FVM-CS-066 Distance Bolt Hole Visible and CPE EB-FVM-CS-066 Washer Size Thread Engagement CPE-EB FVM CS-066 3

0 -

~ -

TABLE 5-2 i (Continued)

O Co#structica Work Cateaory Finai AccePta#ce Attribute eCHve Attribute Validation Method HVAC Air Handling Units / Tightness CPE-EB-FVM-CS-066 Plenums - Bolting (Con't) Number and Size CPE-EB-FVM-CS-066 of Unused Bolt Holes HVAC Air Handling Units / Skewness CPE-EB-FVM CS-066 Plenums-Hilti Bolts Amount of Gap Under CPE EB-FVM CS-066 Nut Diameter CPE-EB FVM-CS-066 ,

Marking (Length) CPE-EB FVM-CS-066 Bolt Projection from CPE-EB-FVM CS-066 Concrete Surface Thread Engagement CDE-EB-FVM CS-066

' Torque CPE-EB-FVM-CS-066 Presence of Torque Seal CPE-EB FVM-CS-066 O 11,. (Reguler/ Super) CvE-EB-FvM-CS.086 Washer Installed CPE-EB-FVM-CS-066 HVAC Air Handling Units / Amount of Gap Under CPE-EB-FVM-CS-066 i Plenums-Richmond Inserts Bolt Head or Nut Presence of Doubir. Nuts CPE EB-FVM-CS-066 .

for Threaded Rods l 1

Length of Bolt or Threaded CPE-EB-FVM-CS-066 Rod i

Material (Marking of Bolt CPE-EB-FVM-CS-066 or Threaded Rod)

Size of Bolt or Threaded CPE-EB FVM-CS-066

, Rod Bolt Thread Engagement CPE-EB-FVM-CS-066 Presence of Torque Seal CPE-EB-FVM CS-066 4 .

O  !

l j l

TABLE 5 2 (Continued)

Construction Final Acceptance PCHVP Attribute Work Cateaory Attribute Validation Method HVAC Air Handling Units / Tightness CPE-EB-FVM CS-066 Plenums - Richmond Inserts (Con't)

HVAC Air Handling Units / Type CPE-EB-FVM CS-066 Plenums-Flanges Alignment CPE-EB-FVM-CS-066 Bolt Edge Distance CPE-EB-FVM CS-066 Number and Size CPE-EB-FVM CS-066 of Unused Bolt Holes Bolt Hole Spacing CPE-EB-FVM-CS-066 (Used and Unused) 1 Bolt Hole Visible and CPE-EB-FVM-CS-066 Washer Size Bolt Location CPE-EB-FVM CS-066 ,

Bolt Size CPE-EB-FVM-CS-066 O Bolt Spacing CPE-EB FVM-CS-066 Bolt Thread Engagement CPE EB-FVM-CS-066 Compression of Lcck Washers CPE-EB-FVM CS-066 Configuration CPE-EB-FVM-CS-066 Location CPE-EB-FVM-CS-066 Size CPE-EB-FVM-CS-066 HVAC Air Handling Units / Housing - Type CPE-EB-FVM-CS-066 Plenums - Welds Housing - Size, Profile CPE-EB-FVM-CS-066 l Housing - Length CPE EB-FVM-CS-066 I l

Housing - Location CPE-EB-FVM-CS-066 l

l 1

5 i O i

I t

- , _ - , _ _ . . _ _1

TABLE 5-2 ,

(Continued)

O Constructioa Work Cateaory Fiael Acceptaace Attribute eCave Attribute Validation Method HVAC Air Handling Units / Presence of Fusion CPE-EB-FVM-CS-066 Plenums - Welds (Con't) Presence of Arc Strikes CPE-EB-FVM CS-066 Presence of Cracks CPE-EB-FVM-CS-066 Presence of Craters CPE-EB FVM-CS-066  ;

Presence of Overlap CPE-EB-FVM-CS-066 Presence of Porosity CPE-EB-FVM-CS-066 4 Presence of Slag CPE-EB FVM-CS-066 Presence of Undercut CPE-EB-FVM CS 066 Presence of Fillet Gaps CPE-EB-FVM-CS-066 (Structural to Structural and Structural to Sheet Metal)

Housing - Presence of CPE-EB-FVM CS-066 Attachment to Sheet Metal Duct-Fit Up (Structural to CPE-EB FVM CS-066 Structural) ,

1 Duct Flange-Angle to CPE-EB FVM-CS-066 Angle Size and Length

(

Duct Flange-Angle to CPE-EB FVM CS-066 )

Ouct length and Spacing i l

i Duct Flange-Corner Tab CPE-EB-FVM CS-066 Length Duct Reinforcing-Angle to CPE-EB-FVM CS-066 Duct length and Spacing Duct-Continuous Splice CPE-EB-FVM-CS-066 ,

Welds I 1

Duct Tie Rods - CPE-EB-FVM CS-066 I Size and Length  !

O I

O e

TABLE 5-2 (Continued)

O Construction Work Cateaory Final Acceptance Attribute PCHVP Attribute Validation Method HVAC Air Handling Units / Ouct Reinforcing-Argle CPE-EB FVM-CS 066 to Angle Size and Length '

Plenums - Welds (Con't)

HVAC Air Handling Units / Presence of Damage CPE-EB-FVM CS-066 Plenums - General Clearances CPE-SWEC-FVM CS-068 (Reference 27)

Cleanliness CPE-EB FVM CS-066 Presence of Touch up CPE-EB-FVM-CS-066 Coatings Concrete Anchorage-Bolt CPE-EB-FVM CS-066 Spacing on Plate l

Presence of Insulation ECE 9.04 05 HVAC Duct Supports - Support Identification CPE-EB-FVM CS-029 General (Reference 14)

Presence of Damage CPE-EB-FVM-CS-029 O Clearances CPE-SWEC-FVM-CS-068 Presence of Touch-up CPE-EB-FVM CS-029 Coatings l

HVAC Duct Supports - Member Shape CPE-EB-FVM CS-029  ;

Configuration  ;

Member Size (Thickness) CPE-EB FVM CS 029 Member Orientation CPE-EB FVM CS-029 i Plumbness, Levelness CPE-EB FVM-CS-029

and Skewness Member Length CPE-EB FVM-CS-029 Copes, Cutouts (Sizes CPE-EB FVM CS-029 and Locations)

Bolt Hole Size (Unused) CPE-EB-FVM-CS-029 7

1

o i

TABLE 5 2 (Continued) <

O Construction Work Cateaory Final Acceptance Attribute _

PCHVP Attribute Validation Method HVAC Duct Supports - Bolt Hole Spacing CPE EB FVM-CS-029 Configuration (Con't) (Used and Unused) .

Number of Bolt Holes CPE EB FVM CS 029  ;

in a Cross Section 1

Location of Additional CPE EB FVM-CS-029 Attachments and Support Spans Location and Configuration CPE EB-FVM-CS-029 4 of Attachments location of Work Points CPE-EB-FVM CS-029 Ouct Attached to Support CPE-EB-FVM-CS-029 Presence of Duct / Support CPE-EB FVM-CS-029 Gaps l HVAC Duct Supports - Presence of Cracks CPE-EB FVM-CS 029 i Welds '

Presence of Overlap CPE-EB FVM CS-029 O Presence of Slag CPE-EB-FVM CS 029  !

Presence of Arc Strikes CPE-EB FVM-CS 029 l Presence of Porosity CPE-EB FVM-CS-029 Presence of Undercut CPE-EB-FVM CS 029 Presence of Craters CPE-EB-FVM CS-029

/  ;

I Presence of Fusion CPE-EB FVM CS 029 i

Type of Weld CPE-EB-FVM-CS 029 4

Size, Profile CPE-EB FVM CS-029 Length CPE-EB-FVM-CS 029 4 i Location CPE-EB-FVM-CS 029 8 ,

t

TABLE 5 2 (Continued)

O Coastructioa Work Cateaory ri=>i acc Ptiac-Attribute eCave attribut.

Validation Method HVAC Duct Supports - Presence of Fillet Gaps CPE EB FVM CS-029 .

Welds (Con't) (Structural to Structural '

anJ Structural to Sheet Metal)  ;

HVAC Duct Supports - Number and Size of Unused CPE-EB FVM CS 029 Bolting Bolt Holes '

Presence of Hardened ECE 9.04-05 Washers for High Strength Bolts i

Hole Location (On Members) CPE-EB FVM CS-029 Bolt Hole Visible CPE-EB FVM-CS 029 Hole to End of Member CPE-EB-FVM-CS-029 Distance Gage Dimension CPE-EB-FVM CS-029 Bolt Size CPE EB FVM CS-029 i O Boit ti htness 9 CPE EB-rvM CS-029 Thread Engagement CPE-EB-FVM CS 029 4

Configuration CPE-EB-FVM-CS 029 Amount of Gap Under CPE-EB-FVM-CS 029 Bolt Head HVAC Duct Supports - Bolt Hole Visible CPE-EB FVM CS-029 ,

Bolted Base Member Hole to End of Member CPE-EB-FVM CS-029 l Distance {

Gage Dimension CPE-EB FVM-CS 029 Presence of Gap Between CPE-EB-FVM-CS-029 j

Base Member and Concrete

]

HVAC Duct Supports - Concrete Anchorage Bolt CPE-EB FVM CS 029 j Hilti Bolts Spacing on Plate I 9 O

TABLE 5-2 (Continued)

O comstructioa Work Cateaory ria 1 Accept ac-Attribute ecave attribut-Validation Method HVAC Duct Supports - Type (Regular or CPE-EB-FVM CS 029 Hilti Bolts (Con't)

Super)

Marking (Length Code) CPE-EB-FVM-CS-029  ;

Diameter CPE-EB FVM CS-029 Thread Engagement CPE-EB-FVM CS-029 Projection from Concrete CPE-EB FVM CS-029 Surface Skewness CPE-EB-FVM CS 029 Amount of Gap Under CPE-EB FVM-CS-029 Nut Torque CPE-EB-FVM CS 029 Presence of Torque Seal CPE-EB FVM-CS-029 j Washer Installed CPE-EB-FYM-CS 029 i O HVAC Duct Supports -

Richmond Inserts Size of Bolt or Threaded CPE-EB-FVM CS 029 Rod i

Material (Marking of CPE-EB-FVM CS-029 j Bolt or Threaded Rod) i Tightness CPE-EB-FVM CS-029 Amount of Gap Under Bolt CPE-EB-FVM-CS-029 Head or Nut length of Bolt or Threaded CPE-EB-FVM CS-029 i Rod

] Presence of Torque Seal CPE-EB-FVM-CS-029 l l

J

.i 10 O

TABLE 5 2 (Continued)

O Coastructioa Work Cateaory riael accePteace Attribute eCave Attribute Validation Method HVAC Duct Supports - Bolt Thread Engage- CPE EB FVM CS 029 '

Richmond Inserts (Con't) ment Presence of Double CPE EB FVM CS-029 Nuts for Threidtd Rods HVAC Duct - General Presence of Damage CPE-EB-FVM CS-029 Presence of Insulation ECE 9.04-05 4

Clearances CPE-SWEC FVM-CS-068 Cleanliness CPE-EB-FVM CS 029 Presence of Touch-up CPE-EB-FVM-CS-029 Coatings HVAC Duct - Component Mounting ECE 9.04 05 Configuration Configuration Accessory Mounting ECE 9.04 05 Configuration O tongitudinai Se- Type CeE-EB-FvM CS-029 4

Duct Size CPE-EB-FVM CS 029 1 l

Gage Thickness CPE-EB-FVM-CS-029 l 1

Piece Length CPE-EB-FVM-CS-029 Tee and Branch Connection CPE-EB-FVM-CS-029 Configuration

Closure Plate CPE-EB FVM CS-029 Configuration Flex Connectors CPE-EB-FVM CS-029 I (Location and Length) l Duct Layout -

CPE-EB-FVM CS-029 Configuration j Support Location CPE-EB-FVM CS-029 11 i i

O

t TABLE 5-2 l (Continued)  !

O coastructica Work Cateaory ria 1 acc Ptarc-Attribute ecsve attribut-Validation Method j HVAC Duct - Support Span CPE EB FVM CS 029 >

Ccnfiguration (Con't)

Configurations of Other CPE EB FVM CS 029 Commodity Attachments ,

l Component and Accessory CPE-EB FVM CS 029 Location t

Component Identification CPE-EB FVM CS 029 ,

! Presence of Extractor CPE-EB-FVM-CS-029 Stiffeners .

Gasket Existence All CPE-EB FVM-CS-029 Around Tie Rod Size ECE-9.04 05 l Tie Rod Location CPE-EB FVM CS-029 .

1 Reinforcing Size CPE-EB FVM-CS 029

Reinforcing Location CPE-EB FVM CS 029

(Spacing)

Reinforcing Type i CPE-EB FVM CS-029

(Lapped, Butted) i Reinforcing Configuration CPE-EB-FVM CS-029 i

HVAC Duct - Type CPE-EB FVM-CS 029 Flanges

Size CPE-EB FVM CS-029 Location CPE EB FVM-CS 029

) Bolt Spacing CPE-EB FVM CS 029

{ Bolt Location CPE-EB-FVM-CS-029 Bolt Size CPE-EB-FVM-CS-029 12

]

4 o

i 4

TABLE 5-2 (Continued)

O coastructica Work Cateaory ria i acc Pt ac-Attribute ecave ^ttribut-Validation Method HVAC Duct - Bolt Edge Distance CPE-EB FVM CS-029 ,

Flanges (Con't) l Bolt Hole Visible and CPE-EB FVM-CS-029  !

Washer Size ,

i i

Number and Size of Unused CPE EB FVM-CS-029 Bolt Holes Bolt Hole Spacing CPE-EB-FVM-CS-029 (Used and Unused)

Alignment CPE-EB FVH-CS-029 j Thread Engagement CPE-EB FVM CS 029 Compression of Lock Washers CPE-EB-FVM CS-029 ,

Configuration CPE EB-FVM-CS-029 4

HVAC Duct - Welds Tie Rods - CPE-EB FVM-CS 029 l Size and length Reinforcing-Angle to Duct O CPE-EB FVM CS-029 L Length and Spacing Reinforcing Angle to Angle CPE-EB-FVM CS-029 Size and Length Flange Angle to Duct CPE-EB-FVM-CS 029  ;

, length and Spacing i

Flange-Angle to Angle CPE-EB-FVM CS-029 Size and Length Flange - Co:ner Tab CPE-EB-FVM CS-029 Length Continuous Splice Welds CPE-EB FVM CS-029 4

13 i

O l

1

TABLE 5-2 (Continued) t p;

v Construction Final Acceptance PCHVP Attribute Work Cateaory Attribute Validation Method i

HVAC Duct - Presence of Fillet Gap CPE EB FVM CS-029 Welds (Con't) (Structural to Structural and Structural to Sheet  :

Metal)

Presence of Craters CPE-EB-FVM CS-029 Presence of Undercut CPE-EB-FVM CS-029 Presence of Porosity CPE-EB FVM CS-029 Presence of Overlap CPE-EB-FVM CS-029 Presence of Cracks CPE-EB-FVM CS-029 Presence of Arc Strikes CPE-EB-FVM CS-029 Presence of Fusion CPE-EB FVM-CS-029 Presence of Slag CPE-EB-FVM-CS-029 HVAC Equipment "upports - Presence of Damage CPE-EB-FVM CS-066 General O Presence of Touch up Coatings CPE-EB FVM CS 066 Clearances CPE-SWEC-FVM CS 068 i Support Identification CPE-EB-FVM CS-066 i l

HVAC Equipment Supports - Member Shape CPE-EB-FVM CS 066 l Configuration Member Size (Thickness) CPE-EB-FVM CS-066 Member Orientation CPE-EB-FVM CS-066 Configuration-Plumbness, CPE-EB FVM CS 066 I Levelness and Skewness 1

Member Length CPE-EB-FVM CS-066

, Copes, Cutouts CPE EB FVM CS-066 l 4

(Sizes and Locations) 14

1 i

1 O

TABLE 5-2 (Continued)

O coastructioa Work Cateaory ria 1 ^cc Pt ac-Attribute ecsve attribut-Validation Method HVAC Equipment Supports - Bolt Hole Size (Used and CPE EB FVM CS-066 Configuration (Con't) Unused)

Bolt Hole Spacing CPE-EB-FVM CS 066 (Used and Unused)

Number of Bolt Holes CPE-EB-FVM CS 066 in a Cross Section location of Additional CPE-EB-FVM CS-066 Attachments and Support 4 Spans Configuration and Location CPE-EB FVM CS-066 of Attachments location of Work Points CPE-EB-FVM-CS-066 HVAC Equipment Supports - Presence of Fillet Gaps CPE-EB-FVM-CS-066 Welds Type CPE-EB-FVM CS 066 Size, Profile CPE-EB-FVM CS 066 Length CPE-EB-FVM-CS 066 Location CPE-EB-FVM CS 066 Presence of Craters CPE-EB-FVM-CS 066 Presence of Undercrt CPE EB FVM-CS 066 Presence of Porosity CPE-EB-FVM CS 066 Presence of Overlap CPE-EB-FVM-CS-066 Presence of Cracks CPE-EB FVM-CS 066 i

Presence of Arc Strikes CPE-EB-FVM-CS-066 Presence of Fusion CPE-EB FVM CS-066 l Presence of Slag CPE-EB-FVM-CS 066 15 i

. O ,

TABLE 5-2 (Continued)

O Coastructioa Work Cateaory Fiaai Acceptance Attribute PCHvP ^ttribute Validation Method HVAC Equipment Supports - Number and Size of CPE-EB FVM CS-066 Bolting Unused Bolt Holes Presence of Hardened ECE 9.04-05 Washers for High Strength Bolts Hole Location (On Members) CPE-EB FVM CS-066 Bolt Hole Visible and CPE-EB FVM CS-066 Washer Size Hole to End of Member CPE-EB FVM CS-066 '

Distance Gage Dimension CPE-EB FVM CS-066 Bolt Size CPE-EB-FVM CS-066 Bolt Tightness CPE EB-FVM CS 066 Thread Engagement CPE-EB-FVM CS-066 Configuration CPE-EB-FVM CS 066 4 Amount of Gap Under CPE EB FVM CS 066 Bolt Head HVAC Equipment Supports - Bolt Spacing on Plate CPE-EB FVM CS 066 i Hilti Bolts Type CPE-EB FVM-CS 066 (Regular or Super) i Marking CPE-EB FVM CS 066 i i (LengthCode)

Diameter CPE-EB FVM CS-066 Thread Engagement CPE-EB FVM CS 066 Projection from CPE-EB-FVM CS 066 Concrete Surface t i

16 '

TABLE 5-2 (Continued)

O construction Work Cateaory ri=>i acc Ptaac-Attribute acave attribut.

Validation Method

- HVAC Equipment Supports - Skewness CPE EB FVM CS 066 Hilti Bolts ' Con't)

Amount of Gap Under CPE EB FVM CS 066 Nut  ;

Torque CPE EB FVM CS 066 i Presence of Torque Seal CPE-EB-FVM CS 066

, Washer Installed CPE EB-FVM CS 066 HVAC Equipment Supports - Size of Bolt or Threaded CPE-EB FVM CS-066 Richmond Inserts Rod Material (Marking " CPE-EB-FVM CS 066 Bolt or Threaded F ,i Tightness CPE-EB-FVM CS 066 Presence of Torque Seal CPE EB-FVM CS-066 Amount of Gap Under CPE-EB-FVM CS-066

, Bolt Head or Nut Length of Bolt or CPE-EB FVM CS-066 Threaded Rod Bolt Thread Engagement CPE EB-FVM CS 066 t

Presence of Doublo CPE EB FVM CS 066  :

Nuts for Threaded Rods l

, HVAC Equipment Supports - Bolt Hole Visible CPE-EB-FVM CS 066 4

Bolted Base Member i Hole to End of Member CPE-EB FVM CS-066 Distance Gage Dimension CPE EB FVM CS-066  :

Amount of Gap between CPE-EB-FVM CS 066 Base Member and Concrete Tornado Vent Fire Dampers - Presence of U.L. Mark on CPE-EB FVM CS-112 General Hold Open Device (Reference 47) 17

I

O  !

1

i i l

TABLE 5-2 (Continued) j

() Construction Work Catecory Final Acceptance Attributo PCHVP Attribute Validation Method  ;

, Tornado Vent Fire Dampers Presence of U.L. Label CPE EB FVM CS-112  :

General on Damper i

Identification of CPE EB FVM CS-ll2 i Fusible Link Actuation j Temperature r

} Presence of Damage on CPE-EB-FVM CS Il2 i Negator Springs and Tracks j 4

I 1

j i .

l  !

()

a 1

I l

i i

18 j C:)

I

TABLE 5-3

SUMMARY

OF AUDITS Ebasco Ouality Assurance (0A) Audits Audit Audit i Audit Auditing Date Report Response Number Oraanization of Audit Location Transmittal Transmittal 2854 Ebasco QA Jan 14 21. New York Mar 5, 1987 1 finding ,

1987 corrected

~

during audit; no i response l was required 2880 Ebasco QA Nov 11-12, New York Dec 14, 1987 No findings; 1987 no response was required

• 2883 Ebasco QA Dec 16 17, New York Dec 30, 1987 No findings;

! 1987 no response

. was required j TV Electric Ouality Assurance (0A) Audits Audit Auditing Date Report Response  !

i Number Oraanization of Audit location Iransmittal Transmittal ATP 87 02 TV Elec TAP Feb 9-13, Site Mar 16, 1987 May 28, 1987 1987 a

l ATP 87-23 TV Elec TAP June 15-19, New York July 2, 1987 Aug 5, 1987 ,

i 1987  !

ATP-87-31 TV Elec TAP July 20-24, New York Aug 13, 1987 Sept 4, 1987 I

1987 .

t

! ATP 87 51 TU Elec TAP Sept 28- New York Oct 30, 1987 Nov 23, 1987 j Oct 2, 1987 ATP-87-52 TU Elec TAP Oct 12 16, New York Nov 13, 1987 No findingst 1987 no response .

was required l

ATP-87-538 TV Elec TAP Nov 30- Site Dec 31, 1987 Jan 15, 1988 '

Dec 18, 1987 4

i

O  !

k TABLE 5-3 (Continued)

O to t' etr4e o" 14tv as>#r="c 'oa)

• 84t=

Audit Audit Audit Auditing Date Report Response l Number Oroanization of Audit location TransmitM Transmittal ATP 87 541 TV Elec TAP Nov 9- Site Dec 31, 1987 Feb 2, 1988 ,

Dec 16, 1987

~

ATP 88 80 TV Elec TAP Jan 25-29, New York Feb 12, 1988 In progress 1987 1

i TCP 87 45 TU Elec QA Dec 7-14, Site Jan 5, 1988 In progress 1987 l

i U

O l i

i f

! l i

1 i

)

4 3, <

1 1

1 l

I 2 l

i O

i

6.0 REFERENCES

p 1. TV Electric Specification 2323 MS 85, "HVAC Ducts, Louvers and d Accessories", Revision 6.

2. TV Electric NEO Quality Assurance Department Instruction NQI 3.09 M 006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2. i

3. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.29, "Seismic l Design Classification", Revision 2. February 1976.

4. Corporate Consulting and Development Company, Ltd., "Test Report for Static Load Tests of HVAC Ductwork for Comanche Peak Steam Electric Station (CPSES)", CCL Report No. A 749 87, October 23, 1987, with Addendum 1 dated January 7, 1988.

5. Ebasco CPSES Manual of Procedures.

I

6. American Institute of Steel Construction (AISC}, Manual of Steel Construction 7th Edition, including Supplements 1, 2, and 3.

i 7. TV Electric CPSES Unit I and Common, "Systems Interaction Program, (Supplement A Mechanical Project Status Report)", Revision 0. L

8. Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987.

O 9. Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

10. TV Electric CPSES Unit 1 & 2 "Design Basis Consolidation Program Plan", Ebasco Services, Inc., Revision 1, April 11, 1987.

11. CPSES Design Basis Document DBD-CS 086, "HVAC Duct and Duct

{ Supports", Revision 1, December 31, 1987. ,

12. TV Electric Engineering and Construction Procedure EC 9.04, "Post Construction Hardware Validation Program", Revision 2, September 30, 1987.

13. Ebasco Calculation HVAC Volume ! - Book 15. "HVAC Duct Qualification i

Methodology", Revision 0. j l

14. CPE-EB FVM-CS 029 "Procedure for Seismic HVAC Duct and Duct Hanger i As-Built Verification in Unit I and Common Areas", Revision 6. '

61 O

i a

l

15. Ebasco Document SAG.CP33, ' Specification for Static Testing of HVAC Ducts for Comanche Peak Steam Electric Station Units 1 & 2", Revision 4, October 21, 1987.

' O 16. Ebasco Document SAG.CP30 "Seismic Design Criteria for Air Handling #

] Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

17. CPE-SWEC-FVM EE/ME/IC/CS-090, "Post Construction Hardware Validation q Program Quality Control Reinspections", Revision 2, October 15, 1987. ,

18. Corporate Consulting and Development Company, Ltd, Report No.  ;

A 413 81, "Duct Test Data", February 19, 1982. '

) 19. Corporate Consulting and Development Company, Ltd, Report No.

q A-414 81, "Duct Test Evaluation", February 19, 1982. '

20. Ebasco Nuclear Quality Assurance Program Manual ETR-1001, Revision 13 dated May 15, 1987.

21. U.S. Nuclear Regulatory Comission, Regulatory Guide 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants",

Revision 2 June 1976.

22. U.S. Nuclear Regulatory Comission, Regulatory Guide 3.92, "Combining -

Model Responses and Spatial Components in Seismic Response Analysis", -

Revision 1. February, 1976. -

23. CPE-EB FVM CS 066, "Procedure for As-8uilt Verification of Seismic 4 HVAC Air Handling Units, Plenums and Equipment Supports in Units I and Comon Areas", Revision 2.

i "a

24. Ebasco Document SAG.CP32 "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis". Revision 2, December 15, '

1987.

l

25. Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, Detober 1, 1987.

26. TV Electric Engineering and Construction Engineering Procedure

, ECE 9.04-05, "Post Construction Hardware Validation Program Engineering Evaluation", Revision 0, October 2, 1987.

27. CPE-SWEC FVM CS 068, "Field Verification Method Comodity Clearance", Revision 0, July 30, 1987.

\ 28. CPSES Design Basis Document DBD ME-300, "Containment Ventilation

! Systems", Revision 1 December 22, 1987.

J j 6-2

O ,

! I

29. CPSES Design Basis Document DBD ME 301, ' Containment Air Cleanup Systems", Revision 1. December 22, 1987.

O 30. CPSES Design Basis Document DBD ME-302, "Safeguards Building Ventilation System", Revision 1, December 22, 1987.

31. CPSES Design Basis Document OBD ME-302A, "Diesel Generator Area t

! Ventilation System", Revision 1, December 22, 1987.

32. CPSES Design Basis Document DBD ME-302B, "Electrical Area HVAC System", Revision 3 February 4, 1988.

33. CPSES Design Basis Document DBD ME-302C, "Mainsteam and Feedwater Area Air Conditioning System", Revision 1, December 22, 1987.

34. CPSES Design Basis Document OBD ME-303, "Auxiliary Building Ventilation System", Revision 1, December 22, 1987.

3S. CPSES Design Basis Document DBD ME-303 01, "Fuel Handling Building Ventilation System", Revision 1, December 22, 1987.  ;

36. CPSES Design Basis Document DBD ME-304, "Control Room Air Conditioning System", Revision 1, December 22, 1987.

37. CPSES Design Basis Document DBD ME-305, "Uncontrolled Access Area .

l Ventilation System", Revision 1. December 22, 1987.

1

- 38. CPSES Design Basis Document DBD ME-309, "Primary Plant Ventilation System", Revision 2, February 12, 1988. .

O 4

39. CPSES Design Basis Document DBD ME 311. "Safety Chilled Water System", Revision 1, December 22, 1987.

40. CPSES Design Basis Document DBD ME 312. "Service Water Intake 4

Structure Ventilatian System", Revision 1, December 22, 1987.

41. CPSES Design Basis Document DBD ME 313, "Uninterruptible Power Supply Area Air Conditioning System", Revision 1, December 22, 1987.

42. Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Appendix 0, CPRT Sampling Policy, Applications and Guidelines, Revision 1 January 31, 1986, and Appendix E. Resolution of Discrepancies identified by the CPRT, Revision 3. June 18, 1987.

43. TV Electric Document "Evaluation and Resolution of Generic Technical Issues for HVAC Systems (Including Ducts and Duct Supports)",

Revision 0, December 15, 1985.

6-3 4

l

44. TU Electric Engineering and Construction Engineering Procedure, ECE 9.04, "Control of the Post Construction Hardware Validation Program Manual", Revision 1, October 7,1987.

45. CPE SWEC FVM EE/ME/IC/CS 089, "Post Construction Hardware Validation (PCHV) Program Engineering Walkdowns", Revision 2, October 15, 1987.

i 46. CPE IM FVM EQ 057, "Equipment Qualification Walkdowns", Revision 2 September 21, 1987.

j 47. CPE-EB FVM CS ll2, "Procedure for As Built Walkdown of Tornado Vent 4

Fire Dampers in Unit I and Common Areas" Revision 0. December 10, 1987.

48. NRC Letter No. 50/445/87 19, 50/446/87-15 to TU Electric, October 15, .

, 1987.

49. Tenera, L.P. (TERA) Mechanical Issue Resolution Report (IRR)

DAP-E M-504, Revision 0.

50. TU Electric Comanche Peak Response Team Issue Specific Action Plan (ISAP) VII.c Appendices 15 and 31.

51. CYGNA Cable Tray Supports Review Issues List (RIL) Comanche Peak Steam Electric Station (CPSES) Independent Assessment Program (IAP) - .

All Phases, Revision 14, transmitted to TU Electric by CYGNA Energy i j Services in letter No. 84056.114, dated August 10, 1987.

52. TU Electric Letter No. TXX 6631, W.G. Counsil to U.S. Nuclear Regulatory Commission, Comanche Peak Programs, August 20, 1987. ,

53. TU Electric Letter No. TXX 6500, W.G. Counsil to U.S. Nuclear Regulatory Commission, Comanche Peak Programs, June 25, 1987.

54. Tenera, L.P. (TERA) Environmental Qualification Issue Resolution Report (IRR) DAP E EIC-503, Revision 0.

55. TU Electric Comanche Peak Response Team Issue Specific Action Plan (ISAP) VII.c Appendix 16.

I i

I l

i 64

~ __ ,, ~

AoPENDIX A s COMANCHE PEAX RESPONSE TEAM (CPRT) AND EXTERNAL ISSVES t

This appendix contains a comprehensive summary of the Ebasco evaluation, resolution and corrective and preventive action for all the Comanche Peak Response Team (CPRT) and external issues which are related to the HVAC duct HVAC supports and HVAC systems designs. Specific references to the design criteria, specifications, procedures and tests which have resolved the issues are provided.

To report the resolution of the Comanche Peak Response Team (CPRT) and external issues, an individual subapper. dix was developed for each issue.

Each subappendix includes: a definition of the issue; issue resolution; and corrective and preventive action.

TheissuescontainedinSubappendicesAl}hqughA7,andA19wereraised by the Comanche Peak Response Team (CPRT) Issues A4 and A5 were also raised by the NRC in Inspection Reports. The issues contained in Subappendices A8 through All were raised by the NRC in Inspection Reports. The issue contained in Subappendix A12 was raised by the NRC Construction Assessment Team (CAT). The issues contained in Subappendices A13 and A14 were raised by CASE. The issue contained in Subappendix A15 was raised by the NRC Technical Review Team (TRT). The issues contained inSubappendicesA16andA17argincludedintheCYGNAEnergyServices (CYGNA) Review Issue List (RIL) . The first nine issues contained in Subappendix A18 are HVAC issues which were identified by the original HVAC designer to Ebasco. The last issue contained in S pJ raised by the Comanche Peak Response Team (CPRT)2.ubappendix The issues containedA18 was in Subappendices A2 through AS, A7, A10 and A12 through A18 were part of the conditions reported as Significant Deficiency Analysis Report (SDAR)

CP 85 54 in letter number TXX 5043, dated September 26, 1986 from TU Electric to the NRC.

1 Tenera, L.P. (TERA) Mechanical Issue Resolution Report (IRR)

DAP E-H 504, Revision 0, and Environmental Qualification IRR DAP E-E!C-503, Revision 0.

2 TV Electric Comanche Peak Response Team (CPRT) Issue Specific Action Plan (ISAP) VII.c Appendices 15, 16 and 31, 3

CYGNA Conduit and Cable Tray Review Issue Li:t (RIL) Comanche Peak Steam Electric Station (CPSES) Independent Assessment Program (IAP) -

All Phases Revision 14, transmitted to TV Electric by CYGNA Energy i Services in letter No. 84056.114, dated August 10, 1987.

A-1

1 The preventive action is embodied in the proceduras, the specifications and the Design Basis Documents (DBDs), developed and used in the HVAC portion of the Corrective Action Program (CAP). These procedures, O sa cificatio#> >#d o >49a s is oocu #ts (osos) r saiv aii r i t d Comanche Peak Response Team (CPRT) and external issues. Implementation of '

these preventive actions can assure that the HVAC portion of the design and hardware for CPSES Unit 1 and Comon will continue to comply with the licensing comitments throughout the life of the plant as described in Section 5.4.

Comanche Peak Response Team (CPRT) and external issues contained in

, Appendix A are listed below:

1 Issue No. Issue Title Al Determination of Heat Loads for Equipment Sizing t

A2 Lack of Construction Details for Fabrication and Installation of Ducts and Plenums A3 Inaccurate HVAC Duct Support Detail Drawings and Their Effect on the Duct Support Designs A4 Inadequate Program for the Installation and Quality Control (QC) Verification of HVAC Duct Supports A5 Groove Welds A6 Lack of Documentation for Receipt Inspection by the Driginal HVAC Duct Support Contractor .

A7 Insufficient Thread Engagement and Pretensioning of Richmond Insert Bolts on HVAC Duct Supports A8 Battery Room Ventilation A9 Battery Room Explosion Proof Thermostats O A10 Inspection Reports Datei Prior to Issue of As-Butit Drawings l All Walder Qualification A12 NRC CAT Inspection Results A13 Seismic Design of HVAC Supports A14 HVAC Dyct Axiti R&straint A15 Seismic Interaction of HVAC Duct A16 CYGNA Conduit and Cable Tray Issues A17 CASE /CYGNA Cable Tray Issues l A18 Other HVAC !ssues A19 Environmental Conditions and Requirements A-2 O

SUBApPENDIX A1  :

DETERMINATION OF HEAT LOADS FOR E0VIPMENT SIZING

\ (IRR DAP-E M 504)  ;

1.0 Definition of the issue The issue was that the original design of the safety-related HVAC j systems:

o may not have considered all applicable heat loads in system j and component sizing calculations; o may not have adequately sized equipment; '

o may not have included applicable plant operating modes; o contained calculation errors in some equipment sizing calculations; ,

o may have utilt,:ed improper design inputs.

! 2.0 Issue Resolution Ebasco resolved this issue by establishing the design criteria for safety-related HVAC equipment sizing which required that all [

applicable heat loads and plant operating modes be considered, j Q v

These design criteria are specified in the Design Basis Documents l (DBDs) (References 4.2 through 4.15). Ebasco then performed new calculations to determine the heat loads for equipment sizing in accordance with Ebasco design control procedures (Reference 4.1).

These procedures require that these calculations be checked and independently reviewed to assure accuracy and the use of proper i design inputs. Equipment sizing was then validated using the

results of the new heat load calculations.

4 J 3.0 Corrective and Preventive Action  ;

4

, o No additional issues were identified during the review and resolution of this issue.

1 o This issue was determined to be reportable under the

. provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report l

. (SDAR) CP 85 43 in letter number TXX-4659, dated December 20, i 1985 from TV Electric to the NRC,

{

Al 1 i

l O

-, - -v--

3.1 Corrective Action O The design criteria for equipment sizing were established which C) required that all applicable heat loads and plant operating modes be considered. These design criteria .re specified in the Design Basis Documents (DBDs) (References 4.2 through 4.15). Ebasco then performed new calculitione to determine the heat loads for equipment sizing in accoru. ce with Ebasco design control procedures (Reference 4.1). These procedures require that these calculations be checked and independently reviewed to assure accuracy and the use of proper design inputs. Equipment sizing was then validated using the results of the new heat load calculations.

3.2 Preventive Action The design criteria for sizing of safety related HVAC equipment, which require that all applicable heat loads and plant operating modes be considered, have been included in the Design Basis Documents (OB0s) (References 4.2 through 4.15). The Ebasco design control procedures (Reference 4.1) require that the calculations be checked and independently reviewed to assure accuracy and the use of proper design inputs.

4.0 References 4.1 Ebasco CPSES Manual of Procedures 4.2 CPSES Design Basis Document DBD ME-300, ' Containment Ventilation f^d System", Revision 1, December 22, 1987.

4.3 CPSES Design Basis Cocument DBD ME 301, "Containment Air Cleanup Systems", Revision 1, December 22, 1987.

4.4 CPSES Design Basis Document DBD ME-302, "Safeguards Building Ventilation System", Revision 1, December 22, 1987.

4.5 CPSES Design Basis Document DBD ME-302A, "Diesel Generator Area Ventilation System", Revision 1, December 22, 1987.

4.6 CPSES Design Basis Document DBD ME-302B, "Electrical Area HVAC System", Revision 3, February 4, 1988.

4.7 CPSES Design Basis Document DBD ME-302C, "Mainsteam and Feedwater Area Air Conditioning System", Revision 1, December 22, 1987.

4.8 CPSES Design Basis Document OBD ME 303, "Auxiliary Building Ventilation System", Revision 1. December 22, 1987.

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4.9 CPSES Design Basis Document DBD ME-303 01, "Fuel Handling Building

! Ventilation System", Revision 1, December 22, 1987. ,

O 4.io CASES Des 49n iasts Decemeat DBD ME 3o4, Coatrol Room Air Conditioning System", Revision 1, December 22, 1987.

l 4.11 CPSES Design Basis Document DBD ME 305, "Uncontrolled Access Area l Ventilation System", Revision 1, December 22, 1987. [

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, 4.12 CPSES Design Basis Document 080 ME 309, "Primary Plant Ventilation

! System", Revision 2 February 12, 1988. <

4.13 CFSES Design Basis Document 080 ME 311 Safety Chilled Water  !

System", Revision 1, December 22, 1987.

I 4.14 CPSES Design Basis Document DBD ME 312. "Service Water Intake Structure Ventilation System", Revision 1, December 22, 1987. l 4.15 CPSES Design Basis Document OBD ME 313. "Uninterruptable Power Supply Area Air Conditioning System", Revision 1, December 22,  :

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SUBAPPENDIX A2 LACK OF CONSTRUC"ION DETAILS FOR FABRICATION AND INS"ALLA"ION OF DUC' AND PLENUMS l f,JSaP Vll.c. APPENDIX 15) >

1.0 Definition of the Issue The issue was that for safety related HVAC duct and plenues, several hardware installations existed where the installation ,

specification and drawings did not contain sufficient construction  !

details describing the fabrication or installation of the

hardware.

2.0 Issue Resolution  !

Ebasco resolved this issue by establishing design criteria for safety-related HVAC duct and plenums in the Design Basis Document (DBD) (Reference 4.1). Ebasco developed design procedures (References 4.6, 4.7 and 4.9) which incorporate the design

I criteria. Ebasco performed engineering walkdowns in accordance with Field Verification Methods (FVMs) (References 4.4 and 4.8) to J develop new drawings of as built configurations of HVAC duct and plenums. Ebasco validated the duct and plenums by performing calculations in accordance with the design procedures (References -

4.6. 4.7 and 4.9). Design changes were identified for HVAC duct ,

and plenums if the calculations determined that the design criteria were not satisified. These design changes are being i

'"a**"d-O i EbAsco revised the HVAC installation specification (Reference 4.3)

! to ir. corporate sufficient details for fabrication and installation for HVAC duct and plenums. The construction procedures and l J Quainy Control (QC) in:pection procedures (References 4.2, 4.5,  ;

4.10 and 4.12) were revised to incorporate the requirements of the '

}j HVAC installation specification (Reference 4.3).

?l 3.0 Corrective and Preventive Action o No additional issues were identified during the review and t resolution of this issue.  !

o This issue was determined to btr reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR)CP-8554.

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3.1 Corrective Action Safety related HVAC duct and plenums were validated to comply with )

the design criteria by performing calculations in accordance with  ;

Ebasco design procedures (References 4.6, 4.7 and 4.9) using new as-built drawings. Design changes were identified as necessary and are being implemented. The installation specification was revised to incorporate sufficient details for fabrication and installation of the HVAC ouct and plenums. Construction procedures (References 4.5 and 4.12) and Quality Control (QC)

Inspection procedures (References 4.2 and 4.10) were updated to be consistent with the HVAC installation specification (Reference 4.3).

3.2 Preventive Action The revised and validated HVAC installation specification (Reference 4.3), the revised construction orocedures (References 4.5 and 4.12) and Quality Control (QC) i- pection procedures (Reference 4.2 and 4.10) assure that HV:( duct and plenums are properly installed. In addition Ebasco aesign and design control procedures (References 4.6, 4.7, 4.9 and 4.11) assure that the HVAC drawings contain sufficient construction details.

4.0 References 4.1 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

4.2 TU Electric NE0 Quality Assurance Department Instruction NQI-3.09-M-006, Verification / Inspection of Seismic HVAC Systems",

Revision 2.

4.3 TU Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and  :

Accessories", Revision 6.

4.4 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Common Areas", Revision 6.

4.5 TV Electric Construction Department Procedure CHV-101, "HVAC -

Detailing, Fabrication, Installation, Rework and Repair", Revision 2.

4.6 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 1, June 5, 1987.

4.7 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. 1 an( 2", Revision 4, December 15, 1987.

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4.8 CPE-EB-FVM-CS-066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Units 1 and Common Areas", Revision 2.

O 4.9 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air Handling Units, Plenums and Equipment Supports", Revision 0, June  !

29, 1987.

l 4.10 TV Electric NE0 Quality Assurance Department Procedure i NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC l Systems", Revision 2. <

4.11 Ebasco CPSES Manual of Procedures.

4.12 TU Electric Construction Department Procedure CHV-106, "Qualitative Walkdown of HVAC Supports and Ducts (Unit 1 and Common Areas)", Revision 4.

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SUBApPENDIX A3 I INACCURATE HVAC DUCT SUPPORT DETAIL ORAWINGS AND THEIR EFFECT ON THE DUCT SUPPORT DESIGNS l (ISAP VII.c. APPENDIX 31) 1.0 Definition of the Issue The issue was that some of the original safety-related duct support drawings did not accurately reflect the installed condition with regard to duct to support attachments, support configuration, member size and weld details.

2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for safety-related HVAC duct supports in the Design Basis Document (DBD) (Reference 4.1). Ebasco developed design procedures (References 4.6 and 4.7) which incorporate the design criteria.

Ebasco performed a walkdown in accordance with a Field Verification Method (FVM) (Reference 4.4) to develop new drawings of as-built configurations of HVAC duct supports. Ebasco validated these duct supports by performing calculations in accordance with design procedures (References 4.6 and 4.7). Design changes were identified for HVAC duct supports if the calculations .

determined that the design criteria were not satisfied. These design changes are being implemented.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and resolution of this issue.

o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP-85-54.

3.1 Corrective Action )

Safety-related HVAC duct supports were validated to comply with the design criteria by performing calculations in accordance with Ebasco design procedures (References 4.6 and 4.7) using new as-built drawings. Design changes were identified as necessary and are being implemented.

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3.2 Preventive Action Ebasco design and design control procedures (References 4.6, 4.7 O and 4.9) require that HVAC drawings for each new safety-related duct support contain sufficient construction details. The revised and validated HVAC installation specification (Reference 4.3), the revised construction procedure (Reference 4.5) and Quality Control (QC) inspection procedures (References 4.2 and 4.8) assure that HVAC duct supports are properb installed.

4.0 References 4.1 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

4.2 TV Electric NE0 Quality Assurance Department Instruction NQI-3.09-H-006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2.

4.3 TV Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 6.

4.4 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As Built Verification in Unit 1 and Common Areas", Revision 6.

4.5 TV Electric Construction Department Procedure CHV-101, "HVAC -

Detailing, Fabrication, Installation, Rework and Repair", Revision

2. I 4.6 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987. <

4.7 Ebasco Document SAG.CP24, "General Instructions for Seismic ,

Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.8 TV Electric NE0 Quality Assurance Department Procedure NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC Systems", Revision 2.

4.9 Ebasco CPSES Manual of Procedures.

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SUBAPPENDIX A4 INADE0VATE PR03 RAM FOR THE INSTALLATION AND OVALITY '

O co"Tao' toc) veatricatto" os svac ouct sueeoats (ISAP VII.c. APPENDIX 31)

(NRC IR 446/8602-V-17) 1.0 Definition of the Issue The issue was that the original HVAC duct support installation contractor's program for the installation and Quality Control (QC) verification of safety-related duct supports may have been inadequate.

2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for safety-related HVAC duct supports in the Design Basis Document (DBD) (Reference 4.1). Ebasco developed design procedures (References 4.6 and 4.7) which incorporate the design criteria.

Ebasco performed a walkdown in accordance with a Field Verification Method (FVM) (Reference 4.4) to develop new drawings of as-built configurations of HVAC duct supports. Ebasco validated these duct supports by performing calculaticas in accordance with design procedures (References 4 6 and 4.7). Design changes were identified for HVAC duct supports if the calculations determined that the design criteria were not satisifed. These design changes are being implemented.

O Ebasco revised the HvAC instaliatioa specification (Refereace 4.3) for HVAC duct supports. The construction procedure and Quality Control (QC) inspection procedures (References 4.2, 4.5 and 4.8) were revised to incorporate tne requirements of the HVAC installation specification (Reference 4.3). The original HVAC duct support installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TV Electric Quality Control (QC).

3.0 Corrective and Preventive Action j o No additional issues were identified during the review and resolution of this issue.

o This issue was determined to be reportable under the l provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report {

(SDAR) CP-85-54.

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3.1 Corrective Action p Safety-related HVAC duct supports were validated to comply with V the design criteria by performing calculations in accordance with Ebasco design procedures (References 4.6 and 4.7) using new as-built drawings. Design changes were identified as necessary and are being implemented. The installation specification was revised for fabrication and installation of the HVAC duct supports. The construction procedure (Reference 4.5) and Quality Control (QC) Inspection procedures (References 4.2 and 4.8) were updated to be consistent with the HVAC installation specification (Reference 4.3). The original HVAC duct support installation  :

contractor has been replaced and Quality Control (QC) inspections are now being performed by TU Electric Quality Control (QC).

3.2 Preventive Action The revised and validated HVAC installation specification (Reference 4.3), the revised construction procedure (Reference 4.5) and Quality Control (QC) inspection procedures (References 4.2 and 4.8) assure that HVAC duct supports are properly installed. In addition, Ebasco design and design control procedures (References 4.6, 4.7, and 4 9) assure that new HVAC duct support drawings contain sufficient construction details.  !

The original HVAC duct support installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TV Electric Quality Control (QC).

4.0 References 4.1 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct .

Supports", Revision 1, December 31, 1987. l 4.2 TU Electric NEO Quality Assurance Department Instruction i NQI-3.09-M-006, "Verification / Inspection of Seismic HVAC Systems", '

Revision 2.

4.3 TV Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 6.

4.4 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit I and Common Areas", Revision 6.

4.5 TV Electric Construction Department Procedure CHV-101, "HVAC - ,

Detailing, Fabrication, Installation, Rework and Repair", Revision l 2.

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4.6 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 1, June 5, 1987.

4.7 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.8 TU Electric NEO Quality Assurance Department Procedure NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC Systems", Revision 2.

4.9 Ebasco CPSES Manual of Procedures.

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I SUBAPPEN0tX A5 GROOVE WELOS O <tsae vit.c aeee"Otx ail (NRC IR 446/8620-V-02)

(NRC IR 446/8602-U-19) 1.0 Definition of the Issue The issue was that the inspection documentation for weld fit-up for groove welds on safety-related HVAC duct supports may have been inadequate. Also, the groove depths and required effective throat dimensions were not specified for square groove welds in the original HVAC duct support drawings.

2.0 h sue Resolution Ebasco resolved this issue by establishing design criteria for safety-related HVAC duct supports in the Design Basis Document (OBD) (Reference 4.1). Ebasco developed design procedures (References 4.6 and 4.7) which incorporate the design criteria.

Ebasco performed an engineering walkdown in accordance with a Field Verification Method (FVM) (Reference 4.4) to develop new  ;

drawings of the as-built configuration of HVAC duct supports. '

Groove welds are specifically identified on the as-built HVAC duct support drawings. Ebasco validated these duct supports by performing calculations in accordance with design procedures (References 4.6 and 4.7). These calculations did not take credit n for the existence of square groove welds identified on the l U drawings. Design changes were identified for HVAC duct supports if the calculations determined that the design criteria was not satisified. These design changes are being implemented.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and resolution of this issue.

o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the l conditions reported as Significant Deficiency Analysis Report '

(SDAR) CP-85-54.

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1 3.1 Corrective Action  !

Safety-related HVAC duct supports were validated to comply with l J the design criteria by performing calculations in accordance with Ebasco design procedures (References 4.6 and 4.7) using new as-built drawings. Design changes were identified as necessary and are being implemented.

3.2 Preventive Action The revised and validated HVAC installation specification (Reference 4.3), the revised construction proceduro (Reference 4.5) and Quality Control (QC) inspection procedures (References 4.2 and 4.8) assure that HVAC duct supports are properly installed, including requirements for groove weld fit-up inspections prior to welding. In addition Ebasco design and design control procedures (References 4.6, 4,7 and 4.9) assure that new HVAC duct support draw.ngs contain sufficient construction details. The original HVAC installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TU Electric Quality Control (QC).

4.0 References 4.1 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

4.2 TV Electric NEO Quality Assurance Department Instruction NQI-3,09-M-006, "Verification / Inspection of Seismic HVAC Systems",

O Revision 2.

4.3 TV Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 6.

4.4 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As Built Verification in Unit 1 and Common Areas", Revision 6.

l 4.5 TV Electric Construction Department Procedure CHV-101, "HVAC - ,

Detailing, Fabrication, Installation, Rework and Repair", Revision '

2.

4.6 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 1, June 5, 1987.

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4.7 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 4, December 15, 1987.

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4.8 TU Electric NE0 Quality Assurance Department Procedure i NQA-3.09-6.01, "Quality Control Inspection of. Safety Related HVAC Systems", Revision 2.

4.9 Ebasco CFSES Manual of Procedures.

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SV8 APPENDIX A6 (q

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LACK 0F DOCUMENTATION FOR RECEIPT INSPECTION BY THE ORIGINAL HVAC DUCT SUPPORT CONTRACTOR (ISAP VII.c. APPENDIX 31) 1.0 Definition of the issue The issue was that the original HVAC duct support installation contractor did not document receipt inspections for some material obtained from the primary site construction contractor.

2.0 Issue Resolution Ebasco resolved this issue by reviewing the instances identified and determining that, based on the Comanche Peak Response Team (CPRT) review of the primary site construction contractor's material control program (Reference 4.1), the material obtained by the original HVAC duct support installation contractor is acceptable.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and resolution of this issue.

o This issue was determined not to be reportable under the provision of 10CFR50.55(e).

3.1 Corrective Action No corrective action was required.

3.2 Preventive Action The revised and validated HVAC installation specification (Reference 4.2) provides the HVAC duct supports material requirements. The original HVAC installation contractor has been replaced and Quality Control (QC) receipt inspections are now being perfo.wed by TV Electric Quality Control (QC). HVAC duct support material is procured in accordance with TV Electric procedures (References 4.3 and 4.4). Upon receipt on site, HVAC duct support material is inspected, and inspections are documented, by Quality Control (QC) in accordance with Reference 4.6. The material is controlled in accordance with the site construction procedure (Reference 4.5).

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I 4.0 References  ;

4.1 CPRT Results Report, ISAP VII.a.1, "Material Traceability",

Revision 1.

4.2 TV Electric Specification 2323-MS-85, "HVAC Ducts, Louvers, and l Accessories", Revision 6. ,

l 4.3 TU Electric Engineering and Construction Engineering Procedure  !

ECE 6.02 "Preparation and Review of Procurement Documents", j Revision 0, November 19, 1987.

l 4.4 TV Electric Engineering and Construction Engineering Procedure ECE 6.02-12, "Engineering Review of Procurement Documents",  ;

Revision 0, June 1, 1987.  !

4.5 CPSES Construction Procedure CP-CPM 8.1, "Receipt, Storage and l Issuance of Items", Revision 5, December 1, 1987.

4.6 TV Electric NEO Quality Assurance Department Procedure NQA-3.09-11.02, "Construction Receiving Inspection", Revision 0, '

October 5, 1987.

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SUBAPPENDIX A7 3 INSUFFICIENT THREAD ENGAGEMENT AND J PRETENSIONING OF RICHMOND INSERT BOLTS ON HVAC DUCT SUPPORTS (ISAP VII.c. APPENDIX 31) 1.0 Definition of the issue The issue was that some safety-related HVAC duct suoports had Richmond Insert bolts installed which had less than the minimum specified thread engagement and were pretensioned causing possible damage to the insert assembly.

2.0 Issue Resolution Ebasco resolved this issue by revising the HVAC installation specification (Reference 4.1) to incorporate the acceptance criteria established by the SWEC Civil / Structural portion of the Corrective Action Program (CAP) through a testing program for pretensioned Richmond Insert bolts with less than the minimum specified thread engagement (Reference 4.2). The Field Verification Methods (FVMs) (P.efercnces 4.3 and 4.4), the construction procedure (Reference 4.5) and the Quality Control (QC) inspection procedures (References 4.6 and 4.7) were revised to incorporate the requirements of the HVAC installation specification (Reference 4.1).

The Field Verification Methods (FVMs) (References 4.3 and 4.4) q L

require determination of the as-installed Richmond Insert bolt threaf engagement lengths. As part of the Post Construction Hardware Validation Program (PCHVP) the installed Richmond Insert bolt thread engagement lengths are being meanred and reconciled with the validated design. Those Richmond Itsert bolts not meeting the requirements of the installation specification (Reference 4.1) are being replaced.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and resolution of this issue, o This issue was determined to be report.able under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP-85-54.

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3.1 Corrective Action  ;

l Ebasco revised the HVAC installation specification (Reference 4.1) hm to incorporate the acceptance criteria established by the SWEC Civil / Structural portion of the Corrective Action Program (CAP) through a testing program for pretensioned Richmond Insert bolts with less than the minimum specified thread engagement (Reference 4.2). The Field Verification Methods (FVMs) (References 4.3 and 4.4), the construction procedure (Reference 4.5) and the Quality Control (QC) inspection procedures (References 4.6 and 4.7) were revised to incorporate the requirements of the HVAC installation specification (Reference 4.1).

The Field Verification Methods (FVMs) (References 4.3 and 4.4) require determination of the as-installed Richmond Insert bolt thread engagement lengths. As part of the Post Contruction Hardware Validation Program (PCHVP) the installed Richmond Insert bolt hread engagement lengths are being measured and reconciled with the validated design. Those Richmond Insert bolts not meeting the requirements of the Field Verification Methods (FVMs) '

(References 4.3 and 4.4) are being replaced.

3.2 Preventive Action The revised and validated HVAC installation specification .

(Reference 4.1), the revised construction procedure (Reference 4.5) and Quality Control (QC) inspection procedures (References 4.6 and 4.7) assure that HVAC duct supports and Richmond Insert i bolts are properly installed. The original HVAC installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TV Electric quality Control (QC).

4.0 References l 4.1 TU Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 6.

4.2 CPSES Design Basis Document DBD-CS-015, "The Qualification of Embedments in Concrete", Revision 2, December 28, 1987.

4.3 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Comon Areas", Revision

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4.4 CPE-EB-FVM CS-066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Unit 1 l i

and Common Areas", Revision 2.

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4.5 TV Electric Construction Department Procedure CHV-101, "HVAC -

Detailing, Fabrication, Installation, Rework and Repair", Revision 2' '

C:) 4.6 TV Electric NEO Quality Assurance Department Instruction NQI-3.09-M-006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2.

4.7 TU Electric NE0 Quality Assurance Department Procedure NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC >

Systems", Revision 2. ,

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i SUBAPPENDIX A8 BATTERY ROOM VENTILATION O <"ac ta 44s'e422-u-os) 1.0 Definition of the Issue The issue was that the structural beams in the battery rooms create two large pockets in the overhead that are not directly swept by the ventilation system and could possibly allow a build-up of hydrogen emitted from the batteries.

2.0 Issue Resolution Ebasco resolved this issue by developing a design change in accordance with the design criteria specified in the Design Basis Document (DBD) (Reference 4.L) to modify the ductwork in the battery rooms so that the ventilation system exhausts the spaces between the structural beams, thus preventing any potential build-up of hydrogen. This design change is being implemented.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and resolution of this issue. .

o This issue was determined not to be reportable under the provisions of 10CFR50.55(e).

O u Corre14ve Act4en A design change was developed in accordance with the design  !

criteria specified in the Design Basis Document (DBD) (Reference '

4.1) to modify the ductwork in the battery rooms so that the ventilation system exhausts the spaces between the structural beams, thus preventing any potential build-up of hydrogen. This design change is being implemented.

3.2 Preventive Action The Design Basis Document (DBD) (Reference 4.1) provides the design criteria for battery room ventilation.

4.0 References 4.1 CPSES Design Basis Document DBO-ME-305, "Uncontrolled Access Area Ventilation System", Revision 1, December 22, 1987.

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1 SUBAPPENDIX A9 g BATTERY ROOM EXPLOSION PROOF THERMOSTATS (NRC IR 445/8601-U-02) 1.0 Definition of the Issue The issue was that insufficient documentation existed to determine if the thermostats inside the battery rooms needed to be installed  :

in explosion proof housings, )

2.0 Issue Resolution Ebasco resolved this issue by performing calculations which demonstrate that the validated design of the battery room ventilation system will maintain hydrogen concentration below 2%,

thus precluding the need for explosion proof housings for the thermostats. The calculations were performed in accordance with the design criteria as specified in the Design Basis Document l (DBD) (Re.ference 4.1) and are included in the HVAC System Design '

Validation fe kage (DVP).

3.0 Corrective and Praventive Action o No additional issues were identified during the review and .

resolution of this issue.

o This specific issue was determined not to be reportable under the provisions of 10CFR50.55(e).

3.1 Corrective Action Calculations were performed which demonstrate that the validated design of the battery room ventilation system will maintain hydrogen concentration below 2%, thus precluding the need for explosion proof housings for the thermostats. The calculations were performed in accordance with the design criteria as specified 1 in the Design Basis Document (DBD) (Reference 4.1) and are l included in the HVAC System Design Validation Package (DVP).

l 3.2 Preventive Action Design criteria to maintain hydrogen concentration below 2% is specified in the Design Basis Document (DBD) (Reference 4.1).

4.0 References 4.1 CPSES Design Basis Document DSD-ME-305, "Uncontrolled Access Area Ventilation System", Revision 1, December 22, 1987.

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SUBAPPENDIX A10 INSPECTION REPORTS 0 DATED PRIOR TO ISSUE OF AS-BUILT DRAWINGS (NRC IR 445/8626-0-07)

I 1.0 Definition of the Issue The issue was that typical duct support configuration drawings  :

were used for inspections. However, the inspection reports did '

not document the specific typical. duct support configurations used. As a result, there was no evidence of inspection performed '

to verify the duct support configuration to the subsequently '

developed as-built drawing.

2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for HVAC supports in the Design Basis Document (DBD) (Reference 4.8).

Ebasco developed design procedures (References 4.3 through.4.7) which incorporate the design criteria. 'Ebasco performed engineering wa Rdowns in accordance with Field Verification Methods (FVMt) (References 4.J and 4.2) to determine the as-built configuration of HVAC supports. Ebasco then validated these -

supports by parforming calculations in accordance with Ebasco i design procedures (References 4.3 through 4.7). Design changes +

were identified for HVAC supports if the calculations determined that the design criteria was not satisfied. These design changes O$ are being implemented.

} 3.0 Corrective and Preventive Action o No additional issues were identified during the review and ,

resolution of this issue. j o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP-85-54.

3.1 Corrective Action l HVAC supports were validated to comply with the design criteria by j- performing calculations in accordance with Ebasco design

procedures (References 4.3 through 4.7) using new as-built 1 j information. Design changes were identified as necessary and are  !

being implemented.

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-3.2 Preventive Action c The revised and validated HVAC installation specification (Reference 4.9), the revised construction procedures (References 4.10 through 4.12) and Quality Control (QC) inspection procedures (References 4.13 and 4.14) assure that HVAC duct supports are properly installed and inspected to the design drawings. Ebasco design and design control procedures (References 4.3 through 4.7 and 4.15) require that a design drawing be developed and issued for each duct support. The original HVAC installation contractor's Quality Control (QC) organization has been replaced.

Quality Control (QC) inspections are now being performed by TU Electric Quality Control (QC).

4.0 References d

4.1 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit I and Common Areas," Revision 6.

4.2 CPE-EB-FVM-CS-066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in linit I and Common Areas', Revision 2.

4.3 Ebasco Document SAG.CP23 "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987 4.4 Ebasco Document SAG.CP24 "General Instructions for Seismic

(')N

(. Category I HVAC Duct and Duct Support Analysis for Comanche Peak ,

Steam Electric Station Nos. 1 and 2", Revision 4, December 15, 1987.

4.5 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air '

Handling Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

4.6 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, October 1, 1987.

4.7 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, December 15, 1987.

4.8 CPSES Design Basis Document 080-CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

4.9 TV Electric Specification 2323-MS-85, "HVAC Oucts, Louvers and Accessories", Revision 6.

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4.10 TV Electric Construction Department Procedure CHV-101, "HVAC -

Detailing, Fabrication, Installation, Rework and Repair", Revision 2

O 4.11 TV Electric Construction Department Procedure ECC 10.99-HV-003, "HVAC Field Requisitions", Revision 0, April 29, 1987.

4.12 TU Electric Construction Department Procedure CHV-106, "Qualitative Walkdown of HVAC Supports and Ducts (Unit 1 and Common Areas)", Revision 4.

4.13 TV Electric NEO Quality Assurance Department Procedure NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC Systems", Revision 2.

4.14 TV Electric NEO Quality Assurance Department Instruction NQI-3,09-M-006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2.

4.15 Ebasco CPSES Manual of Procedures.

O 4

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SUBAPPENDIX All WELDER OUALIFICATION O ("ac ta 44s'8826-v-o8) 1.0 Definition of the issue The issue was that welder performance qualification records dated May 1979, June 1981 and March 1983 certify welders as being qualified in more positions and material thickness ranges than allowed by ASME Section IX for the welder qualification tests performed.

2.0 Issue Resolution Ebasco resolved this issue by determining that AWS 01.1 (Reference 4.2) for structural steel welding and AWS D9.1 (Reference 4.3) for sheet metal welding are more appropriate for welding on HVAC ducts and HVAC supports than Section IX of the ASME Boiler and Pressure Vessel Code. Ebasco revised the HVAC installation specification (Reference 4.1) to include AWS D1.1 and AWS D9.1. Ebasco reviewed the welder qualification test results to the requirements of AWS 01.1 and AWS D9.1. This reviev determined that the welders were qualified for the positions and material thicknesses identified in the welder performar.ce qualification records.

3.0 Corrective and Preventive Agliga o No additional issues were identified during the review and O resolution of this issue.

o This issue was determined not to be reportable under the provisions of 10CFR50.55(e).

3.1 Corrective Action The HVAC installation specification (Reference 4.1) was revised to permit the use of AWS 01.1 (Reference 4.2) and AWS 09.1 (Reference 4.3) for welding of HVAC ducts and supports. Ebasco reviewed the welder qualification test results to the requirements of AWS 01.1 and AWS 09.1. This review determined that the welders were qualified for the positions and material thicknesses identified in the welder performance qualification records. Ebasco reviewed the present HVAC installation contractor's welding procedures to assure compliance with the HVAC installation specification (Reference 4.1).

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3.2 Preventive Action The original HVAC l'.stallation contractor has been replaced. The O "vac iast 11 tioa saecific tioa (aerer ace 4 1) a== deea revised to permit the use of AWS D1.1 (Reference 4.2) and AWS 09.1 (Reference 4.3) for welding of HVAC ducts and supports.

Welders are qualified by the present HVAC installation contractor in accordance with the requirements of the applicable Codes (AWS D1.1 and/or 09.1). These codes provide instructions for welder

. qualification which include specific requirements for welder qualification, testing, documentation, marking and identification, as well as review, approval and surveillance to assure Code compliance.

4.0 References 4.1 TU Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 5, September 15, 1987.

4.2 American Welding Society (AWS) D1.1-77, "Structural Welding Code",

1977.

4.3 American Welding Society (AWS) D9.1-80, "Specification for Welding of Sheet Metal",1980. .

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SUBAPPENDIX All q NRC CAT INSPECTION RESULTS (CPRT-DIR *E-0278) 1.0 Definition of the Issue The issues were that installed and Quality Control (QC) accepted HVAC duct and HVAC supports did not conform to design requirements. In addition, inspection procedures were not established or executed to verify conformance of HVAC supports to design drawings.

Also, certain aspects of HVAC installation and inspection were not adequately controlled, including improperly qualified welding procedures and improperly qualified Quality Control (QC) personnel.

2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for HVAC duct and HVAC supports in the Design Basis Document (DBD)

(Reference 4.8). Ebasco developed design procedures (References 4.3 through 4.7) which incorporate the design criteria. Ebasco performed engineering walkdowns in accordance with Field -

Verification Methods (FVMs) (References 4.1 and 4.2) to determine the as-built configuration of HVAC duct and HVAC supports. Ebasco  ;

then validated these duct and duct supports by performing i D

V calculations in accordance with Ebasco design procedures (References 4.3 through 4.7). Design changes were identified if the calculations determined that the design criteria was not satisfied. These design changes are being implemented.

The issue of inadequate installation and inspection controls was resolved as follows:

1. The original HVAC duct and HVAC supports installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TV Electric Quality Control (QC).

2. Ebasco reviewed the present HVAC installation contractor's welding procedures to assure compliance with the HVAC installation specification (Reference 4.9).

3. The welding procedures used by the original HVAC duct and HVAC supports installation contractor were reviewed and found to be acceptable.

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4. As built information was obtained by engineering walkdowns conducted in accordance with Field Verification Methods (FVMs) (References 4.1 and 4.2). To provide additional O assurance of the accuracy of the as-built drawings and any required rework, reinspection of the HVAC duct and HVAC supports installed by the previous contractor is being performed by TV Electric Quality Control (QC) personnel in accordance with References 4.10 and 4.11.

3.0 Corrective and Preventive Action o No: additional issues were identified during the review and '

resolution of this issue. l o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP 85-54.

3.1 Corrective Action HVAC duct and HVAC supports were validated to comply with the design criteria by performing calculations in accordance with Ebasco design procedures (References 4.3 through 4.7) using as-built information. Design changes were identified as necessary

- t and are being implemented. The original HVAC duct and HVAC supports installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TU Electric Quality Control (QC) to verify the acceptability of installed O components. The welding procedures which were used by the original HVAC duct and HVAC supports installation contractor have been reviewed and found to be acceptable. l 3.2 Preventive Action The Ebasco design procedures (References 4.3 through 4.7) which incorporate the design criteria as specified in the Design Basis '

Document (DBD) (Reference 4.8) assure adequate design of HVAC duct  ;

and HVAC supports. The original HVAC duct and HVAC supports '

installation contractor has been replaced and Quality Control (QC) inspections are now being performed by the TV F.lectric Quality Control (QC). Ebasco reviewed the present HVAC installation  ;

contractor's welding procedures and determined that they comply with the HVAC installation specification (Reference 4.9).  :

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4.0 References 4.1 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct O a aser As Buiit verificatioa ia uait t aad co==oa areas" aevisioa 6.

4.2 CPE-EB-FVM-CS-066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Unit l' and Common Areas", Revision 2.

4.3 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987.

4.4 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.5 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air Handling Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

4.6 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Doct Supports", Revision 2, October 1, 1987.

4.7 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, ,

December 15, 1987.

> 4.8 CPSES Design Basis Document DBD CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

4.9 TU Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and l Accessories", Revision 6.

7 4.10 TU Electric NEO Quality Assurance Department Procedure NQA-3.09 6.01, "Quality Control Inspection of Safety Related HVE Systems", Revision 2.

4. 5.1 TU Electric NEO Quality Assurance Department Instruction NQI-3.09-M 006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2.

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SUBAPPENDIX A13 SEISMIC OESIGN OF HVAC SUPPORTS h- (CPRT-DIR #E-1046) 1.0 Definition of the Issue The issue was that the seismic design of the HVAC supports may not have been adequate.

2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for HVAC supports in the Design Basis Document (DBD) (Reference 4.8).

Ebasco developed design procedures (References 4.3 through 4.7) which incorporate the design criteria. Ebasco performed engineering walkdowns in accordance with Field Verification Methods (FVMs) (References 4.1 and 4.2) to determine the as-built configuration of HVAC supports. Ebasco validated these supports for seismic design adequacy, by performing calculations in accordance with Ebasco design procedures (References 4.3 through 4.7). Design changes were identified for HVAC supports if the calculations determined that the design criteria were not satisfied. These design changes are being implemented.

l 3.0 Corrective Action and Preventive Action o No additional issues were identified during the review and resolution of this issue.

o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP 85-54.

3.1 Corrective Action HVAC supports were validated to comply with the design criteria by performing calculations in accordance with Ebasco design procedures (References 4.3 through 4.7) using as-built information. Design changes were identified as necessary and are being implemented.

3.2 Preventive Action l The Ebasco design procedures (References 4.3 through 4.7) which incorporate the design criteria as specified in the : Design Basis ,

Document (DBD) (Reference 4.8) assure adequate seismic design of HVAC supports.

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4.0 References 4.1 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Ouct and Duct O " aser As-euiit verific tioa ia uait i ae co= oa Are s".

Revision 6.

4.2 CPE-EB-FVM-CS 066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Unit 1 and Common Areas", Revision 2.

4.3 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987.

4.4 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 4, December 15, 1987.

4.5 Ebasco Document SAG.CP30. "Seismic Design Criteria for Air Handling Units, Plenums and Equips nt Surpcrts", Revision 0, June 29, 1987.

4.6 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, October 1, 1987. .

4.7 Ebasco Document SAG.CP32. "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, 2

December 15, 1987.

4.8 CPSES Design Basis Document 0R0 CS-086, "HVAC Ouct and Duct

Supports", Revision 1, December 31, 1987.

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SUBAPPENDIX A14 HVAC DUCT AXIAL RESTRAINT O <ceat-orR e-127t>

1.0 Definition of the issue This issue was that an HVAC duct within the Containment Building may not have had sufficient axial restraint to prevent buckling of the duct during a seismic event.

2.0 !ssue Resolution Ebasco resolved this issue by establishing design criteria for HVAC supports in the Design Basis Document (DBD) (Reference 4.8).

Ebasco developed design procedures (References 4.3 througn 4.7) which incorporate the design criteria. Ebasco performed engineering walkdowns in accordance with Field Verification Methods (FVMs) (Reference 4.1 and 4.2) to determine tne as-built configuration of HVAC supports. Ebasco validated these supports for adequacy of axial restraints by performing calculations in accordance with Ebasco design procedures (References 4.3 through 4.7). Design changes were identified for HVAC supports if the calculations determined that the design criteria were not satisfied. These design changes are being implemented. .

3.0 Corrective Action and Preventive Action o No additional issues were identified during the review and O resolution of this issue.

o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the i conditions reported as Significant Deficiency /,nlaysis Report l (SDAR) CP-85-54.

i

) 3.1 Corrective Action HVAC supports were validated to comply with the design criteria by performing calculations in accordince with Ebasco design procedure.s (Reference 4.3 through 4.7) using as built 3 information. Design changes were identified as necessary and are being implemented.

3.2 Preventive Action The Ebasco design procedures (Referer::es 4.3 through 4.7) which incorporate the design criteria as specified in the Design Basis  ;

Document (DBD) (Reference 4.8) assure adequate seismic design of HVAC supports.

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4.0 Egferences 4.1 CPE-EB.FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct

( )) Hanger As Built Verification in Unit 1 and Common Areas", Revisioa 6.

4.2 CPE-EB FVM CS-066, "Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Unit I and Common Areas", Revision 2.

4.3 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1 June 5,1987.

4.4 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.5 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air Handling Units, Plenums and Equipment Supports", Revision 0, Ju'ne 29, 1987.

4.6 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports". Revision 2. October 1, 1987. .

4.7 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, December 15, 1987.

4.8 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

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i SUBAPp2NDIX A15 l

t SEISMIC INTERACTION OF HVAC DUCT O <Ceat-Dia e-o2s>> '

l.0 Definition of the Issue l  !

The issue was that there may have been inadequate consideration  ;

for seismic interaction of containment HVAC duct with  :

safety-related itens.  !

l 2.0 Issue Resolution Ebasco resolved this issue by establishing design criteria for  ;

HVAC duct and HVAC supports, including the HVAC duct and HVAC i i supports in the containment, in the Design Basis Document (DBD) '

(Reference 4.6). Ebasco developed design procedures (References i

4.2 through 4.5) which incorporate-the design criteria. Ebasco '

d performed engineering walkdowns in accordance with a Field j Verification Method (FVM) (Reference 4.1) to determine the  ;

as-built configuration of HVAC duct and HVAC duct supports. '

q Ebasco then validated these duct and duct supports for seismic design adequacy, by performing calcula.tions in accordance with .

Ebasco design procedures (References 4.2 through 4.5). Design  !

changes were identified for HVAC duct and HVAC duct supports if -

the calculations determined that the design criteria were not l i satisfied. These calculations, in conjunction with the design-i changes, assure that the containment HVAC duct and HVAC duct ,

, r~g supports will not fail during a seismic event such that  :

4

(_/ safety related items would be adversely affected. These design i j changes are being implemented. i I

3.0 Corrective and Preventive Action j l o No additional issues were identified during the review and j resolution of this issue. l a  ;

! o This issue was determined to be reportable under the l l provisions of 10CFR50.55(e). This issue was part of the  ;

) conditions reported as Significant Deficiency Analysis Report  :

(SDAR) CP-85-54.

i i 3.1 Corrective Action y t

HVAC duct and HVAC duct supports, including the HVAC duct and the .

l HVAC duct supports in the containment, were validated to comply  !

, with the seismic design criteria by perfortting calculations in  :

{ accordance with Ebasco design procedures (References 4.2 though  !

4.5) using as-built information. Design changes were identified  !

as necessary and are being implemented.

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3.2 Preventive Action The Ebasco design procedures (References 4.2 through 4.5) which

() incorporate the design criteria as speciiied in the Design Basis Document (DBD) (Reference 4.6) assure adequate seismic design of HVAC duct and HVAC duct supports.

4.0 References 4.1 CPE-EB-FVM CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Common Areas", Revision 6.

4.2 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam .

Electric Station Nos. I and 2", Revision 1, June 5, 1987. t 4.3 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.4 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, October 1, 1987.

4.5 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, December 15, 1987.

! () 4.6 CPSES Design Basis Document DBD CS 086, "HVAC Duct and Duct Supports", Revision 1, December 31, 1987.

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SUBAPPENDIX A16 CYGNA CONDUIT AND CABLE TRAY ISSUES O 1.0 Definition of the Issue The following issues were identified by CYGNA for conduit and cable tray disciplines. These issues were reviewed by Ebasco and issues applicable to HVAC were identified. Conduit issues are indicated and all other issues are cable tray issues. The definition of these issues is presented in Appendix A of the Cable Tray and Cable Tray Hangers Project Status Report (PSR) (Reference 4.9) and Appendix A of the Conduit Supports Trains A and B, and Train C larger than 2 inch diameter Project Status Report (PSR)

(Reference 4.10).

Issues

1. Measurement of Embedment From Top of Concrete Topping (Conduit issue)

2. Bolt Hole Tolerance and Edge Distance Violation (Conduit Issue)

3. Controlling Load Case for Design

4. Seismic Response Combination Method

5. Anchor Bolt Design -

6. Design of Compression Members

7. Vertical and Transverse Loading on Longitudinal Type Support n 8. Support Frame Dead and Inertial Loads

' 9. Design of Angle Braces Neglecting Loading Eccentricity

10. Dynamic Amplification Factors

11. Reduction in Member Section Properties Due to Bolt Holes

, 12. System Concept

13. Validity of NASTRAN Models (Not applicable to HVAC)

14. Working Point Deviation Study

15. Reduced Spectral Accelerations

16. Non-Conformance With AISC Specifications

17. Member Substitution

18. Weld Design and Specifications

19. Embedded Plate Design

20. Tray Clamps (System to Support Connections)

21. FSAR Load Combination

22. Differences Between Installation and Design / Construction Drawings without Appropriate Documentation

23. Design Control

24. Design of Support No. 3136, Detail "5", Cable Tray Hanger Orawing 2323-S-0905 (Not applicable to HVAC)

25. Loading in STRESS Models

26. Design of Flexural Members

27. Cable Tray Qualification (System - Structural Qualification)

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28. Base Angle Desiga >

. 29. Support Qualification by Similarity (Not applicable to i n HVAC) .;

() 30. Critical Support Configurations and Loadings

31. Cumulative Effect of Review Issues a

2.0 Issue Resolution i

Ebasco resolved the applicable HVAC' issues in Paragraph 1.0 above [

, during the design validation process. The resolutions were i incorporated into the HVAC Field Verification Methods (FVMs)

(References 4.1 and 4.2), the Design Basis Document (DBD) i (Reference 4.8), the design procedures (References 4.3 through

, 4.7) and the HVAC installation specification-(Reference 4.11). In i addition, Ebasco reviewed the revised construction procedures i

! (References 4.12 through 4.14) and Quality Control (QC) inspection ,

i procedures (References 4.15 and 4.16) to assure that they comply j with the HVAC installation specification _(Reference 4.11).

l 3.0 Corrective Action and Preventive Action- l 1  ;

o No additional issues were identified during the review and i resolution of these issues.

o This issue was determined to be reportable under the -

provisions cf 10CFR50.55(e). This issue was part of the-  !

] conditions reported as Significant Deficiency Analysis Report (SDAR) CP 85 54.  ;

I 3.1 Corrective Action ,

l 4

The applicable HVAC issues in Paragraph 1.0 above were resolved  ;

) during the design validation process. The resolutions were l

incorporated into the HVAC Field Verification Methods (FVMs)

(References 4.1 and 4.2), the Design Basis Document (DBD) j (Reference 4.8), the design procedures (References 4.3 through i 4.7) and the HVAC installation specification (Reference 4.11). In l addition, Ebasco reviewed the revised construction procedures

(References 4.12 through 4.14) and Quality Control. (QC) inspection J procedures (References 4.15 and 4.16) to assure that they comply 1 with the HVAC installation specification (Reference 4.11).

3.2 Preventive Action The design procedures (References 4.3 through 4.7), which

! incorporate the design criteria as specified in the Design Basis l

Document (DBD) (Reference 4.8), assure adequate design of HVAC duct and HVAC supports. The HVAC installation specification 1

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(Reference 4.11), the construction procedures (References 4.12 through 4.14) and the Quality Control (QC) inspection procedures (References 4.15 and 4.16) assure adequate installation and O 'asPectio" or "v^c d"ct "d "vac suaaorts-4.0 References 4.1 CPE-EB-FVM CS-029, "Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Common Areas",

Revision 6.

4.2 CPE-EB-FVM-CS-066, "Procedure for As-Suilt Verification of Seismic HVAC Air Handling Units, Plenums and Equipment Supports in Unit 1 and Common Areas", Revision 2.

4.3 Ebasco Document SAG.CP23, "Scismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revisien 1 June 5, 1987.

4.4 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. 1 and 2", Revision 4, December 15, 1987.

4.5 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air .

Handling Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

n 4.6 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II Q HVAC Duct and Duct Supports", Revision 2, October 1, 1987.

4.7 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, '

December 15, 1987.

4.8 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct 1 Supports", Revision 1, December 31, 1987.

4.9 TV Electric CPSES Unit 1 and Comon, Impell Corporation and Ebasco Services Incorporated Project Status Report (PSR), "Cable Tray and Cable Tray Hangers", Revision 0.  !

l 4.10 TV Electric CPSES Unit 1 and Common, Ebasco Services Incorporated Project Status Report (PSR), "Conduit Supports Trains A and B and Train C Larger Than 2 Inch Diameter", Revision 0.

4.11 TU Electric Specification 2323-MS-85, "HVAC Ducts, Louvers and Accessories", Revision 6.

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4.12 TV Electric Construction Department Procedure CHV-101, "HVAC -

Detailing, Fabrication, Installation, Rework and Repair", Revision

() 4.13 TV Electric Construction Department Procedure CHV-106,  !

"Qualitative Walkdown of HVAC Supports and Ducts (Unit I and '

Common Areas)", Revision 4.

a 4.14 TV Electric Construction Department Procedure ECC 10.99-HV 010, "HVAC Grouting of Base Members with Ceilcote 658 N Epoxy Grout",

Revision 1, July 23, 1987.

4.15 TV Electric NEO Quality Assurance Department Procedure NQA-3.09-6.01, "Quality Control Inspection of Safety Related HVAC Systems", Revision 2.

4.16 TU Electric NEO Quality Assurance Department Instruction

. NQI 3.09-M-006, "Verification / Inspection of Seismic HVAC Systems",

Revision 2.

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SUBAPPENDIX A17 CASE /CYGNA CABLE TRAY ISSUES l O 1.0 Definition of the Issue The following issues were identified by CASE /CYGNA for the cable tray discipline. These issues were reviewed by Ebasco and applicable HVAC issues were identified. The definition of these issues is presented in Appendix A of the Cable Tray and Cable Tray Hangers Project Status Report (PSR) (Reference 4.7).

Issues

1. System Damping Values

2. Modeling of Boundary Conditions 2.0 Issue Resolution Ebasco resolved the applicable HVAC issues in Paragraph 1.0 above during the design validation process. The resolutions were

- incorporated into the Design Basis Document (DBD) (Reference 4.6) and the design procedures (References 4.1 through 4.5).

3.0 Corrective Action and Preventive Action o No additional issues were identified during the review and resolution of these issues.

o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP-85-54.

3.1 (2rJtttive Action The applicable HVAC issues in Paragraph 1.0 above were resolved during the design validation process. The resolutions were incorporated into the Design Basis Document (DBD) (Reference 4.6) and the design procedures (References 4.1 through 4.5).

i 3.2 Preventive Action The design procedures (References 4.1 through 4.5), which incorporate the design criteria as specified in the Design Basis Document (DBD) (Reference 4.6), assure adequate seismic design of l HVAC duct and HVAC supports. '

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4.0 References 4.1 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic O Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1, June 5, 1987.

4.2 Ebasco Document SAG.CP24. "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak Steam Electric Station Nos. I and 2", Revision 4, December 15, 1987.

4.3 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air Handling Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

4.4 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, October 1, 1987.

4.5 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, December 15, 1987.

4.6 CPSES Design Basis Document DBD-CS-086, "HVAC Duct and Duct '

Supports", Revision 1, December 31, 1987.

4.7 TV Electric CPSES Unit I and Common, Impell Corporation and Ebasco Services Incorporated Project Status Report (FSR), "Cable Tray and Cable Tray Hangers", Revision 0.

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SUBAPPENDIX A18 OTHER HVAC ISSUES 1.0 Definition of the Issue 1.1 The issue was that some HVAC supports had gaps in excess of 1/16 inch between the concrete and the base angle of the support. This gap between the base angle and the concrete was not included on the original contractor's as-built drawings of the support. (NRC IR 446/8602-U-18) I 1.2 The issue was that in some instances gaps existed between duct and duct supports which were not identified on the original contractor's duct support as-built drawings.

1.3 The issue was that some transverse supports were constructed with the duct welded to the support member thus forming a connection which may cause longitudinal load to be transferred to transverse supports from the duct.

1.4 The issue was that original tests performed on ducts included only axial compression loads for determination of duct load capacity.

1.5 The issue was that the original HVAC test program may not have .

adequately addressed the effects of openings on duct section properties or duct load capacity.

p 1.6 The issue was that the HVAC duct sleeves, in which the original v fire dampers were installed, may not have been properly designed for seismic loading.

1.7 The issue was that the original duct support design methodology for evaluating the cantilever portion of the support's base angle may not have included all applicable loadings to assure that no buckling of the vertically projected angle leg occurs. 3 l

1.8 The issue was that non-perpendicularity of drilled-in concrete expansion anchors was not included in the original contractor's as built drawings for HVAC supports and therefore may not have l been considered in the support design, i l

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1.9 The issue was that the original construction details of the HVAC duct did not consistently meet the requirements of the SMACNA and q ERDA codes which were specified in the orginal HVAC installation y specification.

1.10 The issue was that loose counterweights and counterbalance arms were identified on some gravity dampers. (! SAP VII.c. Appendix 16) 2.0 Issue Resolution Ebasco resolved these issues as follows:

2.1 Ebasco performed engineering walkdowns in accordance with Field Verification Methods (FVMs) (References 4.1 and 4.9) which identified supports with base member gaps in excess of 1/16 inch.

These gaps are being grouted to comply with the requirements of the revised and validated HVAC installation specification (Reference 4.6).

1 2.2 Ebasco performed engineering walkdowns in accordance with a Field i

Verification Method (FVM) (Reference 4.1) which identified supports with gaps between the duct support and the duct. These ,

gaps are being shimmed to comply with the requirements of the revised and validated HVAC installation specification (Reference -

4.6).

2.3 Ebasco performed engineering walkdowns in accordance with a Field C' Verification Method (FVM) (Reference 4.1) which identified the as-built transverse support configuration. These configurations were design validated by performing calculations in accordance with the Ebasco design procedures (References 4.2 through 4.5).

Design changes were identified for those supports if calculations determined that the design criteria were not satisfied. These j design changes are being implemented.

2.4 Ebasco performed new static tests (Reference 4.7) of duct specimens, including tests with axial tension loads applied, which provided data for the determination of the ultimate strength of the duct as constructed at CFSES Unit 1 and Common. These data were used to confirm the allowable stress limits. These allowable stress limits were used for the design validation of the HVAC duct.

2.5 Ebasco performed new static tests (Reference 4.7) of duct ,

specimens, including tests on specimens with openings, which '

provided data for the determination of the ultimate strength of the duct as constructed at CPSES Unit I and Common. These data were used to confirm the allowable stress limits. These allowable stress limits were used for the design validation of the HVAC duct.

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2.6 The original fire dampers and HVAC duct sleeves in HVAC duct are being replaced for unrelated reasons. The new fire dampers and sleeves have been procured as Seismic Category I components and are O beins iastalled as Se4smic Catesor, i compoaeats ia safety reiated HVAC duct.

2.7 Ebasco design procedures (References 4.3 and 4.5) specify the applicable loadings for evaluating HYAC duct supports, including the cantilever portion of the support's base angle. The design validation of base angles was performed in accordance with these design procedures.

2.8 Ebasco performed engineering walkdowns in accordance with Field Verification Methods (FVMs) (References 4.1 and 4.9) which identified HVAC supports with drilled-in concrete expansion anchors which did not meet the perpendicularity requirements of the revised and validated HVAC installation specification (Reference 4.6). The ,

identified HVAC support concrete expansion anchors are being '

modified to comply with the revised and validated HVAC installation specification.

2.9 Ebasco performed new static tests (Reference 4.7) of duct specimens which provided data for the determinat. ion of the ultimate strength  :

of the duct as constructed at CPSES Unit 1 and Common. These data were used to confirm the allowable stress limits. These allowable .

stress limits were used for the design validation of the HVAC duct.

2.10 Modifications are being implemented to tack weld the counterweights and counterbalance arms in place.

3.0 Corrective Action and preventive Action o No additional issues were identified during the review and resolution of these issues, o This issue was determined to be reportable under the provisions of 10CFR50.55(e). This issue was part of the conditions reported as Significant Deficiency Analysis Report  ;

(SDAR) CP 85-54.

3.1 Corrective Action Design criteria for HVAC duct and HVAC supports were established and documented in the Design Basis Document (DBD) (Reference 4.8).

Design procedures (References 4.2 through 4.5 and 4.10) were developed which incorporate the design criteria. Engineering walkdowns were performed in accordance with Field Verification Methods (FVMs) (References 4.1 and 4.9) to determine the as built configuration of HVAC duct and HVAC supports. These duct and supports were validated by performing calculations in accordance with design procedures (References 4.2 through 4.5 and 4.10).

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Design changes were identified for HVAC duct and HVAC supports if the calculations determined that the design criteria were not satisfied. These design changes are being implemented.

O New static tests (Reference 4.7) were performed on HVAC duct specimens which provided data confirming the allowable stress limits of duct as constructed at CPSES Unit I and Common. The HVAC installation specification was revised and validated to assure proper installation of HVAC duct and HVAC supports. The revised i construction procedures (References 4.11 through 4.13) and revised Quality Control (QC) inspection procedures (References 4.14 and 4.15) were reviewed to assure consistency with the revised and validated HVAC installation specification (Reference 4.6),

3.2 Preventive Action l-Design criteria for HVAC duct and HVAC supports were established and documented in the Design Basis Document (DBD) (Reference 4.0). Dasign procedures (References 4.2 through 4.5 and 4.10) were developed which incorporate the design criteria.

The HVAC installation specification was revised and validated to assure proper installation of HVAC duct and HVAC supports. The revised construction procedures (References 4.11 through 4.13) and revised Quality Control (QC) inspection procedures (References .

4.14 and 4.15) were reviewed to assure consistency with the revised and validated HVAC installation specification (Reference 4.6). The original HVAC installation contractor has been replaced and Quality Control (QC) inspections are now being performed by TV O Electric Quality Control (QC).

4.0 References 4.1 CPE-EB-FVM-CS-029, "Procedure for Seismic HVAC Duct and Duct

, Hanger As-Built Verification in Unit 1 and Common Areas", Revision ,

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i 4.2 Ebasco Document SAG.CP23, "Seismic Design Criteria for Seismic Category I HVAC Ducts and Duct Supports for Comanche Peak Steam Electric Station Nos. I and 2", Revision 1. June 5, 1987.

4.3 Ebasco Document SAG.CP24, "General Instructions for Seismic Category I HVAC Duct and Duct Support Analysis for Comanche Peak i Steam Electric Station Nos. I and 2", Revision 4, December 15, l 1987. I 4.4 Ebasco Document SAG.CP31, "Design Criteria for Seismic Category II HVAC Duct and Duct Supports", Revision 2, October 1, 1987.

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4.5 Ebasco Document SAG.CP32, "General Instructions for Seismic Category II HVAC Duct and Duct Support Analysis", Revision 2, December 15, 1987.

O 4.6 TU Electric Specification 2323 MS 85, "HVAC Ducts Louvers and

Accessories", Revision 6. i 4.7 Corporate Consulting Development Company, Ltd., "Test Report for Static load test of HVAC Duct Work for Comanche Peak Steam 1

Electric Station (CPSES)", CCL Report No. A-749 87, October 23,

1987. ,

4.8 CPSES Design Basis Document 080-C5 086, "HVAC Duct and Duct  !

Supports", Revision 1, December 31, 1987. t 4.9 CPE-EB-FVM-CS 066, "Procedure for As Built Verification of Seismic  !

HVAC Air Handling Units, Plenums and Equipment Supports in Unit 1 '

and Common Areas", Revision 2.

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4.10 Ebasco Document SAG.CP30, "Seismic Design Criteria for Air j Handling Units, Plenums and Equipment Supports", Revision 0, June 29, 1987.

t 4.11 TU Electric Construction Department Procedure CHV-101, "HVAC -  !

j Detailing, Fabrication, Installation, Rework and Repair", Revision -

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4.12 TV Electric Construction Department Procedure CHV-106, '

"Qualitative Walkdown of HVAC Supports and Ducts (Unit 1 and j O Common Areas)", Revision 4.

4.13 TU Electric Construction Department Procedure ECC 10.99 HV-010 "HVAC Grouting of Base Members with Cellcote 658 N Epoxy Grout",

j Revision 1 July 23, 1987.

4.14 TU Electric NEO Quality Assurance Department Procedure NQA 3.09 6.01, "Quality Control Inspection of Safety Related HVAC l Systems", Revision 2. l 4

I l 4.15 TV Electric NEO Quality Assurance Departmer.t Instruction

NQI 3.09 M-006, "Verification / Inspection of Seis;aic HVAC Systems",

Revision 2.

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i SUBAPPENDIX A19 m ENVIRONMENTAL CONDITIONS AND RE0VIREMENTS i V fIRR DAP E-EIC 503)

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1.0 Definition of the issue The issue was that inadequate calculations existed for determining temperatures in plant areas.

2.0 Issue Resolution Ebasco resolved this issue by establishing the design criteria for plant ambient temperatures for applicable plant operating modes (except for the loss of non safety-related HVAC systems following i a loss of offsite power). These design criteria are specified in the Design Basis Documents (DB0s) (References 4.2 through 4.15). ,

Ebasco performed new calculations to determine temperatures which demonstrate compliance with the design criteria. These calculations were performed in accordance with Ebasco design control procedures (Reference 4.1). These procedures require that i

calculations be checked and independently reviewed to assure accuracy.

Ebasco also performed calculations to determine temperatures, in -

areas outside containment which contain safety-related equipment, resulting from loss of non safety-related HVAC systems following a loss of-offsite power. The results of these calculations were ,

pd transmitted to Impell for use in the equipment qualification portion of the Corrective Actior. Program (CAP) as described in the Equipment Qualification Project Status Report (PSR) (Reference i

4.16). These calculations were performed in accordance with Ebasco design control procedures (Reference 4.1). These procedures require that calculations be checked and independently reviewed to assure accuracy.

3.0 Corrective and Preventive Action o No additional issues were identified during the review and i resolution of this issue

, o This issue was determined to be reportable under the provisions of 10CFR50.55(e). Inadequate calculations for determining temperatures except during loss of non-safety-related HVAC systems following a loss-of-offsite power, were part of the conditions reported as Significant

Deficiency Analysis Report (SDAR) CP 85-41 in letter number TXX 4659, dated Decemba 20, 1985 from TV Electric to the NRC. Loss of non-safety-related HVAC systems, outside containment, following a loss of-offsite power and its impact on environmentil qualification of safety-related equipment were part of the conditions reported as Significant Deficiency Analysis Report (SDAR) CP 84-27 in letter number ,

TXX-4409, dated March 6, 1985 from TU Electric to the NRC. '

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3.1 Corrective action The design criteria were established for the plant ambient O temperatures for applicable plant operating modes (except for the loss of non safety related HVAC systems following a i

loss-of offsite power). These design criteria are specified in ,

the Design Basis Documents (DBDs) (References 4.2 through 4.15). -

- Ebasco performed new calculations to determine temperatures which demonstrate compliance with the design criteria. These calculations were performed in accordance with Ebasco design  !

control procedures (Reference 4.1). These procedures require that '

calculations be checked and independently reviewed to assure accuracy.

Ebasco also performed calculations to determine temperatures, in areas outside containment which contain safety-related equipment, resulting from loss of non-safety related HVAC systems following a loss-of-offsite power. The results of these calculations were transmitted to Impell for use in the equipment qualification portion of the Corrective Action Program (CAP) as described in the Equipment Qualification Project Status Report (PSR) (Reference 4.16). These calculations were performed in accordance with Ebasco design control procedures (Reference 4.1). These procedures require that calculations be checked and independently reviewed for accuracy. . ,

3.2 Preventive Action The design criteria, which specify the plant ambient temperatures O for applicable plant operating modes, are specified in the Design Basis Documents (DBDs) (References 4.2 through 4.15). The Ebasco design control procedures (Reference 4.1) require that  ;

calculations be checked and independently reviewed to assure  ;

accuracy.

4.0 References 4.1 Ebasco CPSES Hanual of Procedures 4.2 CPSES Design Basis Document DBD ME-300, "Containment Ventilation Systems", Revision 1 December 22, 1987.

4.3 CPSES Design Basis Document DBD-ME 301, "Containment Air Cleanup Systems", Revision 1. December 22, 1987.

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i 4.4 CPSES Design Basis Document DBD ME-302, "Safeguards Building Ventilation System", Revision 1, December 22, 1987.

O 4.5 CPSES Design Basis Document DBD ME-302A, "Diesel Generator Area Ventilation System", Revision 1, December 22, 1987.

4.6 CPSES Design Basis Document DBD ME.3028, "Electrical Area HVAC System", Revision 3, February 4, 1988.

4.7 CPSES Design Basis Document DBD ME 302C, "Mainsteam and Feedwater Area Air Conditioning System", Revision 1, December 22, 1987.

4.8 CPSES Design Basis Document DBD ME-303, "Auxiliary Building Ventilation System", Revision 1, December 22, 1987.

4.9 CPSES Design Basis Document DBD ME-303 01, "Fuel Handling Building Ventilation System", Revision 1, December 22, 1987.

4.10 CPSES Design Basis Document DBD ME-304, "Control Room Air Conditioning System", Revision 1, December 22, 1987.

4.11 CPSES Design Basis Document DBD ME-305, "Uncontrolled Access Area

Ventilation System", Revision 1, December 22, 1987. >

s 4.12 CPSES Design Basis Document DBD ME-309, "Primary Plant Ventilation .

System," Revision 2, February 12, 1988. l l 4.13 CPSES Design Basis Document DBD ME 311. "Safety Chilled Water System", Revision 1, December 22, 1987.

O 4.14 CPSES Design Basis Document DBD ME-312. "Service Water Intake Structure Ventilation System", Revision 1, December 22, 1987.

4.15 CPSES Design Basis Document DBD ME-313. "Uninterruptable Power

. Supply Area Air Conditioning System", Revision 1, December 22, ,

a 1987. ,

4.16 TU Electric CPSES Unit 1 and Common, Impe11 Corporation Project i

Status Report (PSR), "Equipment Qualification", Revision 0,  ;

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APPENDIX B O 1ssues rots'trito ouat"o Tat etaroaa^"ce OF THE CORRECTIVE ACTION PROGRAM (CAP)

This appendix describes the details of the resolutions of issues  !

determined to be reportable under the provisions of 10EFR50.55(e) that were identified during the performance of the HVAC portion of the Corrective Action Program (CAP). Included in these appendices are HVAC systems and component-related Significant Deficiency Analysis Reports (SDARs) initiated by TV Electric. Specific references to the criteria, procedures and desip changes which have resolved the issue are provided.

To report the resolution of the issues identified during performance of the Corrective Action Program (CAP), an individual Subappendix was developed for each issue. Each Subappendix includes: a definition of the tssue; issue resolution; and corrective and preventive action.

The preventive action is embodied in the procedures and Design Basis Documents (DBDs) developed and used in the HVAC portion of the Corrective Action Program (CAP). These procedures and Design Basis Documents (DBDs) resolve the HVAC Corrective Action Program (CAP) issues. Implementation of these preventive actions will assure that the design and hardware for .

CPSES Unit I and Common will continue to comply with the licensing comitments throughout the life of the plant as described in Socion 5.4.

Corrective Action Program (CAP) issues contained in Appendix B are listed below:

Issue NL Issue Title 91 SDAR CP-87-124, Xomox Valves B2 SDAR CP-88 08 Class lE Battery Room Temperature l

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SUBAPPENDIX B1 SDAR CP 87-124. X0MOX VALVES O

1.0 Definition of the Issue The issue was that for Xomox plug or butterfly valves with Limitorque 90 degree electric motor operators with H BC gears, the potential may exist for certain components in the drive train within

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the operator or between the operator and the valve stem to move out of correct engagement. This issue was identified by Xomox Corporation (Reference 4.1).

2.0 Issue Resolution Ebasco resolved this issue by identifying the specific application where such valves are utilized at CPSES Unit I and Common (control of component cooling water flow to the condensers of the Control Room air conditioning units), and contacting the Xomox Corporation.

Xomox Corporation has advised (Reference 4.2) that replacement drive parts to resolve this issue are available from them. These replacement parts are being procured from Xomox.

3.0 Corrective and Preventive Action .

No additional issues were identified during the review and resolution of this issue.

O This issue was determined to be reportabia under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis

Report (SDAR) CP-87-124 in letter TXX-7141, dated December 30, 1987 from TV Electric to the NRC.

3.1 Corrective Action Replacement parts for the components identified as potentially i defective by Xomox Corporation (Reference 4.1) are being procured.

The replacement parts are to be installed subsequent to delivery, i

3.2 Preventive Action ,

1 lite issue deals with a vendor item which was found defective by the l vendor. The vendor is addressing the preventive action to prevent recurrence. '

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I f I 4 4.0 References  ;

1 1 4.1 Xomox Corporation Letter, from D.J. Hobson to C. K111ough of TU l'

! Electric, dated October 16, 1987.

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4.2 Xomox Corporation Letter, from D.J. Hobson to C. Killough of TU j i Electric, dated November 5, 1987.  ;

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SUBAPPENDIX 92 i SDAR CP-88 09. CLASS lE BATTERY ROOM TEMPERATURE 1.0 Definition of the Issue r

The issue was that the batteries are required to be sized to provide ,

their required output at 70*F. However, the Heating, Ventilation i

and Air Conditioning (HVAC) system design allowed for a minimum temperature of 40*F during a loss of Offsite Power, when the non Class IE unit heaters will not be operating.  :

2.0 issue Resolution Ebasco resolved this issue by revising the design criteria of the Class 1E battery room Heating Ventilation and Air Conditioning ,

(HVAC) system to provide a minimum room temperature of 70*F under l required plant operating conditions. This revised criteria is [

specified in the Design Basis Document (DBD) (Reference 4.1).

Design modifications for compliance with the revised criteria are j being implemented.

j 3.0 Corrective and Preventive Actions 1

No additional issues were identified during the review and -

resolution of this issue.  ;

I This issue was determined to be reportable under the provisions of l O

ioc'a5o 55(-)- tt > raaart d >= sis"$ric="t o 'ici "cx ^">'r='=

Report (SDAR) CP-88 08, in letter number TXX 88067, dated January 13, 1988 from TV Flectric to the NRC, t 3.1 Corrective Action l The design criteria of the Class 1E battery room Heatint, l Ventilation and Air Conditiong (HVAC) system was revised by Ebasco ,

to specify a minimum room temperature of 70'F under required plant j operating conditions. This revised criteria is specified in the i Design Basis Document (DBD) (Reference 4.1). Design modifications  !

i for compliance with the revised criteria are being implemented.

2 3.2 Preventive Action l The design criteria for the ambient temperature requirements in the t Class 1E battery rooms have been documented in the Design Basis Document (DBD) (Reference 4.1).

j 4.0 References '

4.1 CPSES Design Basis Document DBD ME-305, "Uncontrolled Access Area .

. Ventilation System", Revision 1. December 22, 1987.  :

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