ML20151W314
| ML20151W314 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/31/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| References | |
| NUREG-0797, NUREG-0797-S15, NUREG-797, NUREG-797-S15, NUDOCS 8808240043 | |
| Download: ML20151W314 (183) | |
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NUREG-0797 Supplement No.15 l
! Safety Evaluation Report related to the operation of Comanche Peak Steam E ectric Station,
- Units 1 and 2 Docket Nos. 50-445 and 50-446 Texas Utilities Electric Company, et al.
l U.S. Nuclear Regulatory Commission Office of Special Projects July 1988 l
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.. I NOTICE.
. Availability of Reference Materials Cited in NRC Publications i
Most documents cited in NRC publications will be available from one of the following sources:
- 1. The NRC Public Document Room l1717 H Street, N.W. ~
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Washington, DC 20555 -
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- 2. The Superintendent of Documents, U.S. Government Printing Office, Post Office Box 37082;-
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Washington, DC 20013 7082 -
- 3. The National Technical Information Service,-Springfield, VA 22161 L
Although the listing that follows represents the majority of documents cited in NRC publications,.
l it is not intended to be exhaustive.
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Referenced documents available for inspectiot, and copying for a fee from the NRC Public'Docu.
l ment Room include NRC correspondence and internal NRC memorandai NRC Office of Inspection l
and Enforcement bulletins, circulars, information notices, inspection and investigation noticeo.
Licensee Event Reports: vendor reports and correspondence; Commission papers; and applicant and -
licensee documents and correspondence.
The following documents in the NUREG series are available for purchase from the GPO Sales Program: formal NRC staff and contractor reports, NRC sponsored conference proceedings, and
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NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of.
- Federal Regulations, and Nuclear Regulatory Commission issuances.
Documents available from the Nat onal Technical Information Service include NUREG series i
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Copies of industry codes and standards used in a substantive manner in the NRC regulatory process q
L are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available l
U there for reference use by the public. Codes and standards are usually copyrighted and may be.
L purchased from the originating organization or, if they are American National Standards, from the '
i American National Standards institute,1430 Broadway, New York,- NY 10018, i
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NUREG-0797 Supplement No.15 Safety Evaluation Report related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 Texas Utilities Electric Company, et al.
U.S. Nuclear Regulato.y Commission Office of Special Projects July 1988 p*"*m, f'y'.1,+,
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ABSTRACT Supplement 15 to the Safety Evaluation Report related to the operation of the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 (NUREG-0797), has been prepared by the Office of Special Projects of the U.S. Nuclear Regulatory Commission (NRC).
The facility is located in Somervell County, Texas, approximately 40 miles southwest of Fort Worth, Texas.
This supplement presents the staff's evaluation of the applicant's Corrective Action Program (CAP) related to the design of cable trays and cable tray hangers.
The scope and methodologies for the CAP workscope as summarized in Revision 0 to the cable tray and cable tray hanger project status report and as detailed in related documents referenced in this evaluation were developed to resolve various design issues raised by the Atomic Safety and Licensing Board (ASLB);
the intervenor, Citizens Association for Sound Energy (CASE); the Comanche Peak Response Team (CPRT); CYGNA Energy Services (CYGNA); and the kRC staff.
The NRC staff concludes that the CAP workscope for cable trays and cable tray hangers provides a comprehensive program for resolving the associated technical concerns identified by the ASLB, CASE, CPRT, CYGNA, and the NRC staff and its implementation ensures that the design of cable trays and cable tray hangers at CPSES satisfies the applicable requirements of 10 CFR Part 50.
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TABLE OF CONTENTS Pa2!!
ABSTRACT.................................................................
iii PRINCIPAL CONTRIBUTORS...................................................
vii ABBREVIATIONS............................................................
ix 1
INTRODUCTION........................................................
1-1 2
SOURCE OF ISSUES....................................................
2-1 3
OVERVIEW
SUMMARY
3-1 3.1 CPRT Program Plan..............................................
3-1 3.2 TV Electric Corrective Action Program..........................
3-2 4
CORRECTIVE ACTIONS..................................................
4-1 4.1 Applicant Actions - TU Electric Corrective Action Program Process........................................................
4-1 4.1.1 Design Criteria, Analytical Methodologies, and Acceptance Criteria..............................
4-3 4.1.2 Design Validation....................................
4-21 4.1.3 Hardware Validation..................................
4-27 4.1.4 Final Reconciliation.................................
4-28 4.1.5 Final Documentation..................................
4-29 4.2 Third-Party Actions............................................
4-29 4.2.1 CPRT Review (TENERA, L.P.)...........................
4-29 4.2.2 TV Electric Technical Audit Program..................
4-32 4.2.3 CYGNA Energy Services Review.........................
4-32 5
PREVENTIVE ACTIONS..................................................
5-1 6
CONCLUSIONS.........................................................
6-1 7
REFERENCES.........................................................
7-1 APPENDIX A - RESOLUTION OF CABLE TRAY HANGER TECHNICAL ISSUES APPENDIX B - RESOLUTION OF OPEN ITEMS FROM NRC INSPECTION REPORTS APPENDIX C - RESOLUTION OF OPEN ITEMS FROM SUPPLEMENT 13 TO NUREG-0797 APPENDIX D - CHRON0 LOGY OF NRC STAFF MEETINGS, AUDITS, AND INSPECTIONS RELATED TO CABLE TRAY HANGER DESIGN APPENDIX E - PROJECT AND CPRT DOCUMENTS FOR CABLE TRAY HANGERS APPENDIX F - CYGNA HEARING ISSUES RELATED TO CABLE TRAYS AND CABLE i
1 TRAY HANGERS Comanche Peak SSER 15 v
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PRINCIPAL CONTRIBUTORS l
NRC Staff Organization i
D. Terao ComanchePeakProjectDivision/
Office of Special Projects-e i
Consultants P.- Bezier Brookhaven National Laboratory-G. Breidenbach Brookhaven National Laboratory W. Grossman Brookhaven National Laboratory W. P. Chen Independent l
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ABBREVIATIONS ACI American Concrete Institute AISC American Institute of Steel Construction AISI American Iron and Steel Institute ANSI American National Standards Institute ARS amplified response spectrum (a)
ASLB Atomic Safety and Licensing Board AWS American Welding Society B&R Brown & Roet, Incorporated CAP Corrective Action Program CASE Citizens Association for Sound Energy CCL Corporate Consulting and Development Company Ltd.
CFR Code of Federal Regulations CPRT Comanche Peak Response Team CPSES Comanche Peak Steam Electric Station CTH cable tray hanger CYGNA CYGNA Energy Services DAF dynamic amplification factor DAP Design Adequacy Program DBCP Design Basis Consolidation Program DBD design-basis document l
DIR discrepancy / issue resolution report DSAP discipline-specific action pla" DVP design validation packagc j
Ebasco Ebasco services Incorporated EFE engineering functional evaluation I
ESA equivalent :;tatic analysis ESM equivalent static method FSAR final safety analysis report FSE field support engineering FVM field verification method G&H Gibbs and Hill, Incorporated HVAC heating, ventilation, and air conditioning IAP Independent Assessment Program Impell Impe11 Corporation ISAP issue-specific action plan i
LOCA loss-of-coolant accident Comanche Peak SSER 15 ix
MRM multimode response multiplier-NCIG Nuclear Construction Issue Group NCR nonconformance report NEO Nuclear Engineering and Operations NRC U.S. Nuclear Regulatory Commission OBE operating basis earthquake PCHVP Post-Construction Hardware Validation Program i
PI projectinstruction PSR project status report 2
QA quality assurance QC quality control QOC quality of construction RG regulatory guide RIL review issues list RSM response spectrum method SDAR significant deficiency analysis report SER safety evaluation report SRSS square root of the sum of the squares SRT Senior Review Team SSE safe shutdown earthquake SSER supplemental safety evaluation report SWEC Stone & Webster Engineering Corporation TAP Technical Audit Program l
TENERA TENERA, L.P. (formerly TERA Corporation)
TRT Technical Review Team TU Electric Texas Utilities Electric Company (formerly TUGCO) 1 TUGC0 Texas Utilities Generating Company l
VWAC Visual Weld Acceptance Criteria f
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4 1 INTRODUCTION In September 1984, Texas Utilities Electric Company (TV Electric), lead spli-cant for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, established the Comanche Peak Response Team (CPRT) and formulated the CPRT Program Plan and issue-specific action plans to address issues identified by the U.S. Nuclear Regulatory Commission (NRC) staff in its reviews of technical concerns and allegations pertaining to the CPSES plant.
As the CPRT Program-Plan evolved, its scope was expanded to include (1) the resolution of all design, construction, testing, and quality assurance / quality control issues raised in the Atomic Safety and Licensing Board (ASLB) proceedings, in the 1
Independent Assessment Program conducted by CYGNA Energy Services (CYGNA), and in other NRC staff reviews, and (2) the development of self-initiated reviews to broadly examine the adequacy of the design and construction of the CPSES plant.
In early 1987, TV Electric evaluated the preliminary results of the CPRT self-initiated reviews as the investigative phase of these reviews was completed.
As a result of the numerous, broad-scope findings, TU Electric initiated a comprehensive Corrective Action Program (CAP) that consisted of a complete design and hardware validation and provided for an integrated resolution of identified problem areas rather than a resolution of each issue.
In the design 3
area, ongoing design validation activities from the CPRT Program Plan were incorporated into the CAP, which was divided into the following 11 design workscopes:
(1) mechanical systems (2) electrical systems (3) instrumentation and control (4) civil / structural (5) large-bore piping (6) small-bore piping 1
(7) cable trays and cable tray hangers l
(8) conduit supports (Trains A and B, and Train C larger than 2 inches in diameter) j j
(9) conduit supports (Train C less than or equal to 2 inches in diameter)
(10) heating, ventilttion, and air conditioning I
(11) equipment qualification Comanche Peak SSER 15 1-1
i The applicant contracted with three major design organizations - Ebasco Serv-ices Incorporated (Ebasco), Impe11 Corporation (Impell), and Stone & Webster Engineering Corporation (SWEC) - to perform the activitie'. r6 lated to the 11 design workscopes.
This supplement presents the NRC staff's safety evaluation of the CAP design workscope for cable trays and cable tray hangers.
The CAP contractors for cable trays and cable tray hangers are Ebasco and Impell.
The staff reviews of the remaining ten CAP design workscopes have been or will be addressed in separate supplements to the Safety Evaluation Report.
The staff's evaluation of the CPSES cable tray and cable tray hanger activities provided in this supplement covers a wide range of subjects that cannot be pre-sented appropriately in the usual safety evaluation report (SER) formst used for licensing activities.
Therefore, the format in this supplement will be used for the staff evaluations of the TU Electric CAP.
Section 2 of this supplement discusses the background and source of the issues of concern.
Section 3 provides an overview summary of the corrective actions taken by the applicant.
Section 4 discusses the staff's evaluation of the corrective actions including the design criteria and methodologies used in the CAP.
Section 5 provides the staff's evaluation of the applicant's preventive actions including the programmatic and quality assurance aspects.
Section 6 presents the staff's overall conclusions.
Section 7 lists the references cited in this report.
Availability of all reference material cited is described on
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the inside front cover of this report or in a footnote to the reference list.
4 Appendix A provides the staff's review and evaluation of the resolution of the technical issues associated with cable trays and cable tray hangers.
Appendix B describes the resolution of open items related to cable tray and cable tray i
hanger design from previous NRC inspection reports.
Appendix C describes the resolution of open items related to the design of cable trays and cable tray hangers from SER Supplement 13.
Appendix D provides a chronology of NRC staff meetings, audits, and inspections associated with this workscope.
Appendix E lists design procedures and criteria used by TU Electric, Ebasco, and Impell in the CAP cable tray and cable tray hanger design validation as well as review documents prepared by the CPRT third party, Appeadix F discusses the staff evaluation of cable tray and cable tray hanger issues raised in the ASLB hear-i ings on CYGNA's Independent Assessment Program.
l Mr. Christopher I. Grimes, the NRC Comanche Peak Project Division Director, is managing and coordinating all the outstanding regulatory actions for CPSES.
Mr. Grimes may be contacted by telephone at (301) 492-3299 or by mail at the 3
following address:
Mr. Christopher I. Grimes, Director 1
j Comanche Peak Project Division Office of Special Projects Mail Stop 7H-17 U.S. Nuclear Regulatory Commission Washington, DC 20555 Comanche Peak SSER 15 1-2
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/l Copies of this supplement.are' available for public inspection at (1) the NRC's Public Dccument Room located at 1717 H Street,-NW, Washingto1, DC 20555, (2)
'the Local Public Document Room located at the Somervell County Public Library on the Square,.P.O. Box 1417f Glen Rose, TX 76043, and (3) the mini Local Public Document Room at the University of Texas at Arlington Library, 701 South Cooper, P.O. Box 19447, Arlington, TX 76019.
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2 SOURCE OF ISSUES In 1982, the applicant for the Comanche Peak Steam Electric Station (CPSES) was involved in a heavily contested hearing before the Atomic Safety and Licensing Board (ASLB).
The primary contention was Contention 5
- Contention 5 was broadly interpreted by the ASLB to apply to quality assurance in regard to the design and construction of CPSES.
The ASLB also permitted the intervenor, Citizens Associatio;. for Sound Energy (CASE), to raise questions related to potential design deficier.cies that allegedly were not caught under the design control program.
Hearings held on design issues in 1982 and 1983 focused l
primarily on piping and pipe supports.
In early 1983, concurrent with the ASLB hearings, the staff asked the applicant to conduct an independent verification program in regard to the quality of i
design and construction activities at CPSES.
In requesting this independent 4
verification program, the staff was seeking additional assurance that the de '
sign process used at CPSES complied with NRC regulations and licensing commit-ments.
The applicant submitted a plan for an Independent Assessment Program (IAP) for CPSES to be performed by CYGNA Energy Services (CYGNA).
In November 1983, CYGNA submitted the results of the draft IAP Phases 1 and 2 (Reference 1) to the staff and the applicant.
The CYGNA IAP report (Phases 1 and 2) was a j
iimited-scope assessment of a portion of the design control process and its implementation that included design control, pipe stress, pipe supports, equip-ment qualifications, structural (cable tray hangers) results, electrical i
results, and walkdown results.
In its IAP, CYGNA concluded that the overall design activities at CPSES were adequate and were properly implemented.
t Subsequently, the ASLB issued its preliminary findings on the design issues in its Memorandum and Order ("Quality Assurance for Design"), dated December 28, 1983 (Reference 2).
The ASLB found that the applicant had not demonstrated the existence of a system to promptly correct design deficiencies and concluded i
that the applicant was not in compliance with Part 50 of Title 10 of the Code of Federal Regulations (M CFR Part 50), Appendix B.
The ASLB urged that a
The applicant's failure to adhere to the quality assurance / quality control (QA/QC) provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically l
in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit i
2, weiding, inspection and testing, materials used, craf t labor qua,-
ifications and working conditions (as they may affect QA/QC), and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility.
As a result, the Commission cannot make the findings required by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche Peak.
Comanche Peak SSER 15 2-1
third party independently review the technical issues addressed in the hearings.
The applicant again contracted with CYGNA to perform this review and referred to this review as Phases 3 and 4 of the CYGNA IAP.
Phase 3 was directed pri-marily toward a review of the piping and pipe support designs for selected systems.
Phase 4 was primarily a multidisciplined review of a portion of the main steam and component cooling water systems for Un'.t 1 that included design control, as-built walkdown, pipe stress, pipe support, mechanical system, electrical, instrumentation and control, cable tray support, and conduit support reviews.
Because of the conclusions in the draft IAP report for Phases 1 and 2, CYGNA personnel appeared as witnesses before the ASLB in hearings held during Feb-ruary, April, and May 1984 to testify on the quality of design at CPSES.
In the cource of their testimony, CYGNA witnesses responded to numerous questions pnsed by O SE on specific piping, pipe support, and cable tray design issues pertaining to the scope of work in the draft IAP report for Phases 1 and 2.
The hearings indicated that several items required further explanations by CYGNA. When errata completing the CYGNA IAP Phases 1 and 2 report were issued on October 12, 1984 (Reference 3), these hearing items had not oeen fully resolved.
The staff evaluation of the unresolved items pertaining to cable trays and cable tray hangers from the CYGNA hearings with respect. to their applicability to the current designs under the CAP design validation is pro-vided in Appendix F to this supplement.
In a letter from N. H. Williams (CYGNA) to V. Noonap (NRC) dated January 25, 1985 (Reference 4), CYGNA (1) retracted its conclusions previously established in Phases 1, 2, and 3 of its IAP because of information obtained through later reviews and conclusions affected by a cumulative effects assessment across all phases of the IAP and (2) identified many open and unresolved issues remaining fr'om its IAP (Phase 4) that were related to cable tray and conduit support design.
In a letter from N. H. Williams (CYGNA) to J. Beck (TUGCO*), dated April 4, 1985 (Reference 5),
CYGNA summarized in its review issues list (RIL) all its findings and open items from Phases 1, 2, 3, and 4 of the IAP.
The CYGNA IAP (Phases 1. 2, 3, and 4) revealed many design conceras relatea to pipe stress, cable tray, and conduit support design.
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- TUGC0 = Texas Utilities Generating Company, Comanche Peak SSER 15 2-2
3 OVERVIEW
SUMMARY
j 3.1 CPRT Program Plan Because of numerous design issues identified in regard to the design of cable trays and cable tray hangers at CPSES, the Comanche Peak Response Team (CPRT) developed an action plan to identify and correct design deficiencies relating' i
l to these components.
This discipline specific action plan (DSAP) was part c.'
i the overall CPRT Program Plan to address and resolve all technical concerns relating to the adequacy of design, quality of construction, quality assurance /
quality control, and testing at CPSES.
The "Comanche Peak Response Team Program Plan and Issue-Specific Action Plans,"
Revision 2, was issued on June 28, 1985.
Revision 3 was issued on January 27, 1986, and Revision 4 was issued on June 18, 1987.*
The NRC staff evaluated Revision 3 to the CPRT Program Plan in SER Supplement 13, dated May 1986 (Ref-erence 6).
In regard to cable trays and cable tray hangers, DSAP VIII was developed as part of the Design Adequacy Program (DAP) under the charter of the CPRT Program Plan.
Initially, DSAP VIII involved a review by the CPRT of the cable tray /
conduit support issues raised by CYGNA and the NRC Technical Review Team and a self-initiated review of the civil / structural areas of concrete design, struc-tural steel design, heating, ventilation, and air conditioning (HVAC) and i
other component support design.
As the CPRT Program Plan evolved, the scope of DSAP VIII was expanded to include project ** activities involving a cable tray and cable tray hanger design verification program and a third-party review of this program.
The project activit.ies were to be performed by Ebasco and Impell, and the third party activities were to be performed by TENERA, L P.
(formerly known as TERA Corporation).
DSAP VIII continued to provide for the resolution of all identified technical concerns and a self-initiated evaluation of the CPSES quality of construction and adequacy of design to investigate ad-ditional areas so that its conclusions could be extended to the balance of the CPSES plant.
The scope of the cable tray and cable tray hanger design verifica-tion program was essentially all encompassing.
Consequently, the scope of the self-initiated review was established for all other safety-related civil /
structural discipline design processes that were not covered by the cable tray and cable tray hanger or conduit support design verification activities.
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- Revisions 0 and 1 of the CPRT Prcgram Pian, which were issued on October 8 and November 21, 1984, respectively, provided a plan for the resolution of only those issues identified by the NRC Technical Review Team's inspection at CPSES conducted fron July to September 1984.
The cable tray and cable tray hanger issues identified in the ASLB hearings and by CYGNA were not' included.
- "Project" includes the TU Electric organization and its contractors (e.g.,
Ebasco and Impell) responsible for design activities.
Comanche Peak SSER 15 3-1
In Section 3.5.3 of Supplement 13 (Reference 6), the staff in its evaluation of the cable tray and cable tray hanger design verification found that the scope, process, and structure for the program were acceptable.
Additionally, the staff stated that it would assess the completion of tt.e program objectives through technical sudits performed during the implementation of the program.
3.2 TU Electric Corrective Action Program In April 1987, as the investigative phase of the DAP (Appendix A to the CPRT Program Plan) neared completion, TV Electric became aware of the numerous and broad-scope findings of the CPRT's self-initiated design reviews.
Subsequently, TV Electric decided to initiate a comprehensive Corrective Action Program (CAP) involving a complete design validation of 11 design workscopes to be performed by three major design organizations.
The design workscopes and the responsible CAP contractors are:
(1) mechanical systems (SWEC)*
(2) civil / structural (SWEC)
(3) electrical systems (SWEC)
(4) instrumentation and control (SWEC)
(5) large-bore piping (SWEC)
(6) small-bart piping (SWEC)
(7) heating, ventilation, and air conditioning (Ebasco)
(8) cable trays and cable tray hangers (Ebasco and Impell)
(9) conduit supports (Trains A and B, and Train C larger than 2 inches in diameter) (Ebasco)
(10) conduit supports (Train C less than or equal to 2 inches in diameter)
(Impell)
(11) equipment qualification (Impell)
The establishment of the CAP made the continuation of some CPRT overview and corrective action activities unnecessary and resulted in a redirection of the CPRT's assessment of design adequacy.
The a.oplicant described thv. CAP to the NRC staf f in letters from W. G. Counsil, dated January 29, June 25, August 20, August 28, Scptember 8, and September 23, 1987 (References 7, 8, 9, 10, 11, and 12, respectively).
As a result of the establishment of the CAP and the com-1 pletion of the CPRT investigative activities, Revision 4 to the CPRT Drogram 1
Plan was issued on June 18, 1987 (Reference 13) to refler.t the CPRT Program Plan's revised scope of work.
The staff provided its evaluation of Revision 4 to the CPRT Program Plan and of the overall CAP in a letter from S. D. Ebneter to W. G. Counsil (TV Electric) dated January 22, 1988 (Reference 14).
- Impell is perfo ming the design validation of fire protection, and Ebasco is j
performing that of systems interaction.
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i The scope of the cable tray and cable tray hanger design verification program l
being implemented by Ebasco under Revision 3 to the CPRT Program Plan (0 SAP VIII) was not significantly affected by the establishment of the CAP.
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cable tray and cable tray hanger design verification program was incorporated into the CAP and reformatted so that it was consistent with the Design Basis l
Consolidation Program (0BCP)* (Reference 15), and its overall scope was expanded.
The cable tray and cable tray hanger program as described in Attach-ments 2 and 4 of DSAP VIII of the CPRT Program Plan (Reference 13) evolved into the design validation component of the CAP for cable trays and cable tray hangers.
The CPRT self-initiated reviews in the civil / structural design areas i
evolved into a complete design validation of the civil / structural design and of the HVAC design under the CAP.
The staff evaluations of the civil / structural i
j and HVAC design activities under the CAP have been or will be discussed in supplements to the SER.
This supplement addresses the overall CAP process for cable tray and cable tray hanger design, each of its components, and the effectiveness of the third party c
reviews.
The CAP process in regard to cable trays and cable tray hangers con-i sists of the development of design-basis documents, design validation, hardware l
validation, final reconciliation, and final documentation.
The staff's evalu-ation of the CAP process and its elements is provided in Section 4.1 of this i
1 supplement.
1 The staff evaluated the activities completed by the third party (TENERA) under the CPRT Program Plan's DAP for cable trays and ca i tray hangers (0 SAP VIII) i through several design audits and inspections.
The staff's evaluation of TENERA's activities and associated reports is provided in Section 4.2.1 of this 1
supplement.
The resolution of open items identified during previous NRC staff l
inspections of TENERA activities as documented in NRC Inspection Report 50-445/P3-19; 50-446/86-16, dated November 4, 1986 (Reference 16), is provided 1
in Appendix B to this supplement.
The third party review activities that were transferred from TENERA to the TV Electric Technical Audit Program (TAP) as a result of the CPRT redirection are y
described in the foreword to Appendix A to Revision 4 of tha CPRT Program Plan (Reference 13).
The staff's review and evaluation of the effectiveness of the i
TAP activities related to cable trays and cable tray hangers are provided in Section 4.2.2 of this supplement.
The open items identified in the Independent Assessment Program (IAP) conducted
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l by CfGNA from 1983 to 1985 nave been eddressed under both the CPRT Program Plan l
and the Corrective Action Program.
In addition, since Navember 1986, TU i
Electric has been actively pursuing the resolution of the open IAP issues with
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CYG4A in meetings between CYGNA and the CAP contractors.
CYGNA has been docu-i menting in review issues lists (Reference 5) the status of the CYGNA open items related to cable trays and cable tray hangers.
The staff's evalustion of the CYGNA activities is provided in Section 4.2.3-of this supplement.
I The staff has completed its audits and inspections of the cable tray and cable tray hanger design validation and third party activities and concludes that the effectiveness and completeness of the program's 1mplementation are sufficient
- The applicant uses the OBCP to manage the CAP and ensure consistency of each contractor's activities and products.
Comanche Peak SSER 15 3-3
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to ensure that Itcensing commitments are satisfied and that the_ cable tray and cable tray hanger issues raised by the intervenor (CASE), CYGNA, the NRC staff, and other external sources currently known to the staff are being properly resolved. The staff reviews and evaluations are provided in Section 4 of this l
supplement.
Open items from Supplement 13 (Reference 6) related to the design of cable trays and. cable tray hangers under the CPRT Program Plan are discussed in Appendix C to this supplement.
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4 CORRECTIVE ACTIONS I
To evaluate the design of cable trays and cable tray hangers at CPSES, the NRC staff reviewed the CPRT Program Plan up to and including Revision 4, the appli-cant's letters describing its Corrective Action Program (CAP) (References 7, 8, l
l 9, 10, 11, and 12), CYGNA's Independent Assessment Program and review issues l
lists (Reference 17), and the cable tray and cable tray hanger project status i
report (Reference 18).
In addition, the NRC staff conducted audits and inspec-f i
tions of the CPRT Program Plan and CAP activities related to cable trays and l
cable tray hangers at CPSES from Octaber 1985 through June 1988 (see Appendix D to this supplement for a chronology of staff audits and inspections of cable tray and cable tray hanger activities).
The sections that follow provide the staff's review and evaluation of the cor-f rective actions taken by the applicant to ensure the structural integrity of t
'the cable trays and cable tray hangers at CPSES, including third party over-sight of the CAP activities.
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4.1 Applicant Actions - TV Electric Corrective Action Program Process
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The CAP process for cable trays and cable tray hangers is described in a i
letter from W. G. Counsil (TU Electric) to the NRC dated August 28, 1987 i
(Reference 1D) and in the cable tray and cable tray hanger project status report (PSR) (Reference 18).
The major elements of the CAP process are the j
development of design-basis documents, design validation, hardware validation, final reconciliation, and final documentation.
(1) Development of Design-Basis Documents
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l The design-basis document (DBD), DBD-CS-082, "Cable Tray and Cable Tray t
Hangers," Revision 0, July 31, 1987, provides the design basis and func-tional requirements including project design criteria, analytical methodol-ogies, and procedures developed by Ebasco and Impell for their respective i
scopes of work under the CAP design validation of cable trays and cable i
tray hangers.
The DBD also addresses the approach used to validate design attributes of components that are inaccessible because of fire protection material on the cable tray hangers.
The technical bases for the CAP design criteria and procedures were established through extensive testing l
and engineering studies performed specifically for CPSES.
The DBD elso ensures that licensing commitments including these in the CPSES Final Safety Analysis Report (FSAR) (Reference 19) are properly documented and appropriately addressed in the design procedures, i
j (2) Design Validation 4
)
The design validation for cable trays and cable tray hangers provides a i
comprehensive program for the structural analysis and qualification of safety-related cable trays and cable tray hangers at CPSES.
The scope of Comanche Peak SSER 15 4-1
the CAP implemented far CPSES Unit 1 and common
- areas includes both seismic Category I and nonseismic Category I cable trays and cable tray i
hangers as defined in NRC Regulatory Guide 1.29 (Reference 20), Posi-tion C.2 (referred to as "seismic Category II").
Design validation in-cludes (a) establishing design input for cable tray and cable tray hanger analytical models, (b) conducting design analyses and evaluations-of cable trays and cable tray hangers (including fittings and clamps), (c) identify-ing hardware modifications to satisfy design criteria, and (d) reconciling analyses, modifications, and inspection results to ensure consistency be-7 i
j tween cable tray and cable tray har,ger design documentation and hardware installation.
The results of. design validation are documented in cable tray design validation par.Lages (DVPs) consisting of as-built cable tray and cable tray hanger data, cable tray and cable tray fitting calculations, j
cable tray clamp calculations, cable tray hanger calculations, and design-validated cable tray hanger drawings.
The DVPs provide the necessary documentation to ensure compliance with the design criteria and licensing commitments.
(3) Hardware Validation l
The applicant established the Post-Construction Hardware Validation Pro--
gram (PCHVP) (References 11 and 12) to ensure complete validation of final acceptance attributes, including those attributes for the reinspection of i
safety-related cable trays and cable tray hangers.
Reinspection by either 4'
physical verification or engineering evaluation is performed for those j
inspection attributes associated with (a) CPRT recommendaticns to rein-spect, (b) changes to design or to a hardware final acceptance attribute j
that is more stringent than the original acceptance attribute or those j
attributes not inspected by the CPRT, or (c) modifications to existing i
cable trays and cable tray hangers.
The PCHVP provides assurance that as-installed cable trays and cable tray hangers conform with validated design documents, i
(4) Final Reconciliation 1
The final reconciliation consolidates analysis, hardware modification, and i
inspection documentation to ensure consistency of the installed cable trays and cable tray hangers with the supporting <tesign documentation.
The re-j sults pertaining to cable trays and cable tray hangers are also confirmed by interacting organizations to ensure compatibility with their validated design.
The final reconciliation ensures that the cable tray and cable i
tray hanger DVPs adequately validate the installed hardware.
(5) Final Documentation l
The final documentation requires that all cable tray and cable tray hanger DVPs are transmitted to the permanent records facilities and ensures that the results of the CAP are adequately maintained and are retrievable.
)
- "Common" areas refers to the areas of the CPSES plant containing systems, components, and equipment for both Units 1 and 2.
Comanche Peak SSER 15 4-2
On the basis of its review, the staff finds that the overall CAP process for cable trays and cable tray hangers provides a complete program for ensuring l
compliance with licensing commitments as achieved through validation of as-built design, integration of validated design with installed hardware, and proper documentation and maintenance of results and is, thus, acceptable.
4.1.1 Design Criteria, Analytical Methodologies, and Acceptance Criteria TV Electric contracted with Impell Corporation and Ebasca Services Incorporated to validate the design of all CPSES safety-related cable tray systems based on as-built documentation of the installed cable trays and supports.
Impell is responsible for validating the design of cable tray systems located in the Unit 1 safeguards and reactor buildings.
Ebasco is responsible for validating the design of the remaining cable tray systems in Unit 1 and all safety-related cable tray systems in Unit 2.
Impell and Ebasco established design criteria and developed project instructions and analytical procedures to perform the design validation.
In addition, they performed numeruus engineering studies (also referred to as "special studies") and conducted a comprehensive testing program to verify the analytical methods and assumptions usred in the design validation of the CPSES cable tray systems.
The Impell and Ebasco cable tray hanger analyses are documented in design validation packages that contain the design data, analysis details, and evaluation of the members, clamps, welds, and anchorages.
The design analysis and validation of the cable trays are con-tained in a separate qualification book.
n The sections that follow provide the staff's review and evaluation of the design criteria, analytical methodologies, and acceptance criteria used by Ebasco and Impell ir, their design validation of the CPSES cable tray systems.
The staff reviewed the criteria and ;nethodologies used for the design valida-tion of the CPSES cable trays and cable tray hangers at the Eoasco office on November 2-5,1987 (Appendix 0 to this supplement - Event 18), and at the Impell site office on April 18-21, 1988 (Appendix 0 - Event 22).
Followup inspections were conducted at the Ebasco office on March 30-31, 1988 (Appen-dix D - Event 21) and at the CPSES site on June 13-16, 1988 (Appendix D -
Event 23) to resolve the open items remaining from the earlier inspections.
4.1.1.1 Loads and Load Combinations 1
Loads Ebasco and Impell validated the designs of the cable trays and hangers in regard to deadweight loads and seismic loads.
Ebasco and Impell determined deadweight loads from information obtained from installed components (as-built data) such as span lengths, tray size, fire protection material, cables, tray cover, and side-rail extensions as applicable.
The cable deadweight for the Unit I tray systems is based on the actual as-built cable fill as required in Ebasco docu-t ment SAG.CP4, Paragraph III.2, and Impoll Instruction PI-02, Paragraph 3.3.2.
If as-built data are unavailable, the cable weights are based on an assumed 100 percent fill.
For Unit 2, the cable deadweight is based on 100 percent i
fill as required in Ebasco document SAG.CP3, Paragraph III.2.
Comanche Peak SSER 15 4-3 l
l I
l l
Ebdsco and Impell obtained the values of seismic acceleration loads for the i
operating-M sis-earthquake (OBE) and safe-shutdown-earthquake (SSE) events from
)
the CPSES amplified response spectra, i
)
l The effects of normal operating and accident (loss-of-coolant-accident (LOCA))
thermal loads were evaluated in a detailed engineering study to determine their significance.
Thermal loads were not explicitly analyzed in design validation i
based on an engineering study (Impell calculation M-27) that investigated the effects of thermal loads during normal operations and during a LOCA, as well as
}
the effects during the simultaneous occurrence of a LOCA and an SSE.
In special study M-27, Impell demonstrated for cable tray systems that th0 loads are sec-ondary and self-limiting and all materials and connections are sufficiently
[
ductile to ensure that failure will not occur.
For steel-to-concrete anchorages l
with limited ductility Impell performed additional analyses which showed that l
resulting bolt deformations were far below ultimate stress levels.
In addition, Impell performed an analysis for a worst-case postulated accident in which loads i
resulting from tray thermal expansion were combined with maximum seismic loads.
The results showed that adequate margin against ultimate stress levels was main-tained even in the event of the simultaneous occurrence of LOCA and SSE peak t
loads.
The study concluded that thermal loadings can be ignored for design 4
validation.
The staff reviewed this study and agrees with the conclusions.
l l
The staff finds that the mo:t adverse loadings, including LOCA and SSE, have
[
been adequately addressed by the applicant in its design of cable trays and cable tray hangers.
The design considerations for these loadings provide con-fidence that the deb!gn encompasses a spectrum of lesser pipe breaks and seis-mic events.
On this basis, the staff concludes that the design considerations i
for cable tray and cable tray hanger loads are acceptable-l
)
Load Combinations The load combinations considered by Ebasco and Impell in the analysis of the cable tray systems were (1) the gravity loads combined with the OBE loads con-sidering maximum positive and negative OBE values and (2) the gravity loads com-bined with the SSE loads considering maximum positive and negative SSE values.
l
}
The staff reviewed the methodologies and assumptions for the loads and load i
s combinations used by Ebasco and Impell at inspections held at the Ebasco office t
]
on November 2, 1987 (Appendix 0 to this supplement - Event 18), and at the i
Impell site office on April 18, 1988 (Appendix 0 to this supplement - Event 22).
1 At the inspections, Ebasco and Impell engineers (using actual design validation j
packages) described their procedures.
Tbs staff reviewed Ebasco package i
CTH-1-2088, which contained the analysis of a hanger support using the equiva-
]
lent static method, and package RSM-1-AUX-25, which contained an analysis of a portion of the cable tray system using the response spectrum method.
At the 3
j Impell inspection, the staff reviewed cabl9 tray system packages containing the j
analysis of system 187-82-05 and support CTH-1-2539.
The staff found that the loads and load combinations used by Ebasco and Impell in the design validation l
analyses result in a conservative evaluation of loadings on cable tray hangers, comply with the applicable criteria in the Final Safety Analysis Report, and j
are, thus, acceptable.
l 1
Comanche Peak SSER 15 4-4 l
i
4.1.1.2 Seismic Analysis Methods l
Ebasco and Impell validated the design of 2,698 cable tray hangers out of a total of 10,118 using the response spectrum method.
Ebasco validated the design of the remaining 7,420 cable tray hangers using the equivalent static method.
Response Spectrum Method The response spectrum method (RSM) of seismic analysis is more rigorous than the equivalent static method.
In the RSM, the cable trays and hangers were subdivided into systems, each comprising from 10 to 25 supports.
Each system was then modeled and analyzed using a three-dimensional finite element computer program.
Modeling procedures are described in detail in Section 4.1.1.4 of this supplement.
Structural analysis computer programs are discussed in Sec-tion 4.1.1.3 of this supplement.
Separate analyses were performed for the operating-basis earthquake (0BE) and safe-shutdown-earthquake (SSE) load cases using 4 percent and 7 percent struc-l tural damping values, respectively.
All frequencies of vibration up to 33 cycles per second were considered in the analyses.
The modal responses for each frequency were combined in accordance with Regulatory Guide 1.92, "Com-bining Modal Responses and Spatial Components in Seismic Response Analysis" (Reference 21).
The N-S, E-W, and vertical directions of earthquake were l
considered to act simultaneously, and the responses were combined using the square-root of-the-sum-of-the-squares method.
To determine the validity of the 4 percent (OBE) and 7 percent (SSE) structural damping values used ir, the analysis of the cable tray systems, full-scale cable tray systems representative of actual Unit 1 configurations were dynamically 4
tested by ANCO Engineers, Inc., to establish representative modal damping values for each system as a function of cable fill and excitation level.
The tests were to verify that the 4 percent (OBE) and 7 percent (SSE) viscous damping values are appropriate or conservative for the design verification of the welded and bolted steel cable tray and hanger systems installed at CPSES.
ANC0 Engineers, Inc., issued the test plan report, No. A-000150, "Test Plan -
Dynamic Testing of Typical Cable Tray Support Configurations," in December 1985 and the final summary test report, No. A-000181, "Final Summary Report -
Comanche Peak Cable Tray Tests," in January 1987.
Impell issued an analysis and test correlation report, No. 09-0210-0017, "CPSES Cable Tray System Analysis / Test Correlation," in February 1987, to summarize the dynamic tests and analytical response calculations that were performed and to discuss the correlation of measured and predicted responses.
Seven differ-ent single-or dual-ticr systems with up to five support, and with lengths up j
to 40 feet were installed on a seismic shake table and subjected to a teries of dynamic excitations, including those equivalent to f Ne OBEs, immediately followed by those equivalent to a single SSE.
Studies on the entrelation be-tween measured and calculated accelerations and displacement responses showed that the RSM procedures used by Ebasco and Impell in design validation con-servatively overestimate response when 4 percent OBE and 7 percent SSE damping values are used as input in the analyses.
Actual damping values were deter-mined by test to be 7-10 percent for the OBE and 15-20 percent for the SSE.
)
Comanche Peak SSER 15 4-5
The staff finds that the RSM seismic analysis for analyzing cable trays and cable tray hangers at CPSES uses appropriate damping values - as verified by testing of cable tray systems representative of those installed at CPSES - and modal combination methods in accordance with the guidelines provided in Regu-latory Guide 1.92.
In addition, the results of the full-scale testing of CPSES cable tray systems have been correlated with the RSM analysis results to ensure that the RSM analysis provides a conservative method to predict system response.
Gn this bat.is, the staff finds the RSM analysis of CPSES cable trays and cable tray hangers acceptable.
Equivalent Static Method in the equivalent static method (ESM), individual models of each cable tray hanger were used for design validation as described in Ebasco document SAG.CP34.
1 After a three-dimensional computer model of the cable tray hanger was gener-ated, which included contributory cable tray weight, a frequency analysis was performed to obtain the fundamental (lowest) frequency of the hanger in the 1
transverse, longitudinal, and vertical directions.
This frequency was then combined with the fundamental frequency of the tray in the corresponding direction to calculate the system frequency.
The system frequency was used to determine the seismic acceleration value in each direction from the amplified response spectra (ARS).
This acceleration from the ARS was increased by at least 25 percent and was used to determine the equivalent static loads applied to the hanger in each direction.
Design validation of cable trays using the ESM considered that tray spans (including straight trays, bends, tees, and crosses) were subjected to either peak seis-mic accelerations or seismic accelerations at the system frequency in each direction from the ARS.
In all cases, these accelerations were increased by
)
at least 25 percent.
The acceptability of a 1,25 factor is discussed in Section 4.1.1.4 of this supplement, i
The staff reviewed the ESM procedure and its application at an inspection held j
at the Ebasco office on November 2, 1987 (Appendix 0 to this supplement -
Event 18).
It reviewed two typical ESM hanger packages:
(1) package CTH-12-1683, I
which contained the analysis of a three-tier, two-tray transverse support and included a computer printout and (2) package CTH-1-2088, which contained the analysis of a horizontal longitudinal support and included a computer printout.
The calculations and computer output were spot checked for accuracy.
The staff found that the hanger package > were well documented and conformed to the method-ology described in Ebasco document SAG.CP34 and are, thus, acceptable.
in addition, the staff reviewed two Ebasco RSM design calculation packages:
(1) string RSM-1-AUX-25, which contained the calculations for 14 supports and l
included a computer output, and (2) string RSM-1-AUX-(ELE)-4 which contained the calculations for 14 supports and included a computer output.
Both docu-ments were reviewed in their entirety and the calculations and computer input data and output results were spot checked.
The staff found the calculations had been performed in accordance with Ebasco document SAG.CP34 and are, thus, acceptable.
The staff reviewed the response spectrum methodology at the Impell site office on April 18-21, 1988 (Appendix 0 to this supplement - Event 22).
The relevant Comanche Peak SSER 15 4-6
l procedures, instructions, supporting studics, and test data were discussed.
Overlap criteria that are used to break systems down into smaller analysis packages, requirements for "break" supports (supports that divide a cable tray system for purposes of analysis), and modeling of "analysis only" supports were covered, and the justification for this methodology was presented.
The forces and moments on supports and trays in the overlap region are multiplied by a factor of 1.1 for additional conservatism.
stem analysis (calculation / problem No. 187-82-05) 1 Thestaffreviewedasamplesy' break"support (packageCTH-1-2539).
l as well as the analysis of a The staff reviewed the analysis to determine the adequacy of (1) the modeling of supports for the computer program SUPERPIPE including eccentricities, brace connections, and anchorages; (2) the modeling of tray, tray fittings, and clamps; (3) the justification for neglecting certain eccentricities in the computer program SUPERPOST model; (4) the validation of support members and wolds using SUPER-POST with loads extracted from SUPERPIPE; and (5) the validation of tray, anchorages, and clamps using loads from SUPERPIPE and allowable values from test results or special studies.
In addition, the staff reviewed several Impell studies, project instructions, and calculations during the inspection in conjunction with the presentation of
'j the RSM procedures.
The staff found that the ESM and RSM analyses were per-formed in accordance with the applicable project documents and instructions and j
are, thus, acceptable.
4.1.1.3 Structural Analysis Computer Programs Impell used the computer program SUPERPIPE to perform cable tray system analy-ses.
The progtam input parameters and capabilities are described in the j
SUPERPIPE User's Manual.
Numerous SUPERPIPE verification analyses and bench-j mark problems have been documented in accordance with Impell quality assurance procedures.
Ebasco used the computer program P-Delta 51RUDL to perform cable tray system analyses.
P-Delta STRUDL verification analyses have been performed and are documented in the P-Delta STRUDL Verification Manual.
SUPERPIPE and P-Delta STRUDL use simila; ter.hniques to evaluate gravity and seismic response spectra loadings.
Both programs are based on small-displacement, linear elastic analysis.
In the programs, static and dynamic equilibrium equations are formulated using the direct stiffness method.
Six degrees of freedom are allowed to be specified at each node of the global I
system model.
Static equilibrium equations are solved using Gaussian reduc-tion.
Natural frequencies and mode shapes up to a specified cutoff frequency i
are calculated by subspace iteration.
The combined effect of modes above this frequency is included through a missing mass correction.
By this method, the I
mass at each node point that had not participated in the calculated modes is included in a single rigid body mode assumed to occur at the cutoff frequency.
Both programs allow individual modes to be combined using the grouping combina-tion method specified in NRC Regulatory Guide 1.92 "Combining Modal Responses and Spatial Components in Seismic Response Analysis" (Reference 21).
Consist-ent with the methods used by both Impell and Ebasco in design validation, the three orthogonal directions of excitation are assumed to act simultaneously and 1
their effects are combined by the square-root-of-the-sum-of-the-squares method.
1 Comanche Peak SSER 15 4-7 1
Impell Report No. 09-0210-0136. "Impel /Ebasco Comparison of Computer Programs Used in CPSES Cable Tray System Analysis," dated April 18, 1988, summarizes the results of a comparative study of the computer programs used for the analysis and design validation of safety related cable tray systems at CPSES.
Specific-ally, dominant system modes, as well as member end reactions for static and dynamic load cases, were generated and compared for an identical system model using the computer programs SUPERPITE and P-Delta STRUDL.
These computer pro-grams were used by Impell and Ebasco, respectively, in the design validation of CPSES cable tray systems.
The analysis of an identical model using the SUPERPIPE and P-Delta STRUDL com-puter programs produced consistent results.
The analysis compared both pre-dicted dominant systems modes and predicted gravity and seismic loading on hangers.
Predicted system mode shapes were in agreement with the associated modal frequencies deviating by less than 1 percent.
Member-end forces and moments generally agreed within 5 percent for the gravity load case and within 10 percent for the SSE load case.
The staff finds the degree of accuracy to be within reasonable limits for load prediction and is, thus, acceptable.
Impe11 Report No. 09-0210-0138, "Impell/Ebasco CPSES Cable Tray System -
Comparison of Analysis Results and Test Measurements for Test Configuration 7,"
dated April 19, 1988, compares analytically predicted seismic displacements with actual values obtained from the dynamic testing of a full-scale cable tray system.
Using their respective modeling procedures developed for the design validation of CPSES cable tray systems, Impe11 and Ebasco each performed a re-sponse spectrum analysis of test configuration 7.
Predicted displacements were compared with test measurements for both OBE and SSE input levels to demonstrate the conservatism of each analytical procedure.
A similar comparison was per-formed for a configuration where gaps were deliberately installed between the tray and tray clamps to demonstrate that a conservative response prediction is achieved regardless of gaps.
For the configuration tested without gaps, the Impell analytical procedure over-predicted 10 of the 12 measured displacements for both the OBE and SSE load cases.
The Ebasco analytical procedure overpredicted 9 of the 12 measured dis-placements.
Detailed examination of the underpredicted nodes showed that the seismic response was dominated by a single mode, and the associated spectral acceleration was reduced by the method of "averaging" used to derive a common analytical response spectrum for all attachment points in each direction.
Cor-recting for the actual spectral acceleration at this modal frequency showed that, for both input levels, 11 of 12 measurements were overpredicted by the Impell analysis procedure and 10 of 12 were overpredicted by the Ebasco analy-sis procedure.
Furthermore, the single Impell underprediction and the two Ebasco underpredictions were shown to be very small and within the measurement accuracy of the transducers and are, thus, acceptable.
For the configuration tested with gaps, both analytical precedures accurately predicted or overpredicted the measured displacements for both the SSE and OBE input levels ard sit, thus, acceptable.
The staff concludes that the Ebasco and Impell computer programs (P-Delta STRUDL and SUPERPIPE) provida close agreement for analysis of an identical cable tray system analytical model and that both programs conservatively predict dynamic system responses and are, thus, acceptable.
Comanche Peak SSER 15 4-6
r 1
4.1.1. 4 Analytical Methodologies l
System Modeling Techniques Impell and Ebasco have developed procedures for creating detailed three-dimensional system models to be used for computer analysis of the CPSES cable trays and supports.
The as-built structure is transformed into a computer model by simulating the cable tray system members, clamps, eccentricities, and anchorage stiffnesses with representative element types, rigid links, springs, and boundary conditions available in the computer program.
Since Impell uses SUPERPIPE and Ebasco uses P-Delta STRVOL, the modeling procedures are slightly different.
Impell modeling procedures Are contained in Instruction PI 02; Ebasco modeling procedures are given in documents SAG.CP3, SAG.CP4, SAG.CP11, ard SAG.CP34.
The staff has reviewed and evaluated the modeling procedures used by Ebasco and Impell in creating the three-dimensional system models for computer analyses including the justification of the prying factor, slenderness ratios, cantilever lengths, ESM multimode response multipliers, clamp bolt hole in channels, over-sized bolt holes, and cable tray clamps.
The similarities and differences in modeling between the Impell and Ebasco procedures are discussed in Impell Report No. 09-0210 0137, "Impell/Ebasco Comparison of Modelling Procedures Used in CPSES Cable Tray System Analysis," Revision 0, April 1988, i
The staff reviewed Ebasco's modeling procedures at inspections held at the Ebasco office on November 2 5, 1987 (Appendix 0 to this supplement - Event 18) and on March 30-31, 1988 (Appendix D - E. rent 21).
The staff reviewed Impell's modeling procedures at an inspection held at the Impell site office on April 18-21, 1988 (Appendix D - Event 22).
l.
The staff reviewed two reports (Impell Report Nos. 09-0210-0136 and 09-0210-0138) i which presented the results of studies comparing the accuracy of SUPERPIPE and i
F-Delta STRUDL computer programs with a benchmark problem.
The reports demon-strate that the two computer programs prov,de close agreement for analysis of an identical system model and both methods give conservative results when com-pared with actual seismic system response as measured by testing.
The staff concludes that the analyses were performed on a rep esentative system and that the modeling procedures followed by Ebasco and bpell conform with their respectivt procedures and methods and are, thus, icceptable.
At each inspection, typical systems were selected and the applicable modeling procedures, project instructions, supporting studies, and test results were discussed in detail.
The staff found that the Impell and Ebasco modeling pro-i cedures are based on technically sound assumptions, produce consistent results,
]
and comply with CFSES licensing commitments and are, thus, acceptable.
Justification of Prying Factor Both Impell and Ebasco considered the effects of prying action resulting from the application of eccentric loads to bolted base angles and base plates in cable tray hangers.
Prying forces result when parts of bolted assemblies are restrained from free rotation under the action of the applied loads.
As a re-i sult of the constraint to free rotation, the tensile bolt loads are increased l
Comanche Peak SSER 15 4-9
l
)
above the value of the applied loads, These increased bolt loads must be con-1 sidered in the design of the bolts, Because of the many variations in gecmetry L
i and loads of bolted anchorages in the CPSES cable tray hanger systems, indi-j vidual analyses of each anchorage would have been impractical.
Alternatively, l
- ]
Ebasco and Impell established a procedure whereby the anchorages could be se-lectively grouped and the bolt loads could be conservatively calculated using l
a formula contoining prying action factors that account for anchorage dimen-l sions; type, size, and location of anchor bolts; and applied loads.
Ebasco's studies and calculations for anchor bolt prying action factors are i
contained in Volume I, Book 3, of its report, Ebasco developed a three-dimensional ANSYS finite element model for each of the representative base plates and angles.
Base angle models with one and two bolts and base plate I
models with two and four bolts were created.
The models used STIF63, the
]
three-dimensional quadrilateral shell element to simulate the base plate or i
angle, and STIF10, a nonlinear three-dimensional tension-only or compression spar element to simulate the flexibility of the bolt and the reinforced con-crete at the appropriate nodal locations, Approximately 16 ANSYS computer runs were made to evaluate the prying action factors.
Prying action factors are presented in the tables of Section II of Volume I, Book 3.
Impell performed similar studies on base plates and angles using the Base-j plate 11 computer program.
The methodology, analysis, and results are con-tained in an Impell special study, M-25, I
The staff finds the Ebasco and Impell design validation procedures for prying action factors complete and conservative and concludes that Ebasco and Impell have adequately considered the prying action effect, The prying action factors are, thus, acceptable for CPSES, l
l Slenderness Ratios and Cantilever Lengths j
The staff reviewed the K-factors and slenderness ratios (KL/r) used by Ebasco i
and Impell in the design validation of compre';sive hanger members and found
)
that they were applied in accordance with the American Institute of Steel Construction (AlSC) code (Reference 22),
Cantilever lengths of compression 8
members were also evaluated by Ebasco and Impell in special studies, I
Ebasco's studies contained in Volume I, Book 6, establish reasonable K values i
to be used in verifying conformance with the AISC code requirements, values of 1
K are identified in the AISC code for simple and clearly defined individual
{
column cases.
However, determination of K values for compression members of 1
frames is more complex.
Ebasco performed frame stability analysis using the MSC/NASTRAN finite element computer code to establish appropriate K values for frame post members.
Studies were conducted to determine the K value for trans-verse hangers with and without a longitudinal tie to the tray and for longitu-l dinal hangers, Approximately 140 computer runs were made, for cantilever supports with Typ9 A or G clamps Ebasco used a member length from the face of the concrete to the outside clamp, The results of the studies were incorporated in Ebasco's design validation procedures (SAG.CP3, SAG,CP4, and SAG,CP34),
I In Report No, 01-0210-1470, "Effective Length Factors for Buckling of Cable Tray Supports," and St.udy B-03 "Effective Length Buckling Factors," Impell 1
Comanche Peak SSER 15 4-10 i
i
I 4
t evaluated the stability of typical cable tray supports and developed effective-length factors for vertical posts (or columns) of cable tray supports.
The effective lengths are for weak axis flexural buckling.
Weak-axis flexural i
bbckling controls all other forms of buckling for the cable tray supports in this study.
These factors account for the interaction of the posts with the remainder of the frame and can be used in routine design to predict the capac-ity of such supports.
)
Effective-length factors were developed i.: Impell's study of trapeze, L-shaped, and cantilever supports.
The influences of vertical load distribution, trans-verse load, longitudinal restraint of the cable tray, and rotational restraint j
at the support anchor were considered in developing these effective-length j
]
factors.
For each support type, effective-length factors were shown not to be significantly sensitive to the support's length.
Therefore, support length was not a parameter in those effective-length factors recommended for design.
i Impell Report No. 09-0210-0018, "Slenderness Ratio Limits for CPSES Cable Tray i
Supports," sumarized the results of evaluations to determine the slenderness ratio limits for the CPSES cable tray supports.
Slenderness ratios for com-pression members have been limited to 200.
Tensien members are allo,4ed slender-ness ratios up to 300.
A member is considered to be a tension member when it is normally subjected to tension under static load, and static plus dynamic I
load results in a compressive stress less than 50 percent of the allowable com-pr
've strass.
The results of Impell's studies have been incorporated in i
design validation procedures (PI-03 and PI-11).
Irr e The staff finds that the Ebasco and Impell design validation procedures for f
slenderness ratios and cantilever lengths are conservative and concludes that Ebasco and Impell have adequately considered these effects.
i ESM Multimode Response Multiplier (1.25 MRM) l In its cable tray hanger design validation, Ebasco developed a multimode re-sponse multiplier (MRM) of 1.25 to be used in equivalent static method (ESH) analysis to account for dynamic multimode effects.
Ebasco developed procedures for distributing load among cable tray hangers, These procedures, used in con-junction with the 1.25 MRM, result in hanger loading that adequately reflects 1
j the dynamic behavior of CPSES cable tray systems.
Ebasco conducted extensive studies to justify the 1.25 MRM and related load i
distribution procedures.
The w studies are documented in Ebasco's special J
studies report, Volume I, Book 9 (Parts 1 through 7), Bock 10, Book 15, and Book 23.
2 J
The intent and scope of Ebasco's original MRM study was to justify using th*
i 1.25 MRM in ESM to account for "dynamic mcitiple mode" effects alone, withod i
also accounting for stiffness-related load distribution effects.
This original i
study is documented in Volume I, Book 9 (Section B), Book 9 (Parts 1, 2, and
]
3), and Book 10.
J l
In Book 9 Section B, MRM values were determined by calculating the ritio of
)
cable tray system weighted average accelerations (tray and hangers) from response spectrum method (RSM) analysis to accelerations from ESH analysis.
Three cable tray systems were selected for study to represent the dynamic i
Comanche Peak SSER 15 4-11 l
behavior of actual plant systems.
The systems studied were two idealized-straight-span systems (Models 1 and 2) and one actual CPSES straight-span sys-tem (Modal 3).
Both fixed and flexible hanger anchorage boundary conditions,.
and a variety of seismic input spectra, were considered.
Friction between tray and transverse hanger in the longitudinal direction was not considered.
The results of this study justify the validity of the 1.25 MRM for multimode effects.
Consistent with the methodology used in the-original study, the 1.25 MRM was further justified for multimode effects by an additional study performed for two cable tray systems containing a 90-degree bend (Models 1A and 18).
One system was symmetric about the bend and the other was not.
MRMs were calcu-lated based on average system acceleration ratios as well as hanger anchorage reaction ratios.
This study is documented in Volume I, Book 9, Part 4.
The 1.25 MRM was further justified for multimode effects by an additional study performed using Model 1 of the original study, in which MRM values were calcu-lated based on ratios of RSM to ESM hanger member stress interactions and on ratios of RSM to ESM hanger anchorage reactions.
Flexible anchorage boendary conditions were used.
The resulting MRMs were statistically evaluated.
This study is documented in Volume I, Bock 9, Part 5.
The 1.25 MRM was further justified for multimode effects by an additional study performed using Models 1A and 2 in which MRM values were calculated based on ratios of RSM to ESM weld Srces and RSM to ESM hanger anchorage reactions.
Flexible hanger anchorage boundary conditions were used.
This study showed t %t all production design verification calculations should consider actual ancnorage flexibilities.
This study is documented in Volume I, Book 9, %t 6.
The 1.25 MRM was further justified for multimode effects by an additional study in which MRM values were calculated based on ratios of RSM to ESM tray clamp interactions.
Model 2 with flexible anchorage boundary conditions was used.
This study is documented in Volume I, Book 9, Part 7.
The previous study results showed that most of the calculated MRMs were sig-nificantly less than 1.25.
Additional studies evaluated the possibility of selectively using the 1.25 MRM in lieu of performing detailed load distribution calculations for design verification of the configurations specific to CPSES.
For longitudinal loads (along tray length), it was recognized that the 1.25 MRM would automatically account for load distribution effects in only a limited number of cable tray system configurations (i.e., those with relatively uniform stiffness and mass distribution).
Thus, a procedure (Attachment Y of document SAG.CP34) was developed for calculating the appropriate longitudinal load dis-tribution among hangers when stiffness and mass vary.
The technical basis and justification for this procedure are documented in Volume I, Book 15, Sec-tions I and II.
For transverse and vertical loads (in the plane of the tray cross-section), it was recognized that the 1.25 MRM would automatically account for ioad distribu-tion for most tray system configurations.
This was evaluated in the parametric study presented in Volume I, Book 15,Section II.
The study concluded that for most tray configurations, the 1.25 MRM is sufficient to account for transverse and vertical load distribution effects, In conjunction with this study, a 1
Comanche Peak SSER 15 4-12 l
1 1
screening procedure was developed to identify any hangers for which the 1.25 MRM alone does not suffice.
A detailed summary report describing the contents of Sections I and II of Book 15 is presented at the beginning of Book 15.
In the parametric studies described in Volume I, Book 15, Sections I and II, finite element models were used in which hangers were represented as spring elements and trays as beam elements.
In all other MRM studies described above,-
three-dimensional hanger models were used in which each hanger structural mem-ber was explicitly modeled.
To justify use of the spring-type model in the parametric study, a model correlation study was performed in which MRMs calcu-lated from both the spring and three-dimensional models were compared.
This j
study was perfornied using Model 2.
Flexible boundary conditions were used, and variation in hanger stiffness was considered.
The results demonstrate the con-servatism of the beam-spring-type model.
This study is documented in Volume I, Book 15,Section III.
t In addition to the above MRM-related studies, Ebasco analyzed a complex CPSES cable tray system using both RSM and ESM methodologies to demonstrate the j
validity of the 1.25 MRM by calculating ratios of RSM to ESM member stress interactions.
This system contained many horizontal and vertical bends.
MRMs were calculated both with and without longitudinal friction effects included between the tray and transverse hanger.
The results of these analyses justify the validity of the 1.25 MRM.
These analyses are documented in Volume I, Book 23, Sections III and I, respectively.
1 In addition, a model correlation study was performed for the complex system without friction.
The results of this study further demonstrated the conserv-atism of the beam-spring type model.
This study is documented in Volume I, Book 23,Section II.
l The staff review of the above-described special studies finds that the use of a dyr.amic amplification factor (DAF) of 1.25 in the Ebasco and Impell design validation procedures for cable tray hangers adequately accounts for dynamic multimode effects in the equivalent static method (ESM) analysis and the DAF of 1.25 is, thus, acceptable for CPSES.
Clamp Bolt Holes in Channels Ebasco and Impell evaluated cable tray support tiers using channel section moment of inertia properties reduced to account for the presence of an unused hole.
Ebasco procedures in document SAG.CP34 require that for any tier having a stress interaction ratio larger than the minimum net-to gross section propert.y ratio, an unused 3/4-inch-diameter bolt hole shall be assumed to be present at the highest stress location on the tier.
The section shall be manually veri-fied by reducing the area and moments of inertia to account for the bolt hole.
A shift of the neutral axis because of the bolt hole shall be considered.
The reduced section properties can be used to account for this bolt-hole effect.
For any tier that has a stress interaction ratio less than or equal to the minimum net-to gross section property ratio, the bolt-hole effect does not need to be explicitly considered in design validation.
Comanche Peak SSER 15 4-13
Impell's qualification closecut procedure requires the evaluation of potential bolt holes in tier flange members.
The _multistep approach is described in detail in Paragraph 2.3.2 of Impell's Project Instruction PI-11 for cable tray system analysis and qualification closeout.
Ebasco's special studies covered statistical analysis of bolt holes / edge dis-tances in cable tray hangers (Volume I, Book 22) and reduced section properties for channels with a 3/4-inch hole at-the flange tip (Volume I, Book 25).
In its special study, M-65, Impell evaluated the effects of potential bolt holes in tier members.
The staff review finds that the use of reduced section properties of channel members in design validation procedures to account for the presence of bolt holes is adequately justified.
The staff reviewed Ebasco's and Impell's proce-dures and concludes that they contain adequate and conservative criteric for evaluating the effect of clamp bolt holes in channels and are, thus, acceptable.
Oversized Bolt Holes Ebasco's report, Volume I, Book 22 (Part 2), "Effects of Bolt Hole Oversize on CTH and Conduit System Adequacy," provides a joint Impell and Ebasco position on the issue of oversized bolt holes.
The main types of bolted connections used at CPSES in the cable tray hanger design are (1) anchorages of hangers to concrete, (2) clamp connections to the tier and to the tray, and (3) framing connection of hanger structural members.
A sampling program conducted for cable tray hangers (CTHs) randomly selected from the population of Unit 2 CTHs built and installed at the same time as the Unit 1 CTHs identified the maximum extent of oversize that can be expected in the field for the different kinds of connections used in CTHs.
Maximum over-size is here defined as the difference between the hole diameter determined with a 95-95 confidence level and the bolt diameter.
The anchorages used in the CTH design at CPSES' consist mainly of base members bolted to the concrete with Hilti Kwik-Bolts or Hilti Super Kwik-Bolts and Richmond inserts with A325 or 307 bolts.
The factors of safety used for Hilti Kwik-Bolts (and Super Kwik-Bolts) during design are 5.0 for the operating basis earthquake (0BE) and 4.0 for the safe shutdown earthquake (SSE).
The factor of safety used for Richmond inserts is 3.0 for both the OBE and SSE.
Factors of safety relatad to oversized bolt holes of the extreme-case base anchorage configurations show that the safety factor of the connection is not decreased below 4.17 for the OBE and 3.33 for the SSE when using 1-1/4-inch Hilti Kwik-Bolts, and 2.4 for both the OBE and SSE when using 1-inch Richmond inserts.
Because the methods of analysis used in the design validation proc-ass are conservative, the joint Impcil and Ebasco position is that the slight reduction in :,afaty factors is acceptable and that oversized bolt holes have no effect on the adequacy of the cable tray hanger anchorage.
As documented in ANC0 Document No. A-000181, "Final Summary Report - Comanche Peak Cable Tray Tests," ANC0 Engineers, Inc., conducted dynamic tests to study the effects of bolt hole oversize at the clamps.
The test results showed that oversized bolt holes had an insignificant effect on the dynamic characteristics 1
and seismic response of cable tray systems.
Comanche Peak SSER 15 4-14
Framing connections are multi-bolt with a maximum oversize of 5/32 inch (3/32 inch more than that permitted by the AISC code).
Impell and Ebasco con-cluded that the e'fect of oversized bolt holes in framing connections is negli-cjible because the bolts in the holes that are not oversized will resist and share the applied loads.
Impell conducted an additional special study, M-73, which showed that oversized bolt holes had no significant effect in reducing the factor of safety or system adequacy.
The staff review of the joint Impell and Ebasco position paper on oversized bolt holes finds that in view of the conservatisms used in the analysis and design criteria, the overall effect of oversized bolt holes on the design of cable tray hanger anchorages does not adversely affect the ability of the cable tray hangers to perform their intended functions even if they contain worst-case oversized bolt holes as found at CPSES and is, thus, acceptable.
Cable Tray Clamps - Load Transfer Impell performed full-scale dynamic tests of cable tray systems to evaluate the capacity of the clamps in their ability to transfer load between the trays and hangers and to confirm the design assumption that the trays act as bracing for the hangers.
Impe11 Report No. 09-0210-0017, "CPSES Cable Tray System Analysis / Test Correla-tion," correlates test results with design validation modeling procedures that assume that clamps transmit forces between the tray and support in all directions.
Two configurations, TC3 and TC7, were tested with and without gaps installed at the tray clamps.
Other construction imperfections (such as undercut welds, over-sized bolt holes, and reduced edge distance) were also included in the configura-tions.
The configurations were then tested for design-level loads and fragility-1evel loads.
The results of the tests conducted on configurations TC3 and TC7, as well as the other test cases, supported the assumption that longitudinal restraint is provided by all types of tray clamps.
Under design-level motions for TC7, the peak oscillatory slip response was 0.04 inch, even when gaps were deliberately installed in tray clamps.
The maximum residual slip was less than 0.004 inch.
Both values are insignificant.
For TC6, the maximum measured slippage was 0.07 inch.
For all other test configurations (TC1, TC2, TC3, and TC4), the maximum measured slippage at design-level motions was 0.04 inch.
The fragility-level tests were the final sequence of tests conducted on TC7, for the system with 100 percent.able fill.
Gaps were installed between the support and cable tray to evaluate the effect of the gaps.
These tests con-sisted of four consecutive levels of progressively more intense excitation, which enveloped the 7 percent-damping design SSE by factors of nominally 1.2, 1.5, 1.7, and 1.9.
The Type C and weakened (i.e., with intentional weld undercuts) Type G clamps experienced their first permanent deformations in the 1.2 SSE fragility-level test.
Even at 1.7 SSE (approximately three times the design-level peak accelerations) and with cumulative initial deformations, all clamps were effective in attaching the trays to the hangers and restricting relative motion.
The staff review of Impell Report No. 09-0210-0017 finds that the test results have been adequately applied to modeling procedures that assume that the clamps Comanche Peak SSER 15 4-15
are effective in restricting relative motion between the tray and the hanger.
In addition, the staff reviewed ANC0's final summary report of the full-scale system dynamic tests and finds that the tests and test results sufficiently demonstrate the ability of the clamps to transfer load between the trays and hangers.
4.1.1. 5 Systems Dynamic Tests Six different full-scale test specimens representative of the cable tray hanger systems installed at CPSES were subjected to various types of dynamic tests at the ANC0 Engineers, Inc., testing laboratory.
These tests represented various configurations of tray hangers, sizes of cable trays, types of tray clamps,.and amount of cable in the tray that were tested in various combinations of tray runs and support boundary conditions.
In addition, the test specimens included some with discrepancies (such as oversized bolt holes, unused bolt holes, re-duced minimum edge distances, gaps between tray and clampc, and undersized welds between clamp and tiers) identified during inspections of as-built components.
The plan for the dynamic testing of the cable tray configurations is contained in ANC0 Document No. A-000150, "Test Plan - Dynamic Testing of Typical Cable Tray Support Configurations." The final summary repart is contained in ANCO Document No. A-000181, "Final Summary Report - Comanche Peak Cable Tray Tests."
Impell Report No. 09-0210-0138, "Impell/Elasco CPSES Cable Tray System -
Comparison of Analysis Results and Test Measurements for Test Configuration 7,"
contains a comparisen of analysis results and test measuren.ents.
Of the six cable tray systems tested, half were single tier (one tray run) and half were double tier.
For the single-tier test systems, a 24-inch-wide ladder bottom tray was used; for the double-tier systems, a 12-inch-wide ladder bottom tray was used above the 24-inch-wide tray.
With the exception of one case, all tiers were 40 feet long and spanned five supports; Case 6, which was tested for potential vertical post buckling under dynamic loading, consisted of a 22-foot, single-tier systerr spanning three supports.
Two test systems includd curved tiers - either in a vertical or horizontal plane - at one end of their runs; the remainin0 four systems were straight runs.
Variables in the test programs included tray clamp types, cable-fill level, and construction details; support specing varied somewhat to accommodate curved tiers.
The cable tray systems were all subjected to a series of dynamic events, in-cluding those corresponding te five operating basis earthquakes (OBEs) appli-cable to CPSES, immediately follcwed by that correspoading to a single safe shutdown earthquake (SSE).
In addition, five of the six cable tray systems were subjected to earthquake tests ("fragility events") of 1.4 SSE or greater.
Two systems were subjected to etents of 1.8 and 1.9 SSE.
None of the five test systems exhibited any forn; of Iartial or complete structural collapse or sig-nificant distortion.
There was some local damage in the form of cable tray clamp plastic deformation, which occurred only for the highest fragility-level inputs.
No more than five M astic cable ties failed at loading up to 1.6 SSE.
A sixth test system (Case 6), which had atypical cable tray supports except for the slenderness ratio (related to buckling), was subjected to a series of tests Comanche Peak SSER 15 4-16
1 similar to those to which the other five test systems were subjected; the tests were terminated at 1.1 SSE.
This system showed no buckling under the dynamic loads, nor any other evidence of gross distortion or damage, and no evidence of local damage (to tray clamps, cable ties).
All six systems remained intact and stable at the conclus' ion of the tests and were not significantly distorted.
On the basis of transducer measurements, cable tray slippage relative to tray supports was generally less than 1/10 inch (single amplitude) for all seismic and system behavior tests.
The maximum slippage measured occurred during the fragility tests and, for the most part, did not exceed 2/10 inch.
Oversized bolt holes, less-than-minimum edge dis-tances, undersized welds, and unused bolt holes had no evident effect on response and were not sources of local failures.
Modal damping ratios for the cable tray systems were observed to increase with response amplitude.
The highest modal damping generally occurred for the 50 percent fill condition; higher damping ratios occurred in the lower modes.
Construction details particularly gaps between trays and supports - appeared to have 10 significant effect on damping values.
The staff reviewed the ANCO test plan (ANCO Document NO. A-000150), final sum-mary report (ANC0 Document No. A-000181), and Impell Report No. 09-0210-0138, at an inspection held at the Impell site office on April 18-21, 1988 (Appen-dix D to this supplement - Event 22).
The staff found that the full-scale cable tray tests provided relevant data for the design validation of the cable trays and hangers.
On the basis of its review of the test results, the staff found that the analysis methods used for design validation conservatively predict the dynamic characteristics of the system.
The staff concludes that testing of as-built conditions, such as gaps between tray and clamps and oversized bolt holes, has adequately demonstrated that these conditions as they exist at CPSES do not have an adverse effect on cable tray system seismic response.
On the basis of its review of the correlation of analysis with test results, the staff concludes that the cable tray system dynamic tests provide an ade-quate basis to justify the Ebasco and Impell analysis methods used in the design validation of CPSES cable trays and hangers.
The staff's conclusions are based on the following:
(1) The behavior of cable tray systems when subjected to seismic loadings is predictable.
In particular, the friction-type clamps exhibit linear (non-slip) behavior under seismic loads.
The analysis methods used for design validation conservatively predict the dynamic characteristics of the system.
(2) The analysis procedures substantially overpredict actual measured response when the structural damping values are assumed to be 4 percent and 7 per-cent for the design OBE and SSE, respectively.
The damping values of 4 percent and 7 percent are the licensing commitments for CPSES, (3) The effective cable tray system damping values are 7 to 15 percent for OBE motions and 10 to 20 percent for SSE motions indicating that the criteria Comanche Peak SSER 15 4-17
implemented for design validation (4 percent for the OBE and 7 percent for the SSE) are conservative.
(4) Connectivity exists between the tray and support.
(5) Construction deficiencies, such as gaps, oversized holes, and components that are out of plumb, have no significant effect on system response.
(6) Buckling does not occur even with a very large KL/r (slenderness ratio).
4.1.1.6 Tray, Fitting, and Clamp Tests The cable tray component tests were performed to establish load capacities and to determine the stiffness of cable tray components (i.e., trays,-fittings, and clamps).
The components were tested in the vertical and transverse directions to obtain load capacities and to derive equivalent inertial section properties (area moment of inertia) from load / deflection curves.
The load-carrying capac-ities of the cable trays in the longitudinal direction were calculated on the basis of American Iron and Steel Institute specification criteria (Reference 23).
Both static and cyclic tests were performed by Corporate Consulting and Develop-ment Company Ltd. (CCL).
The test plan for the static tests is contained in CCL Procedure No. 1903.20-1; the test plan for the cyclic tests is in CCL Procedure No. 1903.22-1.
The following reports contain the results of the CCL tray and clamp tests:
(1) A-717-86, "Test Report for Monotonic and Cyclic Tests of Cable Tray Clamps for CPSES" (2) A-719-86, "Test Report for Static Testing of Cable Trays and Fittings for CPSES" (3) A-721-86, "Test Report for Additional Monotonic and Cyclic Tests of Cable 1
Tray Clamps" (4) A-737-86, "Test Report for Additional Static Tests of Cable Trays and Fittings" (5) A-739-86, "Test Report for Additional Static Tests of Cable Trays and Fittings" (6) A-738-87, "Test Report for Cable Tray Shim Test for CPSES" (7) A-742-87, "Test Report for Cable Tray Tee-Fitting Tests" (8) A-743-87, "Summary Test Report for Monotonic and Cyclic Tests of Cable Tray Clamps for CPSES" (9) A-744-87, "Test Report for Cable Tray Deviated Splice Test With T.J. Cope Trays" The staff reviewed the test plan and test report documents and discussed the results of the tray, fitting, and clamp tests at an inspection held at the Ebasco office on November 2-5, 1987 (Appendix 0 to this supplement - Event 18).
Comanche Peak SSER 15 4-18
- _ ~ _ -
For each tray test, the load /deficction curve up to failure load was recorded.
The failure load provided the maximum load-carrying capacity, and the load /
deflection curve was used to calculate the equivalent area moments of inertia of the trays.
Tray clamp assemblies were tested to establish load capacities for use in the design validation.
The clamp assemolies tested were selected through a review of the installed clamp types to determine the test assemblies that would con-i servatively envelope the other installed clamp types (i.e., to test the clamp l
assemblies with the lowest capacity).
The clamp as;emblies were tested to failure in each of the directions in which these assemblies provide significant restraint, and the load / displacement behavior was recorded.
From these results, the allowable design load was determined.
To provide assurance that the clamp assembly would remain functional when subjected to cyclic loads produced by seismic events, cyclic tests were performed to simulate the design life of five OBE events and one SSE event.
On the basis of its review and discussions, the staff found that the tests were complete and were performed in a conservative manner.
The results have been appropriately incorporated in the acceptance criteria and are, thus, acceptable.
4.1. i. 7 Acceptance Criteria l
Ebasco's acceptance criteria for cable tray hangers arc specified in documents SAG.CP3 and SAG.CP4.
Structural members, welds, and anchorages were evaluated in accordance with the acceptance criteria in the general instructions, docu-ment SAG.CP34.
Acceptance criteria for the qualification of cable trays are contained in document SAG.CP18.
Design criteria and procedures for the design validation of cable tray clamps are contained in document SAG.CP19.
Impell Instruction PI-03 contains the acceptance criteria for verifying cable tray hanger members; Instruction PI-06 provides the acceptance criteria and procedures for verifying the cable trays and clamps.
Instruction PI-07 con-tains the acceptance criteria and procedures used to verify anchorage compo-nents such as embedded bolts and plates, base plates, and welds.
Instruction PI-11 contains the criteria and procedures used for the reconciliation of system analyses, resolution of failures, and closeout of calculation files.
]
The staff reviewed the acceptance criteria at an inspection held at the Ebasco office on November 2-5, 1987 (Appendix D to this supplement - Event 18).
In-cluded in the review were the methods used for (1) checking the acceptability of welds, bolts, oversized bolt holes, and bolt hole / edge distance effects under specified loading conditions; (2) developing K values for structural members and prying action factors for anchor bolts to be used in analysis; and (3) qual-ifying cable trays, fittings, and clamps under specified loading conditions.
These methods are used for design validation by both ESM and RSM analysis.
The staff reviewed the methodology, procedures, supporting studies, test proce-dures, and test results on which the acceptance criteria for design verifica-tion are based.
Additional documentation reviewed by the staff consisted of (1) a position paper on oversized bolt holes, "Effects of Bolt Hole Oversize on CTH System Adequacy"; (2) K values for longitudinal supports with in plane loads; (3) tray qualification package; and (4) system effects on tray qualification.
Comanche Peak SSER 15 4-19 I
At inspections held at the Ebasco office on November 2-5, 1987, and March 30-31, 1988 (Appendix 0 to this supplement - Events 18 and 21, respectively), the staff reviewed the following design validation-packages containing acceptance criteria:
four typical-RSM hanger qualification packages CTH-1-6086 CTH-1-6087 CTH-1-2846 CTH-1-2848 two typical ESM qualification packages CTH-1-1668, which contained the design validation for a three-tter, two-tray transverse support CTH-1-2088, which contained the design validation for a horizontal longitudinal support one typical cable tray qualification package CT-1-24, which contained the design validation for both an elbow and straight tray segments one ESM hanger qualification package CTH-1-7053, which was reviewed because it illustrates the use of Attachment S of document SAG.CP34 to qualify warping stresses in anchorage welds At an inspection held at the Impell site office on April 18-21, 1988 (Appen-dix D to this supplement - Event 22) to evaluate the adequacy of the acceptance criteria used in each case, the staff reviewed data on (1) structural members and welds; (2) anchorages including bolts, inserts, base plates, base angles, and spring action factors; (3) slenderness ratio, twist buckling, and warping stresses; and (4) trays, tray fittings, and clamps.
The staff reviewed the methodology, procedures, supporting studies, and test results on which the acceptance criteria are based.
All loads, used for design validation are obtained from the system analysis per-formed using computer program SUPERPIPE.
Structural members and welds are automatically analyzed using computer program SUPERPOST for the load combina-tions discussed in Section 4.1.1.1 of this supplement.
The acceptance criteria comply with the AISC code, Seventh Edition (Reference 22), and the CPSES FSAR (Reference 19) and are, thus, acceptable.
Detailed procedures are provided for the design validation of anchorages includ-ing the use of prying action factors.
Allowable values for attachment bolts and inserts are based on test data and appropriate factors of safety.
Allow-able forces and moments for trays, fittings, and clamps are based on the CCL test results and on analysis.
Detailed instructions are provided for verifying permissible slenderness ratios and for evaluating warping-induced stresses.
Comanche Peak SSER 15 4-20
I The staff reviewed the following typical design validation packages containing
.l acceptance criteria:
1 four RSM system analysis pack.ges (192-154-10, 192-154-11, 217.-88-11, and 187-82-05), which contained the design validation for trays, splices, and clamps four hanger qualification packages (CTH-1-6565, CTH-1-6559, CTH-1-2710, and CTH-1-2539), which contained the design validation for the hanger members, welds, and anchorages On the basis of its review of the design validation packages satisfying the acceptance criteria in Ebasco's and Impell's procedures and project instructions, the staff concludes that the acceptance crit,";a for the design validation of cable trays, hangers, and supports are complece and conform with project commit-ments and applicable codes and are, thus, acceptable.
4.1.2 Design Validation Ebasco and Impell validated the design of all safety-related cable trays and cable tray hangers
- at CPSES, There are 5359 safety related hangers in Unit 1 and common areas and 4766 in Unit 2.
The number of hangers and the number and types of design validation packages in the Impell and Ebasco design validation scope, as well as the analysis methods used, are shown in Tables 4.1 and 4.2.
Table 4.1 Cable tray and cable tray hangers (Ebasco)
Unit 1 and common areas Unit 2 Equivalent Equivalent.
static method Response spectrum method static method Scope (ESM)
(RSM)
(ESM)
Number of hangers 2654 475 4766 Number and type 2654 hanger 48 "string" 475 hanger 4766 hanger i
of design valida-packages packages packages packages tion packages Analyzed subcomponents in package Structural members Yes Yes No Yes Tray clamps Yes No Yes Yes Welds Yes No Yes Yes Anchorages Yes No Yes Yes Tray & fittings
- Tray splices *
[
[
[
[
- Separate tray qualification book - Volume IV i
- This includes all trays and hangers classified as seismic Category I and seis-mic Category II.
Comanche Peak SSER 15 4-21
.1 lable 4.2 Cable tray.and cable tray hangers (Impell)
Unit 1 and common areas Scope Response spectrum method (RSM)
Number and type of design 200 system 2230 hanger validation packages packages packages Number of hangers 2230 Analyzed subcomponents
'j in package Structural members No Yes Tray clamps Yes No Welds No Yes Anchorages No Yes Tray & fittings Yes No Tray splices Yes No j
Impell's and Ebasco's design validation process for cable trays and cable tray hangers consisted of the following steps (1) As-Built Process - Information on the as-built cable trays (including fittings and clamps) and cable tray hangers was obtained, as described in Section 4.1.2.1 of this supplement, in order to develop the input data required for analysis.
i (2) Analysis - The information obtained in Step 1 was used to analyze the cable trays and cable tray hangers using the methodology and loading con-ditions described in Section 4.1.1 of this supplement.
l (3) Modificatiors - The results of the analysis in Step 2 were reviewed to determine if the design criteria were satisfied.
If the analysis results did not conform with the design criteria, the cable trays and/or cable tray hangers were modified as described in Section 4.1.2.3 to ensure con-formance with the design criteria.
(4) Final Reconciliation - Final reconciliation of the analysis, modifications, design-validated cable tray hanger drawings, and inspection documentation, as described in Sections 4.1.2.4 and 4.1.4 of this supplement, ensures consistency between the design documentation and the final installed con-figuration of the cable trays and cable tray hangers.
4.1.2.1 As-Built Process l
l The first step in the design validation process was the collectio, of informa-tion on all as-built safety-related cable trays and cable tray har.gers at CPSES.
The as-built process consisted of a complete engineering walkdown by Ebasco Comanche Peak SSER 15 4-22
i personnel of the installed cable trays and cable tray hangers, which resulted in as-built drawings containing information for determining the cable tray routing, the location of the hangers on the cable tray :'un, tray identification number, cable tray hanger type, har. w identification number, number and size I
of G ble trays supported by the han,', dimensions of tray fittings, location l
of fire protection material, and hanger geometry (member sizes, dimensions, anchor bolt information, weld joints, clamp type, and orientation of the hanger relative to the tray).
Before the as-built drawings were released for anal-ysis, quality contral personnel verified that the drawings conformed with the actual installation.
The staff audited the as-built program for cable tray; and cable tray hangers at the CPSES site on September 8-10, 1987 (Appendix D to this supplement -
Event 16).
The scope of the audit included (1) a review of the as-built pro-cedures for technical adequacy, (2) a review of the implementation of proce-dures and process flow chart, (3) a review of selected installed supports and tray runs to verify agreement with final drawings, and (4) a walkdown of cable tray runs and supports for any visually apparent discrepancies.
The principai procedures used for the as-built program at CPSES are TE-FVM-C/S-001, "Field kerification Method - Unit 1 Cable Try Hanger As-Builting and Design Adequacy Verification Program," and TE-FVM-C/S-003, "Field Verification Metnod
- Unit 2 Cable Tray Hanger As-Builting and Design Adequacy Verification Program,"
which were developed to control the collection of as-built data on cable tray hangers.
The staff reviewed these procedures and discussed them with the engi-neers who were involved with their implementation.
Other procedures that were daveloped for obtaining information on a specific attribute and that were reviewed by the staff were TE-FVM-C/S-019 "Field Veri-fication Method - Unit 2 Cable Tray Selected Attributes As-Builting Program,"
and TE-FVM-C/S-048, "Field Verification Method - Unit 1 Cable Tray Selected Attributes As-Built Program," which were developed to control the collection of specific as-built data required for validating the design of cable trays.
The staff reviewed 1E-FVM-C/S-050, "Field Verification Method - T.J. Cope Tray Ladder Tee Fitting - Selected Attributes Data Collection," which was developed to control the collection of as-built data on tray ladder tee fittings, and CPE-EG-FVM-CS-084, "Field Verification Method - Engineering Walkdown for Replacement of Cable Tray Fittings in Units 1 and 2," which was developed to control the collection of as-built data on nunstandard cable tray fittings.
The staff also reviewed CPE-EB-FV& CS-098, "Field Verification Method - Cable Tray Rung Spacing Walkdown - Units 1 and 2," which was developed to control the 2
collection of as-built data on cable tray rung spacing in order to identify fittings with excessive rung spacing, and CPE-EB-FVM-CS-100, "Field Verifica-tion Method - Cable Tray Hanger Walkdown for Clamp Identification for Unit 1,"
which was developed to control the collection of as-built data on unacceptable cable tray clamp combinations.
The staff found that the procedures being used in the as-builting and design adequacy verification program are sufficiently detailed so that they tan be effectively implemented by the responsible personnel.
Walkdown engineers are formally trained in the use of the procedures and showed that they were famil-iar with the requirements.
Comanche Peak SSER 15 4-23 i
i 1
The staff reviewe'd the work sequences and document flow to determine if the applicable procedures were properly implemented.
It reviewed four completed Unit 1 packages for implementation of procedural requirements, including walk-down checklists and inspection reports.
The staff found that the work activi-ties conformed with procedural requirements and were well controlled and are, thus, acceptable.
The staff conducted walkdowns of five Unit 1 tray spans, including nine supports, and of four Unit 2 tray segments, including five supports, to determine conform-ance to drawings and procedural requirements.
It compared the span drawings and the support drawings with the actual installations by checkirn the following characteristics during the walkdowns:
(1) size, configuration, and location of the tray spans and the supports (2) identification of the supports (3) types of clamps (4) types and sizes of welds (5) types, sizes, and material of bolts (6) orientation of members (7) tray location on tier (8) configuration of anchorages (9) attachments to tray, i.e., conduit (10) tray span lengths (for %it 2 only)
(11) tray or segment numbers The staff conducted a walkdown through randomly selected areas in Units 1 and 2 to note any visually apparent discrepancies.
Tray discrepancies that were visually apparent during the walkdowns included nonstandard splice plates, side-rail cutouts, and nonstandard hinged fittings used for small changes in the horizontal or vertical direction.
A followup audit at the CPSES site on June 13-16, 1988 (Appendix D to this sup-plement - Event 23) determined tha+. these discrepancies were reported by means of significant deficiency analysis reports (SDARs) and are being resolved under the Post-Construction Hardware Validation Program by making hardware changes or by qualifying the nonstandard configuration by the establishment of a minimum rated load.
As a result of the walkdowns of tray runs and hangers, the staff concluded that the cable tray hanger configurations documented by the Ebasco as-built verifi-cation program are sufficiently complete and accurate so that they can be used for the design validation of the CPSES cable trays and cable tray hangers.
4.1.2.2 Analysis The as-built cable trays and cable tray hangers were analyzed for deadweight loads and seismic loads in accordance with the criteria and methodology described in Section 4.1.1 of this supplement.
Deadweight loads include both cable tray and cable tray hanger weights and are based on as-built information.
The cable tray deadweight incluaes the weight of cables, tray, tray cover, side-rail extensions, and fire protection material.
The seismic load is calculated for the OBE or the SSE event using the CPSES amplified response spectra (ARS).
The design of cable trays and cable tray hangers was validated using either the equivalent static method (ESM) or the response spectrum method (RSM).
These seismic ?nalysis methods are discussed in Section 4.1.1.3 of this supplement.
Comanche Peak SSER 15 4-24
The staff reviewed the design criteria and methodology used for the analysis of the cable trays and cable tray hangers at inspections and audits held on Novem-ber 2-6, 1987, March 30-31, 1988, and April 18-21, 1988 (Appendix D to this supplement - Events 18, 21, and 22, respectively).
The staff's evaluation of the desigr. criteria and methodology is discussed in Section 4.1.1 of this supplement.
l During these audits and inspections, the staff also reviewed calculation pack-ages to determine if the procedures that incorporate the design criteria and methodology to be used in the analyses were adequately implemented.
The staff selected the packages for two supports that were design validated by Ebasco using ESM in order to evaluate the application of the design validation pro-cedures.
The support packages selected were CTH-1-2088, Revision 1, and CTH-1-1668, Revision 1.
The staff reviewed (1) the modeling of supports for the STRUDL program, including eccentricities, load application, and brace connections; (2) the system fundamental frequency; (3) the multimode response multiplier; (4) the load distribution between supports; (5) the connectivity effects; (6) the load combinations of seismic and deadweight loads; (7) axial and torsional buckling criteria; and (8) the anchor &ge flexibility effects.
The staff found that the calculations in the packages were performed in accor-dance with the procedures and guidelines specified for ESM analysis, and are, thus, acceptable.
The general instructions with attachments, although complex in some parts, are sufficiently clear and detailed to permit proper implementa-tion.
Because of the complexity of some instructions, the work was organized so that certain evaluations such as the screening procedures (document SAG.CP28),
the use of Attachments Y and Z of document 3AG.CP34 for load distribution and longitudinal connectivity, the calculation of stiffnesses for nonstandard anchorage configurations, ar:d the qualification of cable trays, fittings, and clamps were under the purview of special groups who provided the required information for the analysis.
The staff reviewed a sample package that was design validated by Ebasco usir:g RSM in order to verify that procedures had been correctly implemented.
It ano reviewed a calculation package, RSM-1-AUX-25, involving 14 supports.
Two of the support packages, CTH-1-6068 and CTH-1-6067, were reviewed for weld and anchorage evaluation.
The staff reviewed the analysis, particularly the tech-niques used for modeling member eccentricities, tier loading, and/or stiffness calculations.
It also reviewed an RSM "string" analysis, RSM-1-AUX (ELE)-4, involving "overlap" and "analysis only" supports, after the inspection.
The staff found that this "string" analysis as well as the calculation package, RSM-1-AUX-25, were complete and accurate and that the procedures had been followed satisfactorily.
The staff concludes that the Ebasco methodology for RSM analysis as presented in document SAG.CP11 and supporting studies is ade-quate for the design validation of cable trays and supports.
During the inspection at the Impell site office on April 18-22, 1988 (Appen-dix 0 to this supplement - Event 22), the staff reviewed a sample RSM system analysis (calculation / problem No. 187-82-05) as well as one of the "break" support packages (CTH-1-2539) included in the analysis.
The staff reviewed (1) the modeling of supports for the SUPERPIPE program, including eccentricities, brace connections, and anchorages; (2) the modeling of trays, tray fittings, and clamps; (3) the justifications for neglecting certain eccentricities in the SUPERPOST model; (4) the validation of support members and welds using the Comanche Peak SSER 15 4-25
SUPERPOST program with loads extracted from the SUPERPIPE program; and (5) the validation of trays, anchorages, and clamps using loads fr,om the SUPERPIPE pro-gram and allowable values from test results or special studies.
The staff reviewed the applicable procedures, instructions, supporting studies, and test data.
It also reviewed the overlap criteria that are used to break systems down into smaller analysis packages, the requirements for "break" supports, and the modeling of "analysis only" supports as well as the justifi-cation for this methodology.
Additional RSM system analysis packages that were reviewed after the audit were calculation / problem Nos. 192-1:>4-10 and 192-154-11 as well as calculation package CTH-1-6565, which included loads from RSM analysis 192-154-10.
On the basis of its reviews, the staff found that the Impell criteria and methodology for RSM analysis were applied in accordance with the appropriate procedures and instructions and are, thus, acceptable.
4.1.2.3 Modifications Modifications that may be r quired for as-built cable tray hangers are divided into (1) Type 1 modifications, which are meant to correct installation discrep-ancies observed by the walkdown engineers during the as-built process ar.d which are generally not amenable to resolution by engineering analysis, had (2) de-sign modifications, which result from the design validation process and are required for the hanger to meet the design criteria.
l The procedures for cable tray hanger modifications are given in TE-FVM-C/S-001, l
"Field Verification Method - Unit 1 Cable Tray Hangers As-Builting and Design i
Adequacy Verification Program," and in Impell Project Instruction PI-11, "Cable Tray System Analysis and Qualification Closecut." Type 1 modifications are generally processed by quality control personnel by means of nonconformance l
reports and do not require any engineering evaluation.
Approximately 20 percent of the cable tray nangers in Unit 1 and common areas required design modifications resulting from the design validation process.
During a site audit on June 13-16, 1988 (Appendix D to this supplement -
Event 23), the staff reviewed the procedures, and their implementation, for j
accon,plishing the design modifications of as-built cable tray hangers.
Nine l
cable tray hanger packages (CTH-1-509?, CT-1-1430, CTH-1-1533, CTH-1-2402, CTH-1-1671, CT-1-5082, CTH-1-6276, CTH-1-2685, and CTH-1-3148), which required modifications as a result of overstress conditions found during the design validation process, were selected for review.
Five packages were processed by Impell using RSM analysis, three packages were processed by Ebasco using ESM analysis, and one was an Ebasce RSM analysis package.
The review followed the modification from its initiation at the time of the analysis, development of the modification concept, field concurrence with the modification concept, analysis to demonstrate the acceptability of the modification, documentation to implement the modification, and incorporation of the modification into the final design-validated hanger drawing.
The staff found that the process for document-in-codifications was correctly implemented in accordance with established pio-ce, ses and is, thus, acceptable.
i Comanche Peak SSER 15 4-26
4.1.2.4 Final Reconciliation The purpose of final reconciliation is to consolidate analysis, hanger modifi-cation, and inspection documentation to ensure that the documentation on the-design of cable trays and cable tray hangers is consistent with the installa-tions.
Final reconciliation is addressed in Section 4.1.4 of this supplement.
4.1.3 Hardware Validation In letters dated August 20, August 28, September 8, and September 23, 1987 (Ref-I erence 9, 10, 11, and 12, respectively), and in the cable tray and cable tray l
hanger project status report (Reference 18), the applicant described to the NRC staff its program for hardware validation.
The program referred to as the l
"Post-Construction Hardware Validation Program (PCHVP)" is one of the major elements of the Corrective Action Program (CAP).
The staff's evaluation of the overall concept of the CAP including the PCHVP was provided in a letter from S. D. Ebneter (NRC) to W. G. Counsil (TU Electric) dated January 22, 1988 (Reference 14).
For cable trays and cable traj hangers, the PCHVP was divided into two areas:
(1) preparation of as-built drawings under the as-built and design validation program (2) inspection of the as-built drawings based on the attributes requiring validation under the PCHVP The staff's evaluation of the cable tray and cable tray hanger as-built program including the preparation of as-built drawings is discussed in Section 4.1.2.1 of this supplement.
The second area above of the PCHVP validates the final acceptance attributes for safety-related cable trays and cable tray hangers.
The final acceptance attributes are based on validated installation specifications and are docu-mented in the PCHVP attribute matrix for cable trays and cable tray hangers as provided in Table 5-2 of the cable tray and cable tray hanger project status report (Reference 18).
The field verification methods (FVMs) that were used in the implementation of the PCHVP (including the FVMs used to obtain as-built information for design validation) are given below:
TE-FVM-C/S-001, TE-FVM-C/S-019, TE-FVM-C/S-036, TE-FVM-C/S-050, CPE-EB-FVM-CS-084, CPE-EB-FVM-CS-098, and CPE-EB-FVM-CS-100 were developed to obtain as-built information for design validation and are discussed in Section 4.1.2.1 of this supplement.
CPE-SWEC-FVM-CS-068, "Field Verification Method - Commodity Clearance,"
was developed to control the collection of as-built data for evaluating clearances between adjacent plant components.
CPE-SWEC-FVM-EE/ME/IC/CS-086, "Post-Construction Hardware Validation (PCHV)
Program Construction / Quality Control Reverifications," was developed to identify the locations and color codes for cable trays with Thermo Lag.
Comanche Peak SSER 15 4-27 i
4 l
J i
CPE-SWEC-FVM-EE/ME/IC/CS-088, "Post-Construction Hardware Validation (PCHV) Program Engineering / Quality Control Reverifications," was developed-1 to control the collection of as-built data for cable tray separation and barriers.
CPE-SWEC-FVM-EE/ME/IC/CS-090, "Post-Construction Hardware Validation (PCHV)
Program Quality Control Reinspection," was developed to control the collec-
)
tion of specific as-built data (e.g., data on Hilti thread engagement,;
cable tray covers, and cable tray fill above side rails) for cable trays and cable tray hangers.
The staff finds that the above PCHVP procedures and those discussed in Sec-tion 4.1.2.1 of this supplement reasonably ensure that construction deviations are identified in the installed hardware to enable the performance of appro-priate engineering studies and testing in the development of specific design criteria, guidelines, and procedures for use in the design valioation of CPSES cable trays and cable tray hangers.
The staff also finds that the PCHVP proc-ess and attribute matrix provide an acceptable method for ensuring that the installed cable trays and cable tray hangers are consistent with the design input and the analytical methodologies used in their design validation and are, j
thus, acceptable.
The staff, however, plans to review the specific attributes to determine if they should be reinspected or excluded from the PCHVP attribute matrix.
4.1.4 Final Reconciliation Final reconciliation was performed in accordance with Impell Instruction PI-11, "Cable Tray System Analysis and Qualification Closeout," and Ebasco "Manual of Procedures, Comanche Peak SES."
The purpose of final reconciliation is to consolidate analysis, hardware modification, and inspection documentation to ensure that documentation on the design of cable trays and cable tray hangers is consistent with the installation of hardware.
At the conclusion of final reconciliation, the design validation packages (DVPs) were compiled.
The cable tray and cable tray hanger DVPs consist of as-built cable tray and cable tray hanger data, cable tray and cable tray fit-tings calcuiations, cable tray clamp calculations, cable tray hanger calcula-tions, and design-validated cable tray hanger drawings.
The staff concludes that the final reconciliation of cable trays and cable tray hangers is adequate and complete because it (1) reconciles validated design input with as-built configurations (2) incorporates the resolution of third party (CPRT) issues and other issues raised by sources external to the TU Electric project organization (3) includes confirmation of results from ir.teracting design organizations 4
(4) resolves open itens from NRC notices of violations and TV Electric significant deficiency analysis reports Because of the inclusion of the above items in the final reconciliation, the staff concludes that the scope of the final reconciliation is sufficient to Comanche Peak SSER 15 4-28
i ensure that all design deficiencies and external-source issues are closed and that the cable trays and cable tray hangers comply with validated design docu-i mentation and is, thus, acceptable.
4.1. 5 Final Documentation The fifth and final step in the overall CAP nrocess for cable trays and cable tray hangers was the transmittal of CAP results (e.g., design validation pack-ages) to the permanent records facilities.
The results were processed accord-ing to Procedure ECE 2.13 and transmitted according to the requirements of the "Comanche Peak Records Management Program Manual." Because the design basis and analyses of record for the CPSES plant are established under the CAP, the staff concludes that the final documentation ensures that (1) the technical bases and criteria used for the CPSES design and (2) the analysis results documenting the compliance of the as-built cable trays and cable tray hangers with the design basis will be controlled during plant operation and are, thus, acceptable.
l 4.2 Third-Party Actions 4.2.1 CPRT Review (TENERA, L.P.)
TENERA, L.P. (previously known as TERA Corporation) conducted the CPRT third-party reviev of the cable tray and cable tray hanger activities to ensure verification of the resolution of issues, to confirm the adequacy of design i
criteria, and to provide an overview of the cable tray and cable tray hanger design verification activities.
The review as described in CPRT Program Plan OSAP VIII (Revision 3) (Reference 27) consisted of three major activities:
(1) identification, review, and tracking of all external-source issues (2) verification that all design criteria and applicable standards are addressed in project procedures (3) oversight of the proje;t activities and corrective actions The CPRT Program Plan describes the third party area of review related to the identification, review, and tracking of external-source issues.
The review of external-source issues included not only issues related to cable trays and cable tray hangers but also issues related to piping, pipe supports, conduit supports, mechanical systems and components, electrical systems, instrumenta-tion and control, and civil / structural disciplines.
However, this supplement addresses only those external-source issues related to cable trays and cable tray hangers.
As stated in the foreword to Revision 4 of the CPRT Program Plan (Reference j
13), TU Electric's commitment to the CAP, with its comprehensive design vali-l dation component, resulted in a decision by the CPRT Senior Review Team (SRT) to redirect the Design Adequacy Program as of April 10, 1987.
As a result of this redirection, further identification, review, and tracking of external-source issues were terminated.
l Comanche Peak SSER 15 4-29
The CPRT third party review has established applicable criteria based on the CPSES Final Safety Analysis Report (FSAR) (Reference 19) and licensing commit-ments, and compared both Ebasco's and Impell's procedures and suppo-ting documentation with those criteria.
The design criteria include FSAR commit-ments, applicable NRC regulatory guides, and referenced industry codes and standards.
The CPRT third party oversight of the CAP design validation activities for cable trays and cable tray hangers included reviews of (1) the as-built proce-dures, (2) the design validation procedures, (3) the special studies, and (4) the test programs implemented by Ebasco and Impell.
The CPRT third party activities also included a review of Ebasco's and Impell's procedures, special studies, and test program results as they related to the resolution of each cable tray and cable tray hanger issue raised by sources external to the TU Electric project.
As such, the external-source issues were reviewed as an integrated part of the third party review of Ebasco's and Impell's procedures, spt.cial studies, and test program results.
The staff inspected the third party activities at the office of TENERA to evaluate the activities associated with the CPRT third party review.
The inspections in the area of cable tray and cable tray hanger design were con-ducted from October 28 to November 1, 1985, at Bethesda, Maryland (Appendix D to this supplement - Event 2) as documented in Inspection Report 50-445/85-17; 50-446/85-14 (Reference 24), and from July 7 to July 10, 1986, at Berkeley, California (Appendix D to this supplement - Event 11) as documented in Inspec-tion Report 50-445/86-19; 50-446/86-16 (Reference 16).
TENERA addressed open items identified in Inspection Report 50-445/86-19; 50-446/86-16 related to cable trays and cable tray hangers, and their resolution is provided in Appen-dix B to this supplement.
In addition, the staff audited the CPRT third party activities at the TENERA office in Bethesda, Maryland, on November 12 and 13 and December 2 and 3, 1985 (Appendix 0 to this supplement - Events 4 and 6, respectively) and in. Berkeley, California, from September 28 to October 1, 1987 (Appendix D to this supple-ment - Event 17).
The staff has reviewed and evaluated the (.PRT third party involvement in the identification, review, and tracking of issues.
In its review of the process used by the CPRT third party to identify, review, and track external-source issues, the staff found that the issues, as they were identified, were logged into a computer and their status was tracked on the basis of a periodic updat-ing of the issue evaluation.
This process provided a reasonable method for i
ensuring that all identified external-source issues were properly tracked until they were resolved.
TENERA identified the external-source issues by reviewing 364 source documents containing issues of concern.
The documents included Atomic Safety and Licensing Board (ASLB) hearing transcript,, submittals to the ASLB by the various parties, NRC staff meeting transcripts, safety evaluation reports, inspection reports, and CYGNA letters and reports.
The TENERA review of the source documents identified approximately 200 issues related to cable trays and cable tray hangers.
A discrepancy / issue resolution report (DIR) was assigned to each issue to track it to closure.
TENERA consolidated approximately i
200 DIRs into 31 issue groups (29 issue groups correspond to the groups identi-fled by CYGNA); the staff's evaluation of each issue group is provided in Comancht: Peak SSER 15 4-30
m J
J Appendix A to this supplement.
On the basis of its review of the scope of the i
external-source issues, including all issues identified by CYGNA, the interve-nor, and the NRC staff, the staff concludes that the scope is complete and acceptable.
The staff reviewed the process used by TENERA to verify design criteria and standards used by Ebasco and Impell.
The TENERA process involved a review of all FSAR commitments and relevant industry codes and standards (e.g., those of the American National Standards Institute and American Institute of Steel Construction) in accordance with CPRT Design Adequacy Procedure 1 (DAP-1),
"Preparation and Review of Criteria Lists," to develop a design criteria list.
OAP-1 describes the preparation of design criteria lists and requires all cri-teria and commitments used in the CPSES design to be sequentially numbered and summarized and the source document identified.
The design criteria list was used to develop a checklist for reviewing Ebasco's and Impell's design criteria and procedures.
The staff finds that the process provided a systematic method for ensuring that all relevant design criteria, standards, and licensing commit-ments were identified, documented, and addressed in Ebasco's and Impell's design procedures and is, thus, acceptable.
The staff reviewed the results of the CPRT third party oversight of the project activities related to the design validation of cable trays and cable tray hangers as documented in a CPRT Design Adequacy Program report entitled "Dis-l cipline Specific Results Report:
Civil / Structural - Cable Trays and Supports,"
DAP-RR-C/S-001, Revision 1, September 25, 1987 (Reference 25) (hereinafter referred to as the "cable tray hanger results report").
]
)
The staff reviewed the cable tray hanger results report and finds that it is well written and well organized.
The sections in the main text are technically i
straightforward and concise, and the attachments provide a practical and useful i
aid for tracking the sources of the issues and their resolution in project and third party documents.
Overall, the cable tray hanger results report adequately describes the findings resulting from the TENERA oversight of the CPSES cable tray and cable tray hanger design.
i The staff reviewed the CPRT third party (TENERA) review of Ebasco's and Impe11's special studies and design procedures.
TENERA's reviews of Ebasco's and Impell's documents resulted in either an engineering evaluation or a review checklist:
The reviews of the special studies for cable trays and cable tray 4
hangers were documented in engineering evaluations; the reviews of the design procedures were documented in review checklists.
In total, TENERA issued 81 engineering evaluations and 8 review checklists.
l On the basis of its reviews, the staff finds that the TENERA engineering eval-l uations provide a comprehensive review of the special studies performed by l
Ebasco and Impell and that the TENERA review checklists provide a systematic method for ensuring the completeness of the Ebasco and Impell design procedures in regard to satisfying applicable code and standard requirements and licensing commitments.
The staff concludes that the CPRT third party activities related to cable tray and cable tray hanger design provide an adequate program for ensuring that all external-source issues are identified, that the Ebasco and Impell criteria and l
procedures used for the resolution of external-source issues are technically Comarche Peak SSER 15 4-31 1
l
adequate, and that the Ebasco and Impell design criteria and procedures satisfy FSAR commitments, applicable code and standard requirements, and NRC regulatory guides.
4.2.2 TU Electric Technical Audit Program The TU Electric Technical Audit Program (TAP) is described in a letter from W. G.
Counsil to the NRC dated September 8, 1987 (Reference 26).
The TAP, which is part of the TV Electric Quality Assurance Program, was established to (1) ensure the technical and programmatic effectiveness of the Corrective Action Program (CAP) and (2) provide oversight of project responses to CPRT recommendations.
For cable trays and cable tray hangers, the TAP audits of the CAP activities are designed to evaluate the effectiveness of the design validation process and the technical adequacy of the validated design product and supporting documenta-tion.
These audits are coordinated with other TU Electric audit activities and with the Engineering Funictional Evaluation (EFE) (Reference 26).
(The EFE activities are being addressed by NRC staff inspections of those design areas under the EFE scope of review.) TAP audits are also conducted on project actions taken in response to CPRT recommendations as part of the Issue-Specific Action Plan (ISAP) audit program.
The TAP audit methodology used for the CAP and ISAP audits is described in NE0 (Nuclear Engineering and Operations)
Quality Assurance Department Procedure NQA 3.07-1.01, "Technical Audit Program" (Attachment 3 to Reference 26).
The audit methodologies include both a verti-cal and a horizontal review of the design validation process.
The vertical methodology reviews the cable tray and cable tray hanger designs contained within a selected package.
The horizontal methodology reviews a resolution of an external-source issue common to a number of cable tray and cable tray hanger packages.
On the basis of its review of TAP audit reports on CAP activities at a site audit or, June 13-16, 1988 (Appendix 0 to this supplement - Event 23), the staff finds that under the TV Electric TAP, the implementation of technical and i
design control requirements for the design validation of CPSES Unit 1 and common area cable trays and cable tray hangers is being effectively audited.
In addition, the staff finds that under the TAP, appropriate actions have been taken to resolve discrepancies previously identified during the CPRT audits of the cable tray and cable tray hanger design validation activities.
On the basis of its review of the TAP activities, the staff finds the TAP provides an effec-tive level of technical oversight of the CPSES cable tray and cable tray hanger design validation that is comparable to the level provided previously by the CPRT third party oversight and is, thus, acceptable.
4.2.3 CYGNA Energy Services Review The cable tray and cable tray hanger design issues identified by CYGNA as a result of its Independent Assessment Program (IAP) (Phases 1-4) for CPSES were included in CPRT Program Plan DSAP VIII and designated as external-source issues.
With the establishment of the CPRT Program Plan and the TV Electric CAP design validation, the activities of CYGNA related to the IAP have been i
effectively addressed.
Ebasco and Impell addressed the CYGNA cable tray and cable tray hanger issues as part of the resolution of external source issues in Comanche Peak SSER 15 4-32
__.,..m.
~. _ _ _
l Appendix A to the cable tray and cable tray hangor project status report (Ref-erence 18); the staff evaluated the issues in Appendix A to this supplement.
The CYGNA findings related to other design areas - civil / structural, piping, conduit supports, mechanical and electrical systems, instrumentation and con-trol, and design control - have been or will be addressed by the staff in supplemental safety evaluation reports for those areas.
CYGNA is continuing its design reviews under the formal protocol established during the IAP for closure of the cable tray and cable tray hanger issues raised by CYGNA.
The status of the CYGNA reviews is documented in review is-sues lists (RILs) for each design disciplirie in their scope.
For cable trays and cable tray hangers, all the issues in the respective RIls (Reference 17) have been closed.
The staff finds that the CYGNA review provides an additional level of confi-dence that the corrective actions taken by TV Electric to resolve the defi-ciencies in the design of cable trays and cable tray hangers are appropriate and acceptable.
1 l
i i
Comanche Peak SSER 15 4-33
i 5 PREVENTIVE ACTIONS In assessing the adequacy of the preventive actions taken by TV Electric with respect to the programmatic and quality assurance aspects of the Corrective Action Program (CAP) design validation of the CPSES cable trays and cable tray hangers,.it is important to understand the und9rlying causes of the cable tray and cable tray hanger design problems under the past program that resulted in the types of deficiencies identified by external sources.
In this section, the staff identifies the underlying causes of deficiencies under the past program and addresses,the appropriateness of the preventive actions taken by the appli-cant under its CAP to preclude their recurrence.
Initial Design Process for Cable Tray Systems
- To identify the root causes of the deficiencies in the design of the cable tray systcms, the staff reviewed the process for the design, fabrication, erection, and inspection of the systems under the past program.
The cable tray systems were originally designed by Gibbs & Hill, the cable trays and fittings were purchased by TV Electric, the cable tray hangers were fabricated by Brown &
Root, and the cable tray systems were installcu and in cected by Brown & Root.
The Gibbs & Hill design for the cable tray systems was e in in Gibbs & Hill 2323-El-XXXX drawings for various elevations in the plan uildings.
Cable tray routing and cable tray hanger locations were identified in these Gibbs &
Hill 2323-El series of drawings, and standard cable tray hanger designs were provided in Gibbs & Hill 2323-S-09XX series of cable tray support drawings.
The design calculations for the standardized cable tray hanger configurations shown in the Gibbs & Hill 2323-5-09XX series of drawings were contained in Gibbs & Hill calculation binders.
Cable trays and fittings were purchased by j
TU Electric in accordance with Gibbs & Hill Specification 2323-ES-19 and were provided to Brown & Root for installation in the cabla tray systems.
Cable j
tray hangers were fabricated, erected, and inspected in accordance with Gibbs &
l Hill Specification 2323-SS-16B, "Structural Steel (Category I)," and the cable tray systems were erected and inspected in accordance with Brown & Root Proce-dure 35-1195-ECP-10, "Cable Tray and Hanger Installation."
Brown & Root Procedure 35-1195-ECP-10 required that after approved Gibbs & Hill 2323-El parts drawings were received, the Brown & Root site f! eld support engineering (FSE) group develop Brown & Root "hanger location" or "support map" El-XXXX-5, FSE-4444 drawings, which assigned unique hanger identification numbers to the cable tray hangers.
The identification numbers were logged in a cable tray hanger index.
After this FSE "map drawing" was approved, a fabrication / detail 2323-FSE-000159, XXXX ("Cable Tray Hanger Assembly") drawing was prepared for each hanger - the XXXX portion of the drawing number was to correspond to the hanger identification number.
The 2323-FSE-000159 drawings
- Cable tray systems" refers to the overall structural assemblage consisting of cables, cable trays, cable tray hangers, and other related structural com-ponents (e.g., clamps).
Comanche Peak SSER 15 5-1
were prepared from drawings showing no dimensions that corresponded to the standard hanger designs developed by Gibbs & Hill as shown in its 2323-S-0900 series of drawings and the multisheet Brown & Root 2323-FSE-179 ("Attachment for Cable Tray Hanger") drawing.
This Brown & Root 2323-FSE-179 drawing showed hanger types and attachment details based on the Gibbs & Hill 2323-S-0900 series of drawings.
Each 2323-FSE-000159, XXXX drawing was completed by the addition of dimensions derived from the Gibbs & Hill 2323-5-0900 series of drawings.
Attachments to concrete or embedded plates were shown for reference only.
The hanger detail was determined in the field in accordance with the Gibbs & Hill 2323-5-0900 series of drawings and/or field sketches prepared by Brown & Root site engineering personnel.
Approval of the detailed Brown & Root 2323-FSE-000159 drawings by the responsible Brown & Root engineering organization was required before fabrication.
Subsequently, if it was determined that a hanger could not be erected as shown on a 2323-FSE-000159 drawing, the problems were resolved by the use of component modification cards or design change author-izations.
Requirements to accommodate revisions to the Gibbs & Hill 2323-El-XXXX and 2323-S-0900 drawings and voided, lost, or damaged hangers were also specified.
Brown & Root Procedure 35-1195-ECP-10 permitted cable tray hangers to be fabri-cated either in the field or in the shop.
Parts were welded in accordance with American Welding Society Code D1.1 (Reference 28) and Brown & Root welding Specification WES-029 as indicated by details on the design drawings and/or field sketches prepared by site engineering personnel.
Bolting and welding were also done in accordance with the applicable Gibbs & Hill design drawings, the American Institute of Steel Construction code (Reference 22), and other applicable Brown & Root procedures.
In addition, provisions for gaps between base plates and concrete were specified.
Cable trays were installed in accor-dance with the applicable Gibbs & Hill design drawings and Gibbs & Hill Speci-fication 2323-ES-100.
On the basis of its examination of the preceding description of the past pro-gram for the design, fabrication, erection, and inspection of the cable tray systems at CPSES, the staff identified the following underlying causes of the deficiencies found in these systems.
In general, the staff found that, from the viewpoint of the criteria of 10 CFR Part 50, Appendix B, there was an i
apparent breakdown in the implementation of the past quality assurance program 1
for the design of cable tray systems.
Breakdowns occurred primarily in the two areas of design control and document control as discussed below.
In the follow-ing sections, the deficiencies in the past program are discussed within the framework of the criteria of 10 CFR Part 50, Appendix B, to the extent that they are applicable to design.
InaJequate Desian Control The staff found that one of the primary underlying causes of many of the issues pertaining to the design of the cable tray systems at CPSES wa, the failure of the design process to implement the requirements of Criterion III, "Design Con-trol," of 10 CFR Part 50, Appendix B.
Criterion III of Appendix B to 10 CFR Part 50 requires that measures be estab-lished to ensure that applicable regulatory requirements and the design basis Comanche Peak SSER 15 5-2
for structures, systems, and components are correctly translated into specifi-cations, drawings, procedures, and instructions.
These measures must include provisions to ensure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
Criterion III also requires that measures be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures must include the establishment of procedures among design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.
Criterion III further requires that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of simplified calculational methods, or by the performance of a suitable testing program.
Design control measures must be applicable to items such as stress and the delineation of acceptance criteria for inspections and tests.
Finally, Criterion III requires that design changes, including field changes, be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.
In its review of the design progess for the cable tray systems at CPSES, the staff determined that the design responsibility was shared between Gibbs & Hill and Brown & Root.
Gibbs & Hill was responsible for the design of the layout of the systems and the standard hanger configurations, and Brown & Root was respon-sible for the design of individual hangers within the guidelines for the stan-dard hanger configurations provided by Gibbs & Hill.
This approach for the design of cable tray systems is not uncommon in the design of nuclear facili-ties but requires added measures to ensure adequate control of the design process.
In particular, the standard hanger configuration approach required that (1) detailed design procedures and criteria be established to Ensure that the standard hanger configurations were designed on a uniform basis and (2) structural elements of the standard hanger configuration be designed on a worst-case basis, including the effects of variations in loadings due to hanger loca-tion and alternate hanger detail configurations and tolerances permitted by the designs.
The design procedure is required to include adequate provisions to ensure that deviations from the standard hanger configurations are evaluated in a systematic manner.
In addition, in the sharing of the design responsibility between Gibbs & Hill and Brown & Root, measures are required to be established for adequate interaction between these organizations to ensure that (1) the configurations of hangen, installed by Brown & Root were in accordance with the Gibbs & Hill designs and (2) the effects of design changes, including field changes by Brown & Root, were adequately evaluated by Gibbs & Hill for its standard designs.
l A review of the issues in the CYGNA cable tray support review issues list l
(RIL) (Reference 17) which relate to deficiencies in the past design process for cable tray systems provides ample evidence that a breakdown in the design control required by 10 CFR Part 50, Appendix B, occurred.
(The issues in Comanche Peak SSER 15 5-3
Appendix A to this supplement are the same as those in the CYGNA RIL.)
In its review of these issues, the staff found that they could be characterized as l
deficiencies in the following four areas of design control.
The CYGNA RIL issues characterized as deficiencies are listed under each area.
(1) Establishment of Adequate Design Criteria No. 1, Controlling load case for design No. 3, Anchor bolt design No. 4, Design of compression members No. 5, Vertical and transverse loading on longitudinal type supports l
No. 6, Support frame dead and inertial loads No. 7, Design of angle braces neglecting loading eccentricity No. 8, Dynamic amplification factors, tributary tray support reactions, and missing mass effects No. 19, F5AR load combinations No. 21, Design control (2)
Implementation of Design No. 2, Seismic response combination method No. 3, Anchor bolt design No. 6, Support frame dead and inertial loads No. 9, Reduction in channel section properties due to clamp bolt holes No. 12, Working point deviation study No. 13, Reduced spectral accelerations No. 14, Nonconformance with American Institute of Steel Construction specifications No. 16, Weld design and specification No. 21, Design control No. 23, Loading in stress models No. 24, Design of flexural members No. 25, Cable tray qualifications No. 26, Base angle design No. 27, Support qualification by similarity No. 28, Critical support configurations and loadings a
No. 30, Cable tray damping values No. 31, Modeling of boundary conditions j
No. 32, Conduits attached to cable trays or supports i
(3)
Interaction Between Design Organizations No. 3, Anchor bolt design No. 15, Member substitution No. 16, Weld design and specifications No. 17, Embedded plate design No. 18, Cable tray clamps No. 20, Differnces between the installation and the design /
construction drawings without appropriate documentation No. 21, Design control No. 25, Cable tray qualification I
l Comanche Peak SSER 15 5-4 4
i- __.
(4) Evaluation of Design Changes No. 3, Anchor bolt design No. 12, Working point deviation study No. 21, Design control In its review of Gibbs & Hill Specification 2323-55-16B, "Structural Steel (Category I)," under which ser vices pertaining to the fabrication of the cable tray hangers by Brown & Root and the erection of the cable tray systems by Brown & Root were procured, the staff found that the specification was broad in scope and did not contain specific requirements relating to (1) the process to be used by Brown & Root in the selection of standardized hanger designs for specific locations and (2) adequate control of implementation of the process within the Brown & Root scope of work.
Failure of Gibbs & Hill Specification 2323-SS-16B to specify such requirements does not satisfy the requirements of Criterion III, "Design Control," of 10 CFR Part 50, Appendix B.
Inadequate Instructions, Procedures, and Drawings Critorion V of Appendix B to 10 CFR Part 50 requires that activities affecting q'.'slity be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and be accomplished in accordance with these instructions, procedures, or drawings.
Criterion V also requires 3
that instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
The staff found that Gibbs & Hill lacked specific procedures for performing design activities related to the cable tray systems.
Failure of Gibbs & Hill to establish such procedures is contrary to the requirements of Criterion V, "Instructions, Procedures, and Drawings," of 10 CFR Part 50, Appendix B.
Inadequate Control of Documents Criterion VI of Appendix B to 10 CFR Part 50 requires that measures be estab-lished to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affect-ing quality.
These measures are required to ensure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel, i
The staff found that CYGNA RIL Issue No. 21, Design control:
Subissues A, Tracking and consideration of design changes; F, Lack of calculations for change notices; and G, Design calculation retrievability and completeness, identified deficiencies in the Gibbs & Hill cable tray systems design process related to document control.
These deficiencies are contrary to the require-ments of Criterion VI, "Document Control," of 10 CFR Part 50, Appendix 8.
In addition, Gibbs & Hill Specification 2323-SS-16B required that Brown & Root prepare detailed shop drawings in accordance with American Institute of Steel Construction specifications for items covered by the specification and that the drawings be submitted to Gibbs & Hill for approval.
In addition, fabrication was not to proceed until the engineer had approved the applicable shop drawings.
Comanche Peak SSER 15 5-5
1 The staff found that the Brown & Root 2323-000159 fabrication / detail drawings for individual supports developed by Brown & Root for specific cable tray harg-i ers were submitted to responsible Brown & Root site engineering personnel only.
These drawings were not submitted to Gibbs & Hill for approval.
This lack of approval by the organization responsible for the standard hanger designs of the fabrication drawings was contrary to usual industry practice and to the require-ments of Section 5.0 of Gibbs & Hill Specification 2323-55-16B.
Failure to com-ply with this requirement of the Gibbs & Hill specification indicates an ineffec-tive implementation of the requirements of Criterion VI, "Document Control," of 10 CFP. Part 50, Appendix B.
Preventive Actions In the preceding discussion on the underlying causes of the cable tray issues, it appears that the process used by Gibbs & Hill for controlling design, design changes, and document changes for cable tray hangers contributed to the major issues identified by the external sources, it follows that a complete as-built walkdown of cable trays and cable tray hangers that documents the installed condition of these components would be a prerequisite for the corrective actions required to validate the cable tray and cable tray hanger designs.
The as-built walkdowns performed by Ebasco before its design validation established the as-built design documentation for the CPSES cable trays and cable tray hangers.
In addition, the walkdowns provided the Ebasco engineers the opportunity to cb-tain a firsthand understanding of the cable tray issues and to identify any other undetected issues arising from the previous construction and as-built practices that might affect the cable tray hanger design validation activities.
t The development of the design validation criteria and analysis procedures by Ebasco and Impell was based on thn knowledge thus gained of the installed con-dition of the cable trays and cable tray hangers.
Extensive testing and special analysis were performed by Ebasco and Impell to establish the accept-ability and appropriateness of the design criteria used in the cable tray l
system design validation.
These requirements are incorporated in the design l
validation procedures for cable trays and cable tray hangers.
Design valida-tion procedures include the methodology for control and implementation of cable tray and cable tray hanger design modifications to ensure that the vali-dated designs reflect new or modified configurations.
TV Electric Procedure ECE 5.09-01, "Design Verification and Interdisciplinary Review of Design Change Authorizations and Non-Conformance Reports," Revision 1, September 14, 1987, requires an interdisciplinary review of design changes.
The requirements of ECE 5.09-01 nave been incorporated into the Impell and Ebasco procedures that control the issuance of cable tray and cable tray hanger design change authori-zations.
These requirements provide assurance that interdisciplinary reviews are performed when required and that changes to documents are controlled.
The CPSES cable trays and cable tray hangers have ban design validated using the as-built documentation and the design criteria developed and verified by Ebasco and Impell.
The complete reanalysis of the CPSES cable tray hanger as-built designs using well-founded design criteria provides an effective means to resolve the cable tray hanger technical issues and ensures a consistent and well-controlled approach for the validation of the cable trays and cable tray hangers installed at CPSES.
i Comanche Peak SSER 15 5-6
On the basis of its review of the corrective actions and preventive actions associated with the CAP, the staff finds that the extent of the design valida-tion perforraed by Ebasco and Impell and the degree to which the technical issues have been addressed provide sit *'icient confidence that all deficiencies in cable trays and cable tray hangers *!sulting from the inefficacies of the Gibbs & Hill design control and document control process have been identified and corrected in the implementation of the CAP design validation activities.
Consequently, the staff finds that the de=igns of cable trays and cable tray hangers have been adequately verified using validated documents and controlled procedures under the CAP, thus correcting the deficiencies that might have occurred as a result of such failures and satisfying the applicable portions of 10 CFR Part 50, Appendix B, Criteria III, V, and VI, related to (1) design control; (2) instructions, procedures, and drawings; and (3) document control, respectively.
On the basis of its review of the root causes of the cable tray hanger tech-i nical issues and the corrective actions taken by the applicant, the staff concludes that the TU Electric CAP for cable trays and cable tray hangers i
adequately corrects the underlying causes of the past problems with design control and document control to prevent their recurrence and, thus, satisfies the applicable portion of 10 CFR Part 50, Appendix B, Criterion XVI, related to corrective action.
I
)
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Comanche Peak SSER 15 5-7
t j
6 CONCLUSIONS On the basis of its review of the Comanche Peak Response Team (CPRT) Program Plan (Revision 4) and the TV Electric Corrective Action Program as discussed in Section 4 of this supplement, the staff concludes that for the design valida-l tion of cable trays and cable tray hangers at CPSES Units 1 and 2, the speci-fied design is acceptable and meets the applicable requirements of General Design Criteria 1, 2, and 4 of 10 CFR Part 50, Appendix A.
This conclusion is based on the following:
The criteria used in the analysis, design, and construction of all the plant Category I cable trays and cable tray hangers to account for antic-ipated loadings and postulated conditions that may be imposed on the cable trays and cable tray hangers during their service lifetimes conform with established criteria, codes, standards, and specifications acceptable to the NRC staff.
The use of these criteria as defined by applicable codes, standards, and specifications; the loads and loading combinations; the design and analy-sis procedures; the structural acceptance criteria; the special studies; the testing programs; and the hardware reinspection requirements provide reasonable assurance that, in the event of earthquakes and various postu-lated accidents affecting the cable trays and cable tray hangers, these components will withstand the specified design conditions without impair-ment of structural integrity or the performance of required safety
)
functions.
i The staff further concludes that for the resolution of identified and potential design deficiencies in the cable trays and cable tray hangers at CPSES Units 1 and 2, the TV Electric Corrective Action Program for cable trays and cable tray hangers and the CPRT Program Plan (Revision 4) collectively establish effective means for identifying all design deficiencies, provide comprehensive corrective actions for their resolution, and ensure proper implementation of the correc-tive actions.
These conclusions are based on the following:
The cable tray and cable tray hanger design validation activities per-formed for the applicant by Ebasco and Impell and the CPRT third party review provide a comprehens;ve program for identifying and resolving the i
technical concerns raised by the intervenor, CYGNA Energy Services, the l
NRC staff, and other external sources that are related to the design I
adequacy of cable trays and cable t 7y hangerr, at CPSES.
The staff con-cludes that the overall program reasonably ensures that all deficiencies in the design of cable trays and cable tray hangers are identified and corrected.
The staff further concludes that the effectiveness of the implementation of the program ensures that those issues will be acceptably resolved on completion of the program.
(See Sections 4.1.1 and 4.1.2 and Appendix A to this supplement.)
Comanche Peak SSER 15 6-1
The applicant's cable tray and cable tray hanger hardware validation acciv-ities provide assurance that construction deviations in the associated hardware are corrected and, thus, will not adversely affect the ability of cable trays and cable tray hangers to perform their functions.
(See Sec-tions 4.1.1.1 and 4.1.2 of this supplement.)
The scope and depth of the independent review by CYGNA Energy Services provide additional assurance of the satisfactory resolution of deficien-cies in the design of cable trays and cable tray hangers at CPSES.
Addi-tionally, satisfactory findings by the third party (TENERA) in its review of the cable tray and cable tray hanger design criteria provide assurance that the design of the cable trays and cable tray hangers satisfies licensing commitments and applicable code requirements.
(See Sections 4.2.1 and 4.2.2 of this supplement.)
The TV Electric Technical Audit Program provides assurance that the execu-tion of the design validation by Ebasco and Impell is. technically adequate and that the implementation of the resolution of the cable tray and cable tray hanger external-source issues is appropriate and complete.
(See Section 4.2.2 of this supplement.)
On the basis of its review of the design and interface controls associated with the TU Electric Corrective Action Program (as discussed in Section 5 of this supplement), the staff concludes that the corrective actions are acceptable and and(XVI. sat sfy the applicable requirements of 10 CFR Part 50, Appendix B, Criteria III This conclusion is based on the following:
The applicant has satisfied the requirements of 10 CFR Part 50, Appendix B, Criterion III, with respect to establishing measures to ensure that the applicable regulatory requirements and the design basis are correctly l
translated into specifications, design drawings, and procedures by estab-t lishing design-basis documents and implementing a complete design valida-tion for cable trays and cable tray hangers important to safety.
The design validation provides proper control of the design interaction between the cable tray and cable tray hanger groups and provides an ade-quate review of installed field designs and design changes.
(See Sections 4.1, 4.1.1, and 5 of this supplement.)
The applicant has satisfied the requirements of 10 CFR Part 50, Appendix B, Critarion XVI, by establishing a program to correct design deficiencies and to preclude repetition of the underlying causes of the problems asso-ciated with the design of cable trays ard cable tray hangers at CPSES, (See Section 5 of this supplement.)
l l
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l Comanche Peak SSER 15 6-2 i
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,c i
- 7 REFERENCF,5 l
1.
CYGNA Energy Services, "Independent Assessment Program for_ Comanche Peak Steam Electric Station, Final Report," TR-83090-01 (Draft), Volumes 1 and 2, r
Docket Nos. 50-445/446, November 5, 1983.
2.
U.S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board Memorandum and Order ("Quality Assurance for Design"), December 28, 1983, LBP-83-81, 18 NRC 1410 (1983).
3.
CYGNA Energy Services, Errata and revised pages-to "Independent Assess-ment Program for Comanche Peak Steam Electric Station, Final Report,"
TR-83090-01, Docket Nos. 50-445/446, October 12, 1984.
4.
Letter from N. H. Williams (CYGNA) to V. Noonan (NRC),
Subject:
Status of IAP Conclusions, Docket Nos. 50-445/446, January 25, 1985.
5.
Letter from N. H. Williams (CYGNA) to J. Beck (TUGCO),
Subject:
Review Issues List - Independent Assessment Program All Phases, Docket Nos.
50-445/446, April 4, 1985.
6.
U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the Operation of Comanche ?eak Steam Electric Station, Units 1 end 2" (SER), NUREG-0797, July 1981, and Supplements 1 through 4 and 6 through 14.
5 7.
Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
CPSES Corrective Action Program, Docket Nos. 50-445/446, January 29, 1987.
8.
Letter from W. G. Counsil (TU Electric) to NRC,
Subject:
Response to Additional Information in Conjunction With Program Plan Update, Docket Nos. 50-445/446, June 25, 1987.
9.
Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
Comanche Peak Programs, Docket Nos. 50-445/446, August 20, 1987.
l 10.
Letter trom W. G. f,ounsil (TU Electric) to NRC,
Subject:
Corrective Action Program Description and Flow Diagrams, Docket Nos. 50-445/446, August 28, 1987, 11.
Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
Post-Construction Hardware Validation Program Engineering Evaluation Method-4 ology, Docket Nos. 50-445/446, September 8, 1987.
12.
Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
Post-4 Construction Hardware Validation Program Attribute Matrix, Docket Nos.
j 50-445/446, September 23, 1987.
i Comanche Peak SSER 15 7-1 1
l
l 13.
Comanche Peak Response Team, "Comanche Peak Response Team Program Plan and Issue-Specific Action Plans," Revision 4, June 18, 1987, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to NRC dated June 25, 1987.
14.
Letter from S. D. Ebneter (NRC) to W. G. Counsil (TV Electric),
Subject:
CPSES Licensing and Corrective Action Programs, Docket Nos. 50-445/440, January 22, 1988.
15.
TV Electric, "CPSES Design Basis Consolidation Program Plan," Docket Nos. 50-445/446, December 19, 1986, transmitted in a letter from W. G.
Counsil (TV Electric) to NRC dated December 22, 1986.
16.
U.S. Nuclear Regulatory Commission, Inspection Report 50-445/86-19; 50-446/86-16, November 4, 1986.
17.
Letter from N. H. Williams (CYGNA) to W. G. Counsil (TV Electric), Sub-ject:
Cable Tray Support Review Issues List - Revision 15, Docket Nos.
50-445/446, July 9, 1988.
18.
TV Electric, "CPSES Unit 1 and Common Corrective Action Program - Project Status Report - Cable Trays and l'able Tray Hangers," Revision 0, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to NRC dated November 6, 1987.
19.
TV Electric, "Comanche Peak Steam Electric Station - Final Safety Analysis Report," Docket Nos. 50-445/446, up to and including Amendment 71.
20.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.29, "Seismic Design Classification.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.92, "Combinin 21.
ModalResponsesandSpatialComponentsinSeismicResponseAnalysis.g' 22.
AISC, Manual of Steel Construction, Seventh Edition, American Institute of SteeTConstruction,1970."
i 23.
AISI, "Specification for the Design of Cold-Formed Steel Structural Members," American Iron and Steel Institute, 1980.*
i 24.
U.S. Nuclear Regulatory Commission, Inspection Report 50-445/85-17; I
50-446/85-14, January 21, 1986.
)
)
25.
Comanche Peak Response Team, "Discipline Specific Results Report:
Civil /
Structural - Cable Trays and Supports," DAP-RR-C/S-001, Revision 1, Docket Nos. 50-445/446, September 25, 1987, transmitted in a letter from W. G.
Counsil (TV Electric) to NRC dated December 7, 1987.
- Available through public technical libraries and at the NRC Library, 7920 j
Norfolk Avenue, Bethesda, Maryland.
4 i
Comanche Peak SSER 15 7-2 i
26.
Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
Technical Audit Program and Engineering Functional Evaluation, Docket Nos. 50-445/446, September 8, 1987.
27.
Comanche Peak Response Team, "Comanche Peak Response Team Program Plan and Issue-Specific Action Plans," Revision 3, January 25, 1986, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TUGCO) to V. Noonan (NRC) dated Janaury 27, 1986.
28.
AWS 01.1-77, "Structural Welding Code - Steel," American Welding Society.*
i i
- Available through public technical libraries and at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland.
Comanche Peak SSER 15 7-3
APPENDIX A RESOLUTION OF CABLE TRAY HANGER TECHNICAL ISSUES l
The cable tray hanger technical issues
- consist of those issues raised by ex-l ternal sources, primarily the intervenor Citizens Association for Sound Energy (CASE), CYGNA Energy Services (CYGNA), and the NRC staff, that could affect more than one specific cable tray hanger calculation.
The Comanche Peak Response Team (CPRT) third party organization (TENERA, L.P.) was responsible for identifying, reviewing, and tracking the resolutions of the issues raised by external sources as part of the CPRT Program Plan's Design Adequacy Program (DAP).
The development of the technical resolutions of these issues was the responsibility of Ebasco Services Corporation (Ebasco) and Impell Corporation (Impell) as part of the TV Electric Corrective Action Program (CAP) for vali-dating the design of cable treys and cable tray hangers.
The methodologies to be used for resolving the technical issues regarding cable tray hangers were initially discussed in a Texas Utilities Electric Company (TV Electric) report entitled "Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers," dated March 13, 1987 (Reference A1) and subsequently have been docu-mented in Appendix A to the "Project Status Report for Cable Tray and Cable Tray Hangers" (Reference A2) (hereinafter referred to as the "cable tray hanger project status report").
The method for implementir.g the technical resolutions was incorporated into the Ebasco and Impell design validation procedures iden-tified herein.
The CPRT third party (TENERA) evaluations of the methodologies adopted by Ebasco and Impell to resolve issues are summarized in the CPRT "Discipline Specific Results Report: Civil / Structural - Cable Trays and Supports,"
DAP-RR-C/S-001, Revision 1, dated September 25, 1987 (hereinafter referred to as the "cable tray hanger results report") (Reference A3).
The CPRT evalua-tions are documented in supporting engineering evaluations and checklists identified herein.
i The staff's review of the technical issues regarding cable tray hangers and their resolution consisted of a review of Appendix A to the cable tray hanger project status report, a selective review of portions of the Ebasco and Impell i
desig,a validation procedures and special studies, a review of the CPRT cable tray hanger results report, and a selective review of the DAP engineering eval-uations and checklists.
In addition, the staff conducted several audits and inspections at the Ebasco, Impell, and TENERA offices (Appendix 0 to this supplement).
In this appendix the staff has evaluated each issue raised by j
external sources with respect to the Ebasco and Impall resolutions of the issue and the applicable CPRT third party review and evaluation of the issue.
In addition, the status of the CYGNA review of each issue is provided herein.
l
- In the staff's terminology, a cable tray hanger technical issue (e.g., design of compression members) may consist of several subissues (e.g., slenderness ratio, sidesway restraint).
l Comanche Peak SSER 15 1
Appendix A i
i r
This appendix addresses approximately 200 discrepancy / issue resolution reports (DIRs) generated by the CPRT in its review of 364 various source documents, which are related to cable tray and cable tray hanger issues raised by external
. sources.
The 32 cable tray hanger technical issues evaluated in this appendix and all subissues addressed under each technical issue are:
1 CONTROLLING LOAD CASE FOR DESIGN.
1.1 Operating-Basis Earthquake (0BE) and Safe-Shutdown Earthquake (SSE)
Load Cases 2
SEISMIC RESPONSE COMBINATION METHOD 2.1 Closely Spaced Modes 2.2 Seismic and Dead Load Combination 3
ANCHOR BOLT DESIGN 3.1 Eccentricity of Frame Connection Point 3.2 SSE Hilti Safety Factors 3.3 Inconsistent Application of American Concrete Institute Specifica-tion 349-76 (ACI-349-76) 3.4 Richmond Insert Factor of Safety 1
- 3. 5 Richmond Insert Design 3.6 Connection Designs 3.7 Prying Factor Justification 1
3.8 Anchor Bolt Substitution 3.9 Base Angle Boundary Condition Assumption 3.10 Installation of Expansion Anchors in Diamond-cored Holes 3.11 Reduced Allowable Values for 1-Inch Hilti Kwik-Bolts 4
DESIGN OF COMPRESSION MEMBERS 4.1 Slenderness Ratio 4.2 Sidesway Restraint 4.3 Cantilever Length 4.4 Weld Undercut 4.5 Out-of-Plumbness 4.6 Hanger Post Effective Length i
4.7 Brace Slope 5
VERTICAL AND TRANSVERSE LOADING ON LONGITUDINAL TYPE SUPPORTS 5.1 Vertical and Transverse Loading Considerations 6
SUPPORT FRAME DEAD AND INERTIAL LOADS 6.1 Out-of-Plane Inertial Loads l
6.2 Dead Loads Comanche Peak SSER 15 2
Appendix A
7 DESIGNOFANGLEBRACESNEGLECTINGLdADINGECCENTRICITY 7.1 Longitudinal Braces 7.2 In-Plane Braces l
7.3 Twist Buckling 8
DYNAMIC AMPLICATION FACTORS (DAFS) AND RATIOS BETWEEN CONTINUOUS TRAY SUPPORT REACTIONS AND TRIBUTARY TRAY SUPPORT REACTIONS 8.1 Multimode Response Multiplier 9
REDUCTION OF CHANNEL SECTION PROPERTIES DUE TO CLAMP BOLT HOLES 9.1 Design Considerations for Clamp Bolt Holes in Channels 10 SYSTEM CONCEPT 10.1 Load Eccentricity on Support 20.2 Lateral Bracing of Cantilevers 10.3 Transverse and Vertical Loads on Longitudinal Supports 10.4 Prying Action 10.5 Self-Weight Seismic Loading 10.6 Eccentricities of Tier / Post Lap Joint 11 VALIDITY OF NASTRAN MODELS 11.1 Use of NASTRAN in Previous Generic Studies 12 WORKING POINT DEVIATION STUDY 12.1 Consideration of Working Point Deviation Study 13 REDUCED SPECTRAL ACCELERATIONS 13.1 Tray Design Considerations and Base Angle Flexibilities 14 NON-CONFORMANCE WIT 9 AISC SPECIFICATIONS 14.1 Slenderness Ratio 14.2 Unbraced Length 14.3 Section Property Reduction Due to Bolt Holes 14.4 Composite Compression Members Without Lacing 14.5 Connection Eccentricities 14.6 Oversized Bolt Holes 14.7 Bracing Members 15 MEMBER SUBSTITUTION 15.1 Member Design Considerations Comanche Peak SSER 15 3
Appendix A 1
16 WELD DESIGN AND-SPECIFICATIONS 4
16.1 Weld Details, Weld Sizes, and Minimum Weld Length 16.2 Eccentric Connections 16.3 Base Metal Thickness 17 EMBEDDEO PLATE DESIGN 17.1 Design Considerations for Embedded Plates-18 CABLE TRAY CLAMPS 18.1 Design Considerations for Cable Tray Clamps 19 FINAL SAFETY ANALYSIS REPORT (FSAR) LOAD COMBINATION 19.1 Loss-of-Coolant Accident (LOCA) Design Loadings 20 OIFFERENCES BETWEEN THE INSTALLATION AND THE DESIGN / CONSTRUCTION DRAWINGS WITHOUT APPROPRIATE DOCUMENTATION 20.1 Consideration of As-Built Differences 21 DESIGN CONTROL 21.1 Design Changes and As-Built Conditions 21.2 Evaluations of Supports With Thermo-Lag 21.3 Design Control and Quality Assurance Procedures 21.4 Design Criteria Consistency With FSAR 22 DESIGN OF SUPPORTS EMBEDDED IN NON-SEISMIC CATEGORY I WALLS l
t 22.1 Design Considerations for Supports in Seismic Category II Structures i..
23 LOADING IN STRESS MODELS 4
i 23.1 Tray Load Application Points 23.2 Tributary Load Calculations 23.3 Modeling of Support Frame Height 24 DESIGN OF FLEXURAL MEMBERS 1
24.1 Major Axis Bending Due to Vertical Eccentricity 24.2 Minor Axis Bending Due to Horizontal Eccentricity 24.3 Torsion of Tier Members 24.4 Bolt Holes and Weld Undercut l
24.5 Unsupported Length of Compression Flange I
25 CABlf TRAY QUALIFICATION s
a 25.1 Dynamic Amplification Factor 25.2 Cable Tray Capacity 25.3 Cable Tray Modification 25.4 Cable Tray Moment.of Inertia i
Comanche Peak SSER 15 4
Appendix A
~
'i 1
-26 BASE ANGLE DESIGN l
26.1 Stiffening Effects of Concrete 26.2 Principal Axis Properties 26.3 ' Richmond Insert Spacing
]
26.4 Base Angle Design Adequacy 4
27 SUPPORT QUALIFICATION BY SIMILARI1Y.
27.1 Considerations for.Similar Design
-t 28 CRITICAL SUPPORT CONFIGURATIONS AND LOADINGS
'28.1 Consideration of Critical Support Configurations and Loadings 29 CUMULATIVE EFFECT OF REVIEW ISSUES 29,1 Consideration of Cumulative Effects 30 CABLE TRAY SYSTEM DAMPING VALUES l
30.1 Consideration of Damping Values 31 MODELING 0F BOUNDARY CONDITIONS i
31.1 Design Considerations for Anchorage Modeling I
32 CONDUITS ATTACHED TO CABLE TRAYS OR SUPPORTS 32.1 Design Validation of Conduits Attached to Cable Trays / Supports I
i i
i i
i i
1 i
i l.
i
}
l Comanche Peak SSER 15 5
Appendix A
i
+
1 l
1 CONTROLLING LOAD CASE FOR DESIGN i
4 i
In the initial design of Como,ehe Peak Steam Electric Station (CPSES) calle tray suppcrts, the operating-basis earthquake (0BE) was assumed by Gibbs & Hill to be the governing seismic load ca3e for all support components (e.g., mem-bers, welds, and anchorages).
This assumption was based on a comparison of the 60 percent increase in OBE allowable stress as specified in the final safety analysis report (FSAR) for the safe shutdown earthquake (SSE) design of struc-tural steel components and the ratio of SSE load to 0BE load (which is, in t
general, less than 1.60).
Concerns were raised regarding the use of the OBE as the governing load case, since the 60 percent increase in allowable stress was found to be inappropriate for certain support components (e.g., Richmond inserts and Hilti expansion anchors).
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified five related issues from various source documents.
TENERA combined these related issues into one primary issue concerning the assumption of a controlling load case for design.
The relevant project documents and the corresponding CPRT third party review documents for this issue fol'ow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/5-204 DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/S-204 j
DAP-E-C/S-120 SAG.CP34 DAP-CLC-C/S-204
)
i (Impe11)
PI-02 DAP-CLC-C/S-404 l
PI-07 DAP-CLC-C/S-404 DAP-E-C/5-120 1
1.1 Operating-Basis Earthquake (0BE) and Safe-Shutdown Earthquake (SSE) j Loaa Cases J
This issue is described in Section 3.2.7.1 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions at : presented in Subappendix Al of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.1 of the cable tray hanger results report, i
- All relevant project and CPRT third party documents are listed in Appendix E i
to this supplement.
I Comanche Peak SSER 15 6
Appendix A
The concern, identified by CYGNA in its Independent Assessment Program (IAP),
was that Gibbs & Hill analyzed cable tray hangers for the OBE and not for the SSE assuming that the OBE was the controlling load case for design for all cable tray support components.
CYGNA found this assumption inappropriate for certain components such as Richmond inserts and Hilti expansion anchors where the allowable loads do not increase for the SSE load case.
Ebasco and Impe11 resolved this issue by evaluating all cable tray support components for both OBE and SSE load cases using appropriate allowable values and factors of safety for each load case in accordance with design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, PI-02, and PI-07).
The factors of safety used for the Hilti concrete anchor bolts and Richmond inserts are dis-cussed in Sections 3.4 and 3.5, respectively, of this appendix.
TENERA, as the third party reviewer, confirmed that the Ebasco and Impell design procedures require that all cable tray hanger components be evaluated for both OBE and SSE load cases.
The staff concludes that the inclusion of both OBE and SSE load cases in the Ebasco and Impe11 design validation procedures pievides an adequate basis to resolve this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 1).
- 1. 2 Conclusions On the basis ci the above evaluation, the staff concludes that the concerns associated with the evaluations for both OBE and SSE load cases have been adequatsiy resolved.
The cable tray hanger technical issue concerning the controlling load case for design is, therefore, closed for CPSES.
Comanche Peak SSER 15 7
Appendix A
2 SEISMIC RESPONSE COMBINATION METHOD Several concerns were raised regarding the methods used by Gibbs & Hill for combining seismic responses in the initial design calculations of the CPSES cable trays and supports.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (OAP), identified six related issues from various source documents which were grouped into (1) closely spaced modes and (2) seismic and dead load combination.
The relevant project docuinents and the corresponding CPRT third party review documents for this issue. follow.
Project Document
- CPRT Review Document *
(Ebasco)
)
2 SAG.CP3 DAP-CLC-C/S-204 OAP-E-C/S-120 SAG.CP4 OAP-CLC-C/S-204 l
OAP-E-C/S-120 SAG.CP11 DAP-E-C/S-169 SAG.CP34 DAP-CLC-C/S-204 i
(Impell)
PI-02 DAP-CLC-C/5-404 l
2.1 Closely Spaced Modes This issue is described in Section 3.2.7.2 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies are presented in Sub-appendix A2 of the cable tray hanger project status report.
The CPRT third-party evaluation is summarized in Section 3.2.7.2 of the cable tray hanger 4
results report.
In response spectrum modal analysis, two consecutive modes are defined as i
i closely spaced if their frequencies differ from each other by 10 percent or i
less of the lower frequency.
The concern identified by CYGNA in its IAP regard-ing closely spaced modes was that Gibbs & Hill in performing response spectrum analyses for its "Working Point Deviation Study"** did not combine responses due to closely spaced modes in accordance with the guidelines specified in NRC l
Regulatory Guide (RG) 1.92, "Cembining Modal Responses and Spatial Components in Seismic Response Analysis" (Reference A5).
I i
t
- All relevart project and CPRT third party documents are listed in Appendix E to this supple:nent.
- The "Working Point Deviation Study" is a document developed by Gibbs & Hill
}
to justify to CYGNA the adequacy of the approach Gibbs & Hill used for i
designing cable tray hangers.
I j
Comanche Peak SSER 15 8
Appendix A f
Ebasco and Impell resolved this issue by not relying on the Gibbs & Hfli study and by requiring that for all response spectrum analyses used to validate the l
design of cable tray system components, closely spaced modes be combined in accordance with NRC RG 1.92.
The design validation criteria are specified in l
Ebasco and Impell procedures SAG.CP3, SAG.CP4, SAG.CP11, and PI-02.
TENERA as
(
the third party reviewer confirmed that the Ebasco and Impell design validation procedures require that closely spaced modes be combined in accordance with l
Because the Ebasco and Impell procedures incorporate the guidelines of NRC RG 1.92 for combining closely spaced modes, the staff concludes that the concerns identified in this issue have been adequately resolved, and the resolution is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers ( h ference A4, Issue No. 2A).
2.2 Seismic and Dead Load Combination This issue is described in Section 3.2.7.2 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A2 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.2 of the cable tray hanger results report.
The concern identified by CYGNA in its IAP was that Gibbs & Hill in the initial design calculations added the deadweight acceleration to the vertical seismic acceleration, and then combined this sum with the two horizontal seismic l
accelerations using the square-root-of-the-sum-of-the-squares (SRSS) method.
This approach was not consistent with the CPSES FSAR commitment.
Ebasco and Impell resolved this issue by requiring through design validation that the deadweight load be added separately to the SRSS resultant. of the three t
orthogonal seismic loads.
The design validation criteria are specified in Ebasco and Impell procedures SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34, and PI-02.
TENERA, as the third party reviewer, confirmed that the Ebasco and Impell design validation procedures require that dead load response be added alge-braically to the SRSS resultant of the three orthogonal seismic components.
The staff concludes that the inclusion of a combination method using an alge-braic summation of the deadweight load with the rewltant seismic load in the 1
Ebasco and Impell design validation procedures provides an adequate basis to resolve the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 28),
2.3 Conclusions In response to the above evaluations, the staff concludes that the concerns associated with the methods used for combining seismic system responses in Comanche Peak SSER 15 9
Appendix A
cable tray hanger design nave been adequately resolved.
The cable tray hanger technical issuc concerning seismic response combination method is, therefore, closed for CPSES.
I i
Comanche Peak SSER 15 10 Appendix A
3 ANCHOR BOLT DESIGN Gibbs & Hill Specification No. 2323-SS-30 was used in the initial design of cable tray support anchorages.
Concerns were raised about this document as well as about othei assumptions and criteria used in the initial design of cable tray support anchorages.
The CPRT third party (TENERA, L.P.), in con-junction with the Design Adequacy Program (DAP), identified 28 related issues from various scurce documents which were grouped into tie 11 issues that follow.
(1) eccentricity of frame connection point (2) SSE Hilti safety factors (3) inconsistent application of ACI-349-76 (4) Richmond insert factor of safety (5) Richmond insert design (6) connection designs (7) prying factor justification (8) anchor bolt substitution (9) base angle boundary condition assumption (10) installation of expansion anchors in diamond-cored holes (11) reduced allowables for 1-inch Hilti Kwik-Bolts The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document
- r (Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/5-120 SAG.CP4 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP34 DAP-CLC-C/S-204 DAP-E-C/S-139 Vol. I, Book 3 DAP-E-C/S-137 Vol. I, Book 12 DAP-E-C/S-139 (Impell) l PI-02 DAP-CLC-C/S-404 PI-07 OAP-CLC-C/S-404 DAP-E-C/5-120 All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 11 Appendix A
\\
t f
i;
.Pr.oject Document
- CPRT Review Document" l
PI-11 DAP E-C/5-170 M-04 DV-E-C/5-139 M-25 DAP-E-C/S-107 M-68 DAP-E-C/S-120 l
3.1 Eccentricity of Frame Connection Point i
This issue is described in Section 3.2.7.3 of the cable tray hanger results
[
report.
The Ebasco and Impell resolution methodologies and corrective actions l
are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
l 1
The concern identified by CYGNA in its IAP was that Gibbs & Hill in the initial design calculations for cable tray hanger anchor bolts did not address the eccentricity between the frame connection point to the base angle and the centroid of the anchor bolt pattern.
l l
Ebasco and Impell resolved this issue by requiring that the eccentricity be-tween the frame connection point to the base angle and the centroid of the bolt l
pattern be evaluated in the design validation of cable tray hanger anchorages and anchor bolts based on as-bLilt configurations.
The design validation I
criteria are specifted in Ebasco and Impell procedures SAG.CP3, SAG.CP4, i
SAG.CP34, PI-02, and PI-07.
Tne CPRT third party reviewer confirmed that j
Ebasco and Impell procedures appropriately consider these eccentricities in the
[
j design validation of anchorages and anchor bolts.
i The staff concludes that the inclusion of detailed modeling techniques to i
account for eccentricities in the frame connection point in the Ebasco and i
Impell procedures provides an adequate basis to resolve the concerns identi-l fied in this issue, and is, thus, acceptable.
l 1
i CYGNA's review cf the resolution of this issue closed the issue in Revision 15 i
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 3A).
l
(
i 3.2 SSE Hilti Safety Factors 1
This issue is described in Section 3.1.7.3 of the cable tray hanger results report.
The Ebasco and Impe11 resohition methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRf third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
As identified by CYGNA in its IAP. Gibbs & Hill used a safety factor of four for Hilti expansion anchors for OBE loadings which was considered to be the i
i
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 12 Appendix A.
controlling load case for desi p (see Section 1.1 of this appendix).
This resulted in a reduced factor of safety for SSE loadings.
Ebasco and Impell resolved this issue by requiring that each support be evaluated for OBE and SSE using a factor of safety of five for OBE loads and four for SSE load in the design validation of Hilti anchor bolts.
A safety factor of four is consistent with the guidelines provided by the manufacturer and is, thus, acceptable.
TENERA, as the third party reviewer, confirmed that the Hilti safety factors are appropriately specified in the Ebasco and Impell design validation procedures (SAG.CP3, SAG.CP4, and PI-07).
The staff concludes that the inclusion of appropriate safety factors for both the OBE and SSE loadings in the Ebasco and Impell procedures provides an adequate basis to resolve the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 38).
3.3 Inconsistent Application of American Concrete Institute Specification 349-76 (ACI-349-76)
This issue is described in Section 3.2.7.3 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are precented in Sabappendix A3 of the cable tray project status report. The third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
The concern identified by CYGNA in its IAP was that although Gibbs & Hill used the criteria of ACI-349-76 (Reference A6) for qualifying some anchorage designs, it violated these criteria in other cases.
Ebasco and Impell found that ACI-349-76 is not a CPSES FSAR coranitment for the design of concrete anchor bolts, and is not used for validating the design of anchorages.
TENERA confirmed that it is not necessary to use ACI-349-76 because this document is i
not a CPSES licensing commitment.
The staff concurs that ACI-349-76 is not the CPSES code of record and concludes that this issue is closed.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
No. 3C).
3.4 Richmond Insert Factor of Safety This issue is described in Section 3.2.7.3 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
Comanche Peak SSER 15 13 Appendix A
~.
i
[
i As identified by CYGNA in its IAP, Gibbs & Hill used t safety factor of three for Richmond inserts for OBE loadings, which was considered to be the control-i ling load case for design (see $6ction 1.1 of this appendix).
This results in
.a reduced factor of safety for SSE loadings.
Ebasco and Impell resolved this issue by requiring that each support be evaluated for both OBE and SSE using a factor of safety of three for OBE and SSE loads in the design validation of j
1 Richmond inserts.
A safety factor of three is recommended by the vendor,
)
Richmond Screw Company, and is, thus, acceptable.
i TENERA confirmed that the Richmond insert safety factors are appropriately I
specified in the Ebasco and Impe11 design validation procedures (SAG.CP3, j
SAG.CP4, and PI-07).
i The staff concludes that the inclusion of appropriate. Richmond insert safety i
factors for both OBE and SSE load cases in the Ebasco and Impe11 procedures provides an adequate basis to resolve the concerns identified in this issue, i
and is, thus, acceptable, s
CYGNA's review of the resolution of this issue closed the issue in Revision 15 1
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue j
l No. 3D).
l
(
i 3.5 Richmond Insert Desian l
\\
F This issue is described in Section 3.2.7.3 of the e M e tray hanger results I
report.
The Ebasco and Impell resolution methodoiogies and corrective actions
]
are presented in Subappendix A3 of the cable tray hanger project status report.
I The CPRT third-party evaluation is summarized in Section 3.2.7.3 of the cable i
]
tray hanger results report, i
In its IAP, CYGNA identified concerns regarding the initte,1 design of Richmond inserts in anchorage connections for cable tray supporn.
CYGNA noted that (1) prying action was not considered, (2) the onsite testing program provided higher allowable values than the original design criteria to qualify some con-nections that use Richmond inserts, and (3) reductions in allowable values were not applied as required by design criteria for cluster arrangement, embedment i
in sides of concrete beams, and less than required center-to-center spacing.
l 1
l The concern dealing with prying action is discussed in Section 3.7 of this appendix.
The resolution of the concerns regarding onsite testing and reduction in allowable values because of clustering, sides of beams, and spacing will be 4
i addressed under the civil / structural Corrective Action Program.
i l
3.6 Connection Desians 1
j This issue is described in Section 3.2.7.3 of the cable tray hanger results i
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7,3 of the cable
)
tray hanger results report, l
l Comanche Peak SSER 15 14 Appendix A
,m-
)
i i
i i
The concern identified by CYGNA in its IAP regarding connection designs was that the Gibbs & Hill design calculations did not consider installation tol-I erances for anchor bolt spacing or structural member location on the cable tray i
hanger base angle'or base plate.
In addition, the Gibbs & Hill design drawings allowed the use of either Hilti expansion anchors or Richa;ond inserts for cer-l tain base connections.
However, design calculations were provided for only Hilti expansion anchors.
Ebasco and Impell procedures (SAG.CP3, SAG.CP4, SAG.CP34 PI-02, and PI-07) i require that the design validation of the anchorage for each individual support i
be based on as-built information including the actual bolt type and spacing as well as the actual location of attached structural members.
TENERA, as the I
third-party reviewer, found that the use of as-built information in design validation of base connections resolves the concerns raised in this issue regarding spacing and type of expansion anchors, r
The staff concludes that the requirement to use as-built information as speci-j fled in the Ebasco and Impe11 design validation procedures for connection t
design provides an adequate basis to resolve the concerns identified in this issue and is, thus, acceptable.
l CYGNA's review of the resolution of this issue closed the issue in Revision 15 1
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
No. 3F).
i i
3.7 Prying Factor Justification i
This issue is described in Section 3.2.7.3 of the cable tray hanger results j
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project statu report.
t The CPRT third party evaluation is summarized in Section 2.2.,/.3 of *he cable tray hanger results report.
l The concern identified by CYGNA in its IAP was that no technical j u tifli. tion I
was provided for a prying action factor of 1.5 used by Gibbs & K+,l'l in base j
connection design calculations.
1 Ebasco and Impell have performed studies (Vol. I, Book 3, and M-25) using f
l finite element models of typical anchorage configurations which exist ai CPSES i
to develop prying factors.
These factors have been incorporated into Ebasco and Impell design validation procedures SAG.CP3, SAG.CP4, SAG.CP34 PI-02, and 1
PI-07.
If an anchorage is not typical, the effects of prying action on base angles and anchor bolts are computed directly by using finite element analysis.
l l
TENERA, as the third party reviewer, has reviewed the Ebasco and Impell studies and evaluated the justification for the prying factors developed therein.
The third party found that these factors are appropriate and confirmed that they have been incorporated into Ebasco's and Impell's design validation procedures.
The staff concludes that the inclusion of appropriate prying factors in the Ebasco and Impell design validation procedures and the acceptability of the Comanche Peak SSER 15 15 Appendix A
-~_ _ ___._-__
l i
i l
J i
studies that justify the appropriateness of the prying factors as found by l
the DAP review provide an adequate basis to resolve the cuncerns identified i
in this issue and are, thus, acceptable.
The staff review and evaluation.of the prying factors are further discussed in Section 4.1.1.4 of this supplement, j
CYGNA's review of the resolution of this issue closed the issue in Revision 15 i
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue j
No. 3G).
1 s
j 3.8 Anchor Bolt Substitution t
t i
This issue is described in Section 3.2.7.3 of the cable tray hanger results I
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable i
tray hanger results report, 2
The concern identified by CYGNA in its IAP was that Gibbs & Hill design drawings and field design changes allowed the interchangeability of Richmond inserts and l
Hilti expansion anchors, and combinations of the two types of anchorages.
Anchor bolt substitution may be inconsistent with design calculations because j
of differences in minimum spacing, tolerance, and embedment length requirements l
for each anchor type.
As a result, allowable tensile loads in Richmond inserts j
and Hilti bolts may be overestimated.
i To resolve this issue, Ebasco and Impell design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, PI-02, and PI-07) require the use of as-built information j
for qualifying anchorages and anchor bolts for each individual support.
- TENERA, v
i as the third party reviewer, found that the as-built program adequately addresses the concern raised in this issue.
{
j The staff concludes that the design validation of_ each cable tray hanger as-built configuration which includes the type of anchor bolt installed as spect-i i
fled in the Ebasco and Inpell procedures provides an adequate basis to resolve i
the concerns identified in this issue and is, thus, acceptable.
i CYGNA's review of the resolution of this issue closed the issue in Revision 15-to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 3H).
i j
3.9 Base Angle Boundary Condition Assumption j
This issue is described in Section 3.2.7.3 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report, l
The concern identified by CYGNA in its IAP was that for trapeze-type supports
]
with two-bolt base angles, Gibbs & Hill design calculations assumed, without l
appropriate justification, free rotation of the base angles about an axis per-pendicular to the plane of the hanger, ignoring the stiffness of the base angle.
I l
Comanche Peak SSER 15 16 Appendix A i
i i
\\
1 Ebasco and Impell have performed special studies (Vol. I, Book 12, and M-04) to determine base angle stiffness including rotation about the strong axis of 1
the angle.
These stiffness values have been incorporated into Ebasco's and Impell's design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, PI-02, and PI-07).
TENERA, as the third-party reviewer, evaluated the base anchorage flexibility coefficients developed by Ebasco and by Impell.
The validity of the assumptions j
and approach used by Ebascc and Impell to generate the stiffness values as well as the methodology for computing stiffnesses analytically was reviewed by the CPRT third party and was found acceptable.
The CPRT third party confirmed that these flexibility coefficients have been incorporated into Ebasco's and Impell's procedures, On the basis of the OAP review, the staff concludes that the acceptability of i
the Ebasco and Impell studies that justify the base angle stiffness values used I
in the Ebasco and Impell design validatinn procedures provides an adequate basis to resolve the concerns identified in this issue, and the base angle stiffness values are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 31).
3.10 Installatior. of Expansion Anchors in Diamond-Cored Holes This issue is described in Section 3.2.7.3 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
i The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
The concern identified by CYGNA in its IAP was that construction procedures i
allowed re-installation of Hilti expansion bolts in previously used holes.
l Anchor strength may be decreased because an oversized core-bore bit was used to i
remove previous bolts.
Bit diameter was not controlled during installation.
No records of whit.h bolts were installed in core-bored holes exist.
Impell performed a special study (M-68) which demonstrates that there is no significant reduction in anchor strength because of the installation of Hilti expansion anchors in diamond-cored (pre-used) holes.
TENERA, as the third-party reviewer, evaluated the Impell study and found the justification provided for not reducing the allowaM e value for Hilti anchors installed in diamond-cored (pre-used) holes acceptable.
The DAP finding was based on the fact that the installation of expansion anchors in diamond-cored holes does not have a significant effect on ultimate capacity when the minimum torque required to set the anchor during installation is achieved.
On the basis of the DAP review, the staff concludes that the installation procedures which ensure that minimum torque values are achieved and the Impell study which shows that there is no significant reduction in anchor strength in diamond-cored holes provide an adequate basis to resolve the concerns in this issue and are, thus, acceptable.
1 l
Comanche Peak SSER 15 17 Appendix A
1 I
i CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
No. 3J).
3.11 _ Reduced Allowable Values for 1-Inch Hilti Kwik-Bolts This issue is described in Section 3.2.7.3 of the cable tray hanger results i
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A3 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.3 of the cable tray hanger results report.
j The concern identified by CYGNA in its IAP was that the vendor-revised (reduced) allowable values for 1-inch-diameter Hilti Kwik-Bolts were not considered by j
Gibbs & Hill in the re-evaluation of existing supports and in new support j
designs performed after the revision.
1' Ebasco and Impell have resolved this issue by incorporating the vendor-recommended reduced allowable values for 1-inch-diameter Hilti Kwik-Bolts into their design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34 PI-02, and PI-07).
The CPRT third party confirmed that Ebasco's and Impell's design i
validation procedures contain the reduced allowble values for 1-inch-diameter Hilti Kwik-Bolts.
3 The staff concludes that the inclusion of the vendor-recommended reduced allow-l able values for 1-inch-diameter Hilti Kwik-Bolts in the Ebasco and Impell pro-cedures provides an adequate basis to resolve the concerns identified in this issue and is, thus, acceptable.
l CYGNA's review of the resolution of this issue closed the issue in Revision 15 j
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue j
No. 3K).
I 3.12 Conclusions Considering these evaluations, the staff concludes that the concerns associated with the design of anchor bolts have been adequately resolved.
The ceble tray
(
hanger technical issue concerning anchor bolt design is, therefore, c)osed
[
for CPSES.
i j
I 1
j i
I l
1 4
1 i
E i
i l
i i
i i
)
Comanche Peak SSER 15 18 Appendix A i
l 4 DESIGN OF COMPRES$10N MEMBERS Concerns were raised about the initial design of the cable tray hanger com-pression members provided by Gibb3 & Hill.
l l
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified 11 related issues from various source docu-ments.
In the cable tray hanger results report, TENERA conbined these concerns into the seven primary issues that follow.
(1) slenderness ratio (2) sidesway restraint (3) cantilever length (4) weld undercut (5) out-of plumbness (6) hanger post effective length (7) brace slope The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-102 i
l SAG.CP4 DAP-CLC-C/5-204 DAP-E-C/S-102 SAG.CP9 DAP-CLC-C/S-204 SAG.CP11 DAP-E-C/5-169 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 SAG.CP34 (Attach. E)
DAP-E-C/5-153 Vol. I, Book 6 DAP-E-C/S-103 Vol. I, Book 16 DAP-E-C/5-143 Position paper on DAP-E-C/S-182 base metal damage
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 19 Appendix A
Project Document
- CPRT Review Document *
(Impell)
PI-02 DAP-CI.C-C/S-404 PI-03 DAP-CLC-C/S-404 PI-11 DAP-E-C/S-170 Report No. 09-0210-0017 DAP-E-C/S-147 Report No. 09-0210-0018 DAP-E-C/S-106 Report No. 01-0210-1470 DAP-E-C/S-103 Study No. B-03 DAP-E-C/S-103 Study No. B-04 DAP-E-C/5-190 (Test Laboratory)
ANCO Document No. A-000181 DAP-E-C/S-146 4.1 Slenderness Ratio This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A4, Section 2A).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.4).
CYGNA identified a concern in its IAP that in the design of compression members for trapeze-type support frames in cable tray hangers, Gibbs & Hill did not consider the entire unsupported length of the channels to calculate the slender-ness ratios.
If the co rect unsupported lengths and pinned end conditions were assumed, the slenderness ratio of the.e members for bend;ng about their weak axis would exceed 200.
The AISC code specification (Reference A) in Para-graph 1.8.4 limits the slenderness ratio for compression members to 200.
The Ebasco and Impell resolution metnodologies provide a design validation of compression members performed in accordance with the AISC specification (Ref-erence A7) using K-factors (effective length) and KL/r (slenderness ratio) limits determined by special studies.
)
K-factors for transverso hanger members are based on the assumption that trays restrain hangers against out-of plane buckling (i.e., buckling about the weak l
axis of channel members).
This assumption has been confirmed by full-scale dynamic tests of cable tray systems (ANCO, Document No. A-00C181) which showed that little or no slip occurs between trays and transverse hangers during seismic shaking.
K-factors and slenderness ratios for in-plane buckling (e.g.,
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 20 Appendix A
I buckling of posts in longitudinal hangers about the weak axis of channel mem-bers) are addressed in the following issue (see Section 4.2 of this appendix) concerning the effectiveness of sidesway restraint.
1 Slenderness ratios for compression membert have been limited to 200.
Tension members are allowed slenderness ratios up to 300.
A member is considered to be a tension member when it is normally subjected to tension under static load, and static plus dynamic load results in a compressive stress less than 50 per-cent of the allowable compressive stress.
The DAP review of this issue found the K-factors and KL/r limits resulting from Ebasco and Impell documents (Special Study Vol. I, Book 6; Reports Nos. 09-0210-0018 and 01-0210-1470; and Study No. B-03) for transverse hanger members to be acceptable and verified that the limits have been incorporated in Ebasco's and Impell's design validation procedures (SAG.CP9, SAG.CP34, PI-03, PI-11).
The OAP review also found the assumption that trays provide lateral stability to hangers to be valid (see Section 18.1 of this appendix).
Impell design validation procedures include K-factors and KL/r limits for most hanger configurations, but in a few cases (e.g.. for very long hangers) ex-plicit rules are not provided and are evaluated on a case-by-case basis, The l
g DAP review (DAP-E-C/S-188) of 521ected Impell calculations confirmed that conservative K-ftators were used for hangers not explicitly covered by the design validatic ocedures.
The staf f concludes that the inclusion of appropriate K-factors and KL/r limits in Ebasco's and Impell's design validation procedures and their justification as documented in the related special studies performed by Ebasco and Impell provide an adequate basis to resolve the concerns raised with regard to the issue of slenderness ratio.
On the basis of the OAP review, the staff concludes that for the few cases of very long hangers, conservative K-factors were used in the Impell calculations and v e, thus, acceptable.
The staff review and evaluation of the slenderness ratio are further discussed in Section 4.1.1.4 l
of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 4A).
4.2 Sidesway Restraint i
This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A4, Section 28).
The DAP evaluation l
is summarized in the cable tray hanger results report (Section 3.2.7.4).
CYGNA identified a concern in its IAP that when calculating the slenderness ratio of the compression members for trapeze-type supports, Gibbs & Hill did not check the ef fectiveness of the in plane sidesway restraint for the various support designs.
In the Ebasco and Impell resolution methodologies, special studies (Ebasco, Special Study Volume I, Book 6; Impell, Report No. 01-0210-1470 and j
Comanche Peak SSER 15 21 Appendix A
_ _ _ =
l
.1 i
j j
Study No. B-04) were performed to determine effective length (K) factors for j
cable tray hangers representative of the installed configurations.
These studies include consideration of sidesway restraint for both transve.se and i
longitudinal trapeze-type hangers.
These effective length factors are used in l
l cable tray hanger validation in accordance with design validation procedures I
(Ebasco, SAG.CP9 and SAG.CP34, and Impell, Instruction PI-11).
The DAP review found the K-factors resulting from the special studies to account for the in plane sidesway restraint to be adequate and verified that the factor has been incorporated in Ebasco's and Impell's design validation procedures.
a The OAP also found the approach used in these studies to model the sidesway restraint provided by the trays to be acceptable.
The staff concludes that the development of an appropriate K-factor to account for the in plane sidesway restraint and its inclusion in the Ebasco's and i
Impell's desinn validation procedures and the acceptability of the related special studies as found by the DAP review which justify the K-factor provide an adequate basis for the resolution of the concerns raised with regard to this issue and are, thus, acceptable, t
CYGNA's review of the resolution of this issue closed the issue in Ravision 15 to CYGNA's reviev issues list for cable tray hangers (Reference A4, issue No. 4B).
l 4.3 Cantilever Length I
This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A4, Section 2C).
The DAP evaluation 1
1 is summarized in the cable tray hanger results report (Section 3.2.7.4).
t i
J CYGNA identified a concern in its IAP that in the design of the compression 1
member for cantilever tu e supports, Gibbs & Hill used the distance from the i
face of the concrete to the centerline of the cable tray as the cantilever length.
The correct length should have been from the concrete face to the 1
clamp in the far side of the tray.
An effective length value of K = 1.0 was
)
used to calculate the minor axis slenderness ratio, rather than the value of 4
K = 2.0 for cantilevers.
A value of K = 1.0 was based on the assumption that l
the tray will provide lateral bracing at the clamp location.
t i
The Ebasco and Impell resolution methodologies involved the development of i
design validation procedures (SAG.CP9, SAG.CP34. PI-03, and PI-11) which pro-l vide requirements for the appropriate unsupported length of hanger members to be 1
use9 to calculate compression member slenderness ratios.
In addition, engineer-i ing studies (Ebasco, Vol. I, Book 6; Impell, Report No. 01-0210-1470 and Study 1
No. B-04) have been conducted to develop effective length factors for cable tray hangers representative of the installed configurations.
These effective length factors are used in cable tray hanger validation in accordance with design validation procedures.
e l
The lengths specified in Ebasco's procedures for cantilever members were i
reviewed under the DAP and found acceptable.
The lengths specified in Impell's l
procedures for cantilever members and the related K-factors determined by
}
Comanche Peak SSER 15 22 Appendix A i
special studies (Impeli, Report No. 09-0210-1470 and Study No. B-03) were reviewed under the DAP and found acceptable.
The DAP review also verified that trays provide restraint to cantilevered compression members (see Section 18.1 of this appendix).
The staff concludes that the development of appropriate values fcr effective cantilever lengths and their inclusion in Ebasco's and Impell's design valida-tion procedures provide an adequate basis for the resolution of the concerns raised with regard to this issue and are, thus, acceptable.
The staff review and evaluation of the effective cantilever lengths are further discussed in Section 4.1.1.4 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGHA's review issues list for cable tray hangers (Reference A4, Issue No. 4C).
4.4 Weld Undercut This iscue is discussed in the cable tray hanger rese'ts report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are p,ovided in the cable tray hanger project status report (Subappendix A4, Section ?D).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.4).
CYGNA identified a concern in its IAP for the trapeze-type cable tray supports, that Gibbs & Hill did not consider the effect of weld undercut on the section properties of compression members at the point where in plane braces are attached to the channel web.
The Ebasco and Impell resolution methodologies involved the use of the Nuclear Construction Issues Group (NCIG), "Visual Weld Acceptance Criteria (WAC),"
NCIG-01, Revision 2, May 7, 1985, which has been found acceptable by the staff for CPSES as discussed in Section 3.8.3 of Supplement 12 to the SER (Refer-ence A8).
Welds not satisfying the WAC undercut requirement are evaluated and, where necessary, repaired.
In addition, Ebasco has performed a study of the
'i base metal defects identified by quality control inspection of cable tray hangers (Ebasco "Position Paper on Base Metal Damage in Thermolagged CTHs") and has concludec that the effects of weld undercut on cable tray hangers are not significant and can be neglected in design validation.
The OAP reviewed Ebasco's special study on base metal defects and found that weld undercut need not be consicered in design validation of cable tray hangers.
The staff concludes that the acceptability of the study on base metal defects l
at CPSES as found by the DAP review and the approach for evaluating weld under-cut as specified in the WAC method provide an adequate basis for the resolu-tion of the concerns raised with regard to this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 3D).
4.5 Out-of-Plumbness This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are previded in the cable tray Comanche Peak SSER 15 23 Appendix A
hanger project status report (Subappendix A4, Section 2E).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.4).
CYGNA identified an issue in its IAP concerning the effect of a 2-degree tolerance from plumb for vertical compression-members.
Tests and studies performed by Impell and Ebasco (heport No. 09-0210-0017 and Vol. I, Book 16) demonstrated that the 2-degree out-of plumbness tolerance for cable tray hangers has no effect on design adequacy.
Out-of plumbness greater than 2 degrecs was noted on as-built hanger drawings and was conaidered as required in Ebasco and Impell design validation procedures SAG.CN4 and PI-02.
The DAP reviewed Ebasco's special study on dimensional tolerances and found that the effect of a 2-degree out-of plumbness tolerance on member stresses is insignificant.
The staff concludes that the inclusion of guidelines for evaluating out-of-plumbness greater than 2 degrees in Ebasco's and Impell's design validation procedures and the justification for neglecting out-of plumbness of 2 degrees or less as documented in related special studies provide an adequate basis to resolve the concerns raised with regard to this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue Nos. 4E and 29).
4.6 Hanger Post Effective Length This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A4, Section 2F).
The OAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.4).
CYGNA identified a concern in its IAP concerning the use of a reduced un-supported length for cable tray trapeze hangers based on an invalid assumption of rigidity of the base angle leg relative to the hanger.
The Ebasco and Impell resolution methodologies involved the determination of a conservative length of cable tray hanger members to be used in the design validat:an as specified in Ebasco and Impell procedures SAG.CP34, PI-03, and PI-02.
The Ebasco and Impell procedures required that the unsupported member length be measured from the face of the concrete.
The DAP review confirmed that Ebasco's and Impell's procedures es+.ablished appropriate member lengths in the design validation of trapeze hangers and cantilevers.
The staff concludes that the use of a conservative method to determine the length of cable tray hanger members to be used in analytical models in Ebasco's and Impell's design validation procedures provides an adequate basis to re-solve the concerns raised with regard to this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 4F).
Comancho Peak SSER 15 24 Appendix A
4.7 Brace Slope This issue is discussed in the cable tray hanger results report (Section 3.2.7.4).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A4, Section 2G).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.4).
For the design of braces in compression, the axial force is a function of the brace slope.
Gibbs & Hill designs provided a range of allowable brace slopes.
CYGNA in its IAP identified a concern that, in some cases, Gibbs & Hill calcu-lations checked the brace for the slope w'nich resulted in the largest axial load without considering other cases which have lower loads, but also had reduced capacity becausa of a longer member length.
.ie Ebasco and Impell resolution methodologies involved the design validation of bracing members using as-built information in accordance with Ebasco and Impell procedures SAG.CP3, SAG.CP4, SAG.CP34, PI-02, and PI-03.
The DAP review found that the use of as-built information by Ebasco and Impell in design validation resolves this concern.
The staff concludes that the design validation of bracing members using actual slopes as specified in Ebasco's and Impell's design validation procedures pro-vides an adequate basis to resolve the concerns raised with regard to this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 4G).
4.8 Conulusions i
Considering these evaluations, the staff concludes that the concerns associated j
with cable tray hanger compression members have been adequately resolved.
The cable tray hanger technical issue concerning the design of compression members at CPSES is, therefore, closed.
I t
I Comanche Peak SSER 15 25 Appendix A
5 VERTICAL AND TRANSVERSE LOADING ON LONGITUD AAL TYPE SUPPORTS Gibbs & Hill considered only longitudinal seismic load in the design of long-itudinal trapeze-type supports.
Concerns have been raised that these supports should also be dosigned for transverse and vertical seismic load.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified four related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP11 DAP-E-C/S-169 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 (Impell)
PI-02 DAP-CLC-C/S-404
)
5.1 Vertical and Tran'sverse Loading Considerations This issue is discussed in the cable tray hanger results report (Section 3.2.7.5).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A5).
The DAP evaluation is summar-ized in the cable tray hanger results report (Section 3.2.7.5).
In its IAP, CYGNA identified a concern regarding the applicable loadings to be considered on longitudinal-type supports.
Longitudinal trapeze-type supports were assumed to act independently of the transverse supports.
Gibbs & Hill calculations for these longitudinal supports only considered longitudinal cable tray loads in the design of frame members and anchor bolts.
Since these supports are rigidly connected to the cable trays with "heavy duty clamps,"
a tributary tray mass will be associated with these supports.
Ghen this type of tray connection, CYGNA questioned whether these supports must be additionally designed for vertical and possibly transverse seismic loads similar to the transverse supports.
- All relavant project and CPRT third party documents are listed in Appendix E to thic supplement.
Comanche Peak SSER 15 26 Appendix A
The Ebasco and Impell resolution methodologies involved developing guidelines in their design validation criteria and procedures (SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34, and PI-02) which require the simultaneous application of seismically induced loads in three orthogonal directions on all cable tray hangers.
The DAP review of Ebasco's and Impell's design validation procedures confirmed that. longitudinal trapeze-type supports are required to be design validated for the simultaneous application of seismic loads in all three orthogonal directions.
The staff concludes that the design validation of longitudinal supports for three orthogonal components of earthquake motion provides an adequate basis to resolve the concerns raised by this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 5).
5.2 Conclusions Considering this evaluation, the staff concludes that the concerns about the vertical and transverse loading considerations have been adequately resolved.
The cable tray hanger technical issue concerning vertical and transverse load-ing on longitudinal-type supports is, therefore, closed for CPSES.
Comanche Peak SSER 15 27 Appendix A
~.
6 SUPPORT FRAME DEAD AND INERTIAL LOADS Concerns were raised regarding Gibbs & Hill's consideration of out-of plane inertial loads and dead loads in the design of cable tray supports.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP) identified six related issues from various source documents which were grouped into (1) out-of plane inertial loads and (2) dead loads.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 JAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP11 DAP-E-C/S-169 SAG.CP34 DAP-CLC-C/S-204 (Impell)
PI-02 DAP-CLC-C/S-404 Report No. 09-0210-0017 DAP-E-C/S-147 (Test Laboratory)
ANC0 Document No. A-000181 DAP-E-C/S-146 6.1 Out-of-Plane Inertial Loads This issue is discussed in Section 3.2.7.6 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A6 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.6 of the cable tray hanger results report.
The concerns that CYGNA identified in its IAP were (1) out-of plane inertial loads (loads in direction parallel to the cable tray) that were not considered by Gibbs & Hill in the design of transverse (twc"way) cable tray supports and (2) out-of plane inertial loads transmitted from the transverse supports through the cable trays that were not considered in the design of longitudinal supports.
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 28 Appendix A
= _ _. -
Ebasco and Iupell resolved this issue by modeling the transverse support mass and assuming that transverse supports are fully connected to the cable trays in all directions when the response spectrum method (RSM) is used for validation.
The assumption of full connectivity between transverse supports and the cable tray has been validated by full-scale dynamic tests and related engineering studies (ANCO, Document No. A-000181 and Impell, Report No. 09-0210-0017).
In the equivalent static method (ESM) analysis used by.Ebasco, the issue is resolved by using the longitudinal support displacements and accelerations for the out-of plane response in the design validation of transverse supports.
For design validation of longitudinal supports, the out-of plane load from transverst tupports is assumed to be transmitted through the cable trays to the longituoinal supports.
The Ebasco and Impell design validation criteria are specified in Ebasco and Impell precedures (SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34, and PI-02).
The CPRT third party reviewer found the assumptions used by Ebasco and Impell in RSM analyses acceptable, and verified that the Ebasco procedures for ESM analysis adequately considered out-of plane inertial loads in the design validation of cable tray systems.
The staff concludes that the inclusion of appropriate connectivity assumptions fc? cable trays and supports in the Ebasco and Impell procedures and the justi-fication of these assumptions by the tests and special study provide an adequate basis to resolve the concerns identified in this issue and are, thus, acceptable.
l CYGNA's i uiew of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 6A).
6.2 Dead Loads This issue is discussed in Section 3.2.7.6 of the cable tray hanger results l
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A6 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.6 of the cable tray hanger results report.
The concern identified by CYGNA in its IAP was that Gibbs & Hill in the design of cable tray supports did not consistently consider, and at times totally ignored, the self-weight of the support.
To resolve this issue, Ebasco and Impell procedures (SAG.CP3, SAG.CP4, SAG.CP11, SAG.CP34, and PI-02) require that support deadweight be explicitly included in the design validation of the cable tray supports.
TENERA, as the CPRT third party reviewer, confirmed in its review of the Ebasco and Impell design validation procedures that dead-weight is appropriately considered in the design of cable tray supports.
The staff concludes that the inclusion of the deadweight load case '- the Ebasco and Impell design validation procedures provides an adequate basis to resolve the concerns identified in this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 6B).
1 Comanche Peak SSER 15 29 Appendix A
6.3 Conclusions
.Considering these evaluations, the staff concludes that'the concerns.regarding the self-weight and inertial loads of cable tray hanger frames have been adequately resolved. 'The cable tray hanger technical. issue concerning support frame dead and inertial loads is, therefore, closed for CPSES.
F i
Comanche Peak SSER 15 30 Appendix A
_... _. _ ~ _... _, _. _ -, -_.__
e 7 DESIGN OF ANGLE BRACES NEGLECTING LOADING ECCENTRICITY Various concerns were raised regarding Gibbs & Hill's design of angle braces for cable tray supports which neglected consideration of stresses induced by eccentric end connections.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified five related issues from various source documents.
TENERA combined these related issues into (1) longi-tudinal braces, (2) in plane braces,'and (3) twist buckling.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/5-204 DAP-E-C/F-120 SAG.CP4 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP34 DAP-CLC-C/S-204 SAG.CP34, Attach. V DAP-E-C/S-151 (Impell)
PI-02 DAP-CLC-C/S-404 PI-03 DAP-CLC-C/S-404 M-12 DAP-E-C/S-115 7.1 Longitudinal Braces This issue is discussed in Section 3.2.7.7 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A7 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.7 of the cable tray hanger results report.
CYGNA has identified two concerns in its IAP regarding Gibbs & Hill's design of double-angle braces used to resist longitudinal loads in longitudinal cable tray supports.
One concern was that bending stresses caused by eccentric end connections were not considered in design calculations.
The second concern was that double-angle braces were improperly analyzed as composite members even though intermittent filler plates were not provided as required by AISC code Section 1.18.2.4 (Reference A7).
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 31 Appendix A
To resolve these concerns, both Ebasco and Impell evaluated double-angle braces as composite members only if filler plates were provided in accordance with the AISC specification.
Ebasco validated the design of angle braces for moments induced by end-connection eccentricity.
Impell performed a study (M-12) to investigate the effects of end-connection eccentricity and found the effects to be insignificant.
Therefore, Impell.did not model end-connection eccentri-city in the-design validation of angle braces.
The CPRT third party review confirmed that Ebasco and Impell. design validation procedures (SAG.CP34, PI-02, and PI-03) allow double-angle members to be evalu-ated_as composite members only if filler plates are provided in accordance with AISC specifications.
The CPRT. third party review also confirmed that Ebasco procedures require angle braces to be checked for the effects ?f end-connection eccentricity.
In addition, the third party review found Impell's findings in study M-12 that end-connection eccentricity effects are small and can be ignored in design validation of angle braces to be acceptable.
The staff concludes that the inclusion of appropriate guidelines to evaluate loads in longitudinal braces in the Ebasco and Impell procedures and the justi-fication for ignoring end-connection eccentricity, as documented by Impell studies, provide an adequate basis to resolve the concerns identified in this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 7A).
7.2 In-Plane Braces This issue is discussed in Section 3.2.7.7 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A7 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.7 of the cable tray hanger results report.
CYGNA has identified concerns in its IAP regarding Gibbs & Hill's design of in plane angle braces of transverse and longitudinal cable tray supports that bending stresses due to end-connection eccentricity were not considered in design calculations and that angle members were not checked considering prin-cipal axis section moduli.
4 The Ebasco and Impell resolution of the concern regarding end-connection eccen-tricity is discussed in Section 7.1 of this appendix.
The second concern regarding section moduli was resolved by Ebasco in its requirement that angle braces be design validated using principal axis properties.
Impell resolved this concern by applying a correction factor to account for the difference between geometric and principal axis properties.
The CPRT third party review found the Ebasco use of principal axis section properties and Impell's use of a correction factor as applied to the geometric axis section properties to be acceptable.
I The staff concludes that the inclusion of appropriate methods to evaluate principal axis section moduli in Ebasco and Impell design validation proce-dures and the development of studies to justify these methods provide an Comanche Peak SSER 15 32 Appendix A
adequate basis to resolve the concerns identified in this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray-hangers (Reference A4, Issue No. 7B).
7.3 Twist Buckling This issue is discussed in Section 3.2.7.7 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A7 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.7 of the cable tray hanger results report.
The concern identified by CYGNA in its IAP was that for some angle braces, one leg of the angle was welded at one end of the brace while the other leg of the angle was welded at the other end of the brace.
Braces with such end condi-tions were not evaluated for. twist buckling.
Twist buckling may also occur with angles that are welded on the same leg at each end but that have eccen-tric loading.
Ebasco and Impell have resolved this issue by requiring that angle braces be checked for twist buckling if their slenderness ratios are below a specified value depending on the angle size.
For braces with high slenderness ratics, Euler buckling will govern.
The Ebasco and Impell criteria are specified in procedures SAG.CP34, M-12, and PI-03.
TENERA found that Ebasca and Impell design validation procedures adequately resolve this issue.
In addition, the CPRT third party reviewed selected Ebasco and Impell calculations to confirm that single-angle braces are adequately checked for twist buckling (documented in DAP-E-C/S-187 and DAP-E-C/S-188).
The staff concludes that the inclusion of appropriate design criteria for twist buckling in Ebasco and Impell design validation procedures provides an i
adequate basis for resolving the concerns identified in this issue and is,_thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 7C).
7.4 Conclusions f
l Considering these evaluations, the staff concludes that the concerns regarding the eccentricity effects on the design of angle braces have been adequately resolved.
The cable tray hanger technical issue concerning the design of angle braces neglecting loading eccentricity is, therefore, closed for CPSES.
Comanche Peak SSER 15 33 Appendix A
8 DYNAMIC AMPLIFICATION FACTORS (DAFs)-AND RATIOS BETWEEN CONTINU0US TRAY j
SUPPORT REACTIONS AND TRIBUTARY TRAY SUPPORT REACTIONS Concerns have been raised in the initial design of the CPSES cable tray sup-ports regarding the dynamic amplification factor used in the equivalent static analysis of cable tray hangers.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy I
Program (DAP), identified six related issues.from various source documents.
TENERA combined these related issues into one primary issue.
The relevant Ebasco and Impell project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP CLC-C/S-204 DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/5-204 DAP-E-C/S-120 SAG.CP18 DAP-E-C/S-124 SAG.CP19 DAP-E-C/S-124 SAG.CP28 DAP-E-C/S-149 SAG.CP34 (Attach. Y & Z)
DAP-CLC-C/S-204 DAP-E-C/S-149 Vol. I, 'Jook 9 DAP-E-C/S-101 Vol. I, Book 1U DAP-E-C/S-101 Vol. I, Book 15 DAP-E-C/S-149 Vol. I, Book 23 DAP-E-C/S-149 (Impell)
PI-02 DAP-CLC-C/S-404 8.1 Multimode Response Multiplier This issue is discussed in Section 3.2.7.8 of the cable tray hanger results report.
The Ebasco and Impe11 resolution methodologies and corrective actions
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 34 Appendix A
l are presented in Subappendix A8 of the cable tray hanger project status report.
i The CPRT third party evaluation is summarized in Section 3.2.7.8 of the cable tray hanger results report.
Gibbs & Hill applied a dynamic amplification factor (DAF) of 1.0 to the govern-ing design spectrum in order to determine the seismic response of the support.
The CPSES FSAR (Reference A9) required the use of a DAF of 1.5 unless justi-fication was provided for using a lower value.
An additional concern was that Gibbs & Hill used the tributary span method to account for the distribution of tray loads on the individual supports.
This method may not adequately consider the effect of system response on the distribution of tray loads to individual supports.
i Ebasco validated most of the cable tray supports within its scope by equivalent l
static method (ESM) analysis, multiplying the governing design spectrum ordi-nate at the lowest frequency of the cable tray system by a DAF of 1.25 to obtain the seismic response of the support.
If the lowest frequency of the cable tray system fell below the peak of the spectrum, then the DAF of 1.25 was applied to the peak value.
Ebasco performed special studies to validate the 1.25 multiplier (Vol. I, Books 9, 10, 15, and 23).
These studies also deter-mined the limits of applicability for both multimode and system-type load distribution effects, including stiffness-of trays relative to hangers, varying span lengths and configurations, and different support stiffnesses.
For cable tray systems or supports falling outside the permissible limits, a multiplier greater than 1.25 was used, or a response spectrum analysis was performed.
The Ebasco 1.25 multiplier is specified in design validation procedures SAG.CP3, SAG.CP4, SAG.CP18, SAG.CP19, and SAG.CP34.
Impell used ESM analysis only for complex ganged supports and in these cases applied a DAF of 1.5 consistent with the CPSES FSAR.
When response spectrum 6nalysis was used by either Impell or Ebasco, system effects, such as relative stiffnesses and varying span lengths, were explicitly accounted for by a dynamic model of the cable tray system.
TENERA found acceptable the Ebasco studies (Vol. I, Books 9 and 10) which vali-date the use of a DAF of 1.25 for "regular" tray configurations.
The additional studies and screening procedures (Vol. I, Books 15 and 23, and SAG.CP28) which delineate the limits of the 1.25 multiplier and the methods for determining the value of the multiplier to be used for "irregular" tray / support configurations were also found acceptable.
TENERA reviewed Impell's project instruction (PI-02) for using ESM or RSM analysis and concluded that it is appropriate for resolving this issue.
The staff concludes that the use of an appropriate dynamic amplification factor in the Ebasco and Impell design validation procedures and the development of special studies to justify the 1.25 multiplier provide an adequate basis for resolving the concerns identified in this issue and are, thus, acceptable.
The staff review and evaluation of the 1.25 multimode response multiplier are further discussed in Section 4.1.1.4 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 8A).
Comanche Peak SSER 15 35 Appendix A
8.2 Conclusions Considering this evaluation, the staff concludes that the concerns regarding the dynamic amplification factor used in equivalent static analyses-of cable tray hangers have been adequately resolved.
The cable tray hanger technical issue.concerning dynamic amplification factors and ratios between continuous tray support reactions and tributary tray support reactions.is, therefore, closed for CPSES.
i
.1 Comanche Peak SSER 15 36 Appendix A
9 RE0VCTION OF CHANNEL SECTION PROPERTIES DUE TO CLAMP BOLT HOLES Concerns were raised in the initial cable tray support calculations performed by Gibbs & Hill that a reduction in section properties of channel members when bolt holes are present in the flange was not considered as is required by the AISC code (Reference A7).
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified three related issues from various source documents, which were combined into one issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP34 DAP-CLC-C/S-204 Vol. I, Book 22 DAP-E-C/S-181 Vol. I, Book 25 DAP-E-C/S-184 (Impell)
PI-11 DAP-E-C/S-170 M-65 DAP-E-C/S-180 9.1 Design Considerations for Clamp Bolt Holes in Channels This issue is discussed in Section 3.2.7.9 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A9 of the cable tray hanger project status report.
The CPRT third party evaluation is sum.narized in Section 3.2.7.9 of the cable tray hanger results report.
The concern was that Gibbs & Hill did not use reduced section properties when holes were present in the flanges of channel members used for cable tray support tiers.
Ebssco and Impell resolved this issue by requiring that all cable tray support tiers be evaluated with reduced section properties to account for the preser.ce of either used or unused clamp bolt holes in one flange.
The reduced section properties were used to derive limits on interaction ratios for design validation of cable tray support tiers.
The derivations of reduced section properties are documented in Ebasco's special studies (Vol. I, Books 22 and 25) and Impell's special study (M-65).
TENERA, as the CPRT third party reviewer, found that the Ebasco and Impell studies for the derivation of reduced section properties and the corresponding limits on interaction ratios are consistent with AISC specification require-ments. TENERA also confirmed that the Ebasco and Impell design validation
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 37 Appendix A
procedures (SAG.CP34 and PI-11). correctly incorporate the limits on inter-
. action ratios.
The staff concludes that the use of reduced section properties to account for bolt holes in channels in Ebasco and Impell design validation procedures as justified in the related special studies provides an adequate basis for resolving the concerns identified in this issue and is, thus, acceptable.
The staff review and evaluation of clamp-bolt holes in channels are further dis-cussed in Section 4.1.1.4 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 9).
9.2 Conclusions Considering this evnluation, the staff concludes that the concerns regarding the effects of clamp bolt holes in channel members have been adequately re-solved. The cable tray hanger technical issue concerning reduction of channel section properties due to clamp bolt holes is, therefore, closed for CPSES.
1 i
i Comanche Peak SSER 15 38 Appendix A y
10 SYSTEM CONCEPT Concerns were raised regarding the rationale that the cable tray and cable tray supports act as a system used by Gibbs & Hill to justify cable tray support l
design assumptions.
]
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified 10 related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into the six primary issues that follow.
(1) load eccentricity on support (2) lateral bracing of cantilevers 4
(3) tranverse and vertical loads on longitudinal supports (4) prying actior, (5) self-weight seismic loading (6) eccantricities of tier / post lap joint The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/S-204 l
DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/S-204 DAP-E-C/S-120 l
SAG.CP9 DAP-CLC-C/S-204
]
SAG.CP11 DAP-E-C/S-169 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 Vol. I, Book 2 DAP-E-C/S-112 Vol. I, Book 7 DAP-E-C/S-109 (Impell)
PI-02 DAP-CLC-C/S-404 PI-07 DAP-CLC-C/S-404 DAP-E-C/S-120 l
M-12 DAP-E-C/5-115 Report No. 09-0210-0017 DAP-E-C/S-147 j
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 39 Appendix A j
10.1 Load Eccentricity on Support This issue is discussed in the cable tray hanger results report (Sections 3.2.7.10, 3.2.7.18, and 3.2.7.24).
The Ebasco and Impell resolutions of this issue are pro-vided in the cable tray hanger project status report (Subappendices A10.2.A. A18, and A24).
The DAP evaluation is summarized in the cable tray hanger results re-port (Sections 3.2.7.10, 3.2.7.18, and 3.2.7.24).
In the initial design justification of cable tray hangers, Gibbs & Hill assumed that the moments caused by the eccentricities between the load application points (i.e., tray centroid) and the support members (i.e., center of resistance) would be balanced by force couples at adjacent supports.
These assumptions were inconsistent with certain assumptions made regarding tray-to-hanger clamp behavior.
In the CAP design validation of cable tray hangers, Ebasco assumed the longi-tudinal load to be applied on the supporting tier member at the centerline of the clamp-to-tray bolt for one-bolt connections and at the top of the tier flange for two-bolt connections.
Impell assumed the longitudinal load to be applied coincident with the mid-height of the tray.
The CPRT third party reviewed the Ebasco and Impell studies that justify the methods used for evaluating load eccentricities.
The justification for Ebasco load location assumptions provided in a special study (Vol. 1, Book 7) was re-viewed under the DAP and found acceptable.
Impe11 study M-12, which provides the justification for load location and other modeling techniques, was reviewed under the DAP and found acceptable.
The staff concludes that the inclusion of detailed modeling techniques to account for load eccentricities in Ebasco and Impell design validation proce-dures and the development of special studies to justify those methods provide an adequate basis for resolving the concerns identified in this issue and are, thus, acceptable.
The staff review and evaluation of the modeling of load eccentricities are further discussed in Section 4.1.2.4 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue Nos. 18, 24A, 24B, and 240).
I 10.2 Lateral Bracing of Cantilevers This issue is discussed in the cable tray hanger results report (Sections 3.2.7.10, 3.2.7.4, and 3.2.7.18).
The Ebasco and Impell resolutions of this issue are pro-vided in the cable tray hanger project status report (Subappendices A10.2.B. A4, and A18).
The DAP evaluation is summarized in the cable tray hanger results report (Sections 3.2.7.10, 3.2.7.4, and 3.2.7.18).
In Gibbs & Hill's design of trapeze and cantilever support members for com-pression loads, trays were assumed to provide lateral bracing to the support members, without justification.
l The staff evaluated this issue in Sections 4.1 and 18.1 of this appendix.
I i
1 i
Comanche Peak SSER 15 40 Appendix A 4
10.3 Transverse and Vertical Loads on Longitudinal Supports This issue is discussed in the cable tray hanger results report (Sections 3.2.7.10 and 3.2.7.5).
The Ebasco and Impell resolutions of this issue are provided in the cable' tray hanger project status report (Subappendices A10.2.C and A5).
The DAP evaluation is summarized in the cable tray hanger results report (Sec-tions 3.2.7.10 and 3.2.7.5).
The primary concern was that, for.the design of longitudinal trapeze supports, transverse and vertical loads were not considered by Gibbs & Hill.
Only longitudinal loads were considered.
The staff evaluated this issue in Section 5.1 taf this appendix.
10.4 Prying Action This issue is discussed in the cable tray hanger results report (Section 3.2.7.10 and 3.2.7.3).
The Ebasco and Impell resolutions of this issue are provided in the cable tray project status report (Subappendices A10.2.D and A3).
The DAP evaluation is summarized in the cable tray hanger results report (Sec-tions 3.2.7.10 and 3.2.7.3).
Gibbs & Hill assumed that the hanger attachment to the tray minimizes addi-tional tensile forces in anchor bolts that would otherwise occur when base angles rotate about their longitudinal axis.
The staff evaluated this issue in Section 3.1 of this appendix.
10.5 Self-Weight Seismic loading This issue is discussed in the cable tray hanger results report (Sections 3.2.7.10 and 3.2.7.6).
The Ebasco and Impe11 resolutions of this issue are provided in the cable tray hanger project status report (Subappendices A10.2.E and A6).
The DAP evaluation is summarized in the cable tray hanger results report (Sec-tions 3.2.7.10 and 3.2.7.6).
In the design of longitudinal supports, Gibbs & Hill did not consider out-of-plane seismic loads from self-weight excitation of two-way trapeze support frames (i.e., transverse supports).
The staff evaluated this issue in Section 6.1 of this appendix.
10.6 Eccentricities of Tier / Post Lap Joint This issue is discussed in the cable tray hanger results report (Section 3.2.7.10).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A10.2.F).
The DAP evaluation is sum-marized in the cable tray hanger results report (Section 3.2.7.10).
Without sufficient justification, Gib's & Hill neglected bending and torsion o
introduced in support members by the eccentricity between section neutral axes in tier / post lap joint connections.
The tray was assumed to resist a portion of the additional loads caused by the eccentricity.
Comanche Peak SSER 15 41 Appendix A
.The Ebasco and Impell resolut on met o o ogy cons s s of developing design vali-i hdl it dation procedures (SAG.CP3, SAG.CP4, SAG.CP9, SAG.CP11, SAG.CP34, PI-02, and PI-07) to evaluate hanger joint eccentricities using specified modeling tech-niques.
Ebasco and Impell special studies (Vol. I, Books 2 and 7, and Report No. 09-0210-0017) provide justification for the modeling techniques used in the Ebasco and Impell procedures.
The DAP review verified that Ebasco's and Impell's design validation procedures account for tier / post eccentricity in the analyses of supports.
Attachment E of Ebasco's design validation procedures and Impell's project instruction (PI-02), which specify eccentric joint modeling methods, were evaluated under the DAP and found to be acceptable.
The staff concludes that the inclusion of detailed modeling techniques to evaluate hanger joint eccentricities in the Ebasco and Impe11 design validation procedures and the development of special studies to justify the modeling techniques provide an adequate basis for resolving the concerns identified in this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 10F).
10.7 Conclusions Considering these evaluations, the staff concludes that the concerns regarding Gibbs & Hill's system concept have been adequately resolved.
The cable tray hanger technical issue concerning the system concept is, therefore, closed for CPSES.
r I
i 1
Comanche Feak SSER 15 42 Appendix A
- -,,, + - -
11 VALIDITY OF NASTRAN MODELS NASTRAN models used in certain generic studies performed by Gibbs & Hill in support of the initial cable tray support design assumed a row of identical supports.
A concern was raised that these models were not representative of actual mixed support and span configurations.
Hence, system frequencies and seismic responses obtained using these models might have been incorrect.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified two related issues from various source docu-l ments.
In the cable tray hanger results report, T'.NERA combined these concerns l
into one primary issue.
11.1 Use of NASTRAN in Previous Generic Studies This issue is discussed in the cable tray hanger results report (Section 3.2.7.11).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix All).
The DAP evaluation is summar-ized in the cable tray hanger results report (Section 3.2.7.11).
This issue is specific to generic studies performed in support of the initial cable tray hanger design by Gibbs & Hill and is not relevant to the cable tray hanger design validation effort under the TU Electric Corrective Action Program.
The staff concludes that the issue of generic NASTRAN study models is not applicable to design validation work by Ebasco and Impell.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 11).
11.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with the Gibbs & Hill NASTRAN models have been resolved.
The cable tray hanger technical issue regarding the validity of NASTRAN models is, therefore, closed for CPSES.
i i
Comanche Peak SSER 15 43 Appendix A
12 WORKING POINT DEVIATION STUDY In the initial design of cable tray supports, Gibbs & Hill assumed that the neutral axes of connected members intersected at a common point.
Thus, con-I nection eccentricities were not considered.
Gibbs & Hill provided_ allowable working point deviations for generic acceptance of installed cable tray supports in the Working Point Deviation Study.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the. Design Adequacy Prngram (OAP), identified 20 related issues from various source'docu-ments.
In the cable tray hanger results report, TENERA combined these concerns into the 10 primary issues that follow.
i t
l (1) effects of design change documents g
(2) vertical and transverse loads on longitudinal supports (3) evaluation of connections, base angles and anchor bolts 1
]
(4) modeling assumptions i
(5) support component governing design (6) working point location for two-bolt brace connections (7) arbitrarily allowed working point deviations (8) working point deviations by similarity (9) use of enveloping cases (10) compressive load capacity of members These issues are discussed under a single subissue.
12.1 Consideration of Working Foint Deviation Study This issue is discussed in the cable tray hanger results report (Section 3.2.7.12).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Su' appendix A12).
The DAP evaluation is sum-o j
mariled in the cable tray hanger results report (Section 3.2.7.12).
The Working Point Deviat%n Study was performed as part of the initial design 1
effort by Gibbs & Hill te justify generic design configurations.
Because neither l
Ebasco nor Impell used the results of this study (instead, a complete as-built walkdown was performed to obtain the installed configurations of all cable tray i
hangers), this issue is not directly applicable to the TV Electric Corrective Action Program design validation efforts.
Nonetheless, the methods proposed by i
Ebasco and Impell for ensuring that the issues raised in the Working Point Deviation Study are not applicable to the design validation effort were reviewed under the OAP and found to address the generic aspect of all concerns adequately.
1 l
The staff concludes that the use of Ebasco's and Impell's design validation procedures which do not rely on the Gibb5 & Hill Working Point Deviation Study 4
and the DAP review of the applicability of the issues to the design validation i
procedures provide un ar' equate basis to resolve the concerns identified with this issue and are, tNs, acceptable.
]
CYGNA's review of the wolution of this issue clnsed the issue in Revision 15 to CYGNA's review issues i ?.t for cable tray hangers (Reference A4, Issue No. 12).
4 i
Comanche Peak SSER 15 44 Appendix A i
1
~. _. _, _
~
)
12.2 Conclusions
-.Considering this evaluation, the staff concludes that the concerns associated.
with the Gibbs & Hill Working Point Deviation Study have been adequately re-solved.'. The cable tray hanger technical issue concerning the Working Point Deviation Study is, therefore, closed for CPSES..
l l
l l
h t
i J
j 9
1 1
l i
~
I s-i i
i I
i Comanche Peak SSER 15 45 Appendix A i
13 REDtiCED SPECTRA! ACCELERATIONS
-In the initial design of certain cable tray supports, Gibbs & Hill used reduced r
spectral accelerations (i.e., accelerations less than the peak of the governing seismic design response spectrum) based on assumed cable tray system weights and geometries.
A general concern was raised that the assumed cable tray sys-tem weights and geometries did not represent cable tray installations at CPSES.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified four related issues from various source j
documents.
In the cable tray hanger results report, TENERA combined these concerns into three primary issues which could affect the calculation of the cable tray system frequency used to select the design spectrum acceleration; the issues are (1) tray weight and span, (2) axial tray flexibility and eccentrici-ties, and (3) flexibility of base angles.
These issues a)e discussed under a single subissue.
The relevant project documents and the corresponding CPRT third party review
]
documents for this issue follow.
Project Document
- CPRT Review Document
- i (Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-120 l
SAG.CP4 DAP-CLC-C/S-204 4
DAP-E-C/S-120 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 SAG.CP34 (Attach. G-8 & G-9)
DAP-E-C/S-139 Vol. I, Book 2 DAP-E-C/S-112 Vol. I, Book 7 DAP-E-C/S-109 j
Vol. I, Book 12 DAP-E-C/S-139 (Impell) i PI-02 DAP-CLC-C/S-404 M-04 DAP-E-C/S-139 13.1 Tray Design Considerations and Base Angle Flexibilities This issue is described in the cable tray hanger results report (Section 3.2.7.13).
The Ebasco and Impell resolutions of this issue are provided in i
i
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
4 Comanche Peak SSER 15 46 Appendix A
the cable tray hanger project status report (Subappendix A13).
The DAP eval-uation is summarized in the cable tray hanger results report (Section 3.2.7.13).
The primary concern related to this issue was that the weight and geometry of the cable tray contents and the base angle flexibilities which were not properly considered could result in an erroneous calculation of the system frequency.
For Unit 1 cable tray systems, Ebasco and Impell used as-built tray weights and as-built span lengths to determine response of transverse supports.
For Unit 2 cable tray systems, Ebasco used as-built span lengths and full-tray design weight (including fireproofing when applicable) to determine transverse support response.
Ebasco and Impell included the effects of tray flexibility in calculations of longitudinal support response, and modeled eccentricities between trays and supports, when such eccentricities were significant for design validation.
In addition, Ebasco and Impell included base angle flexibility in calculations of longitudinal support response.
The CPRT third party review of Ebasco's and Impell's design validation pro-cedures (SAG.CP3, SAG.CP4, SAG.CP34, and PI-02) confirmed that as-built weight and geometry are adequately prescribed for design validation of cable tray systems.
In addition, special studies (Ebasco, Vol. I, Books 2, 7, and 12, and Impell, M-04) were reviewed to verify the methods for considering (1) tray weight and span, (2) axial tray frequency and eccentricities, and (3) flexi-bility of base angles.
The CPRT third party confirmed that Ebasco and Impell used as-built weight (design weight in Unit 2) and as-built geometry for design validation of transverse supports.
The CPRT third party concluded that Ebasco's and Impell's design validation procedures and modeling techniques adequately considered the axial stiffness of tray and the eccentricity between trays and supports in design validation of longitudinal supports.
In addition, the third party found the flexucal stiffness of base angle was adequately considered in the design validation of longitudinal supports.
The staff concludes that the inclusion of appropriate input design data and the assumptions used in seismic analysis methods in Ebasco and Impell design validation procedures and the use of as-built cable tray hanger properties in the design validation provide an adequate basis for resolving the concerns identified in this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue j
Nos. 13A, 13B, and 13C).
13.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with the method used to determine seismic response spectrum acceleration values have been adequately resolved.
The (.able tray hanger technical issue concern-l ing reduced spectral accelerations is, therefore, closed for CPSES.
Comanche Peak SSER 15 47 Appendix A
14 NONCONFORMANCE WITH AISC SPECIFICATIONS i
Concerns were raised that the initial design of CPSES cable tray supports did not conform to certain requirements of the AISC code (Reference A7) with re-spect to slenderness ratio'and unbraced length of compression members, section property reduction due to bolt holes, connection eccentricities, oversized bolt holes, and bracing members.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified 13 related issues from various source docu-ments.
In the cable tray hanger results report, TENERA combined these concerns into the seven primary issues that follow.
(1) slenderness ratio (2) unbraced length (3) section property reduction due to bolt holes -
(4) composite compression members without lacing (5) connection eccentricities (6) oversized bolt holes i
(7) bracing members 1
l The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
a f
Project Document
- CPRT Review Document
- i (Ebasco)
SAG.CP3 DAP-CLC-C/5-204 DAP-E-C/S-120 SAG.CP4 OAP-CLC-C/S-204 i
DAP-E-C/S-120 SAG.CP19 DAP-E-C/5-124 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 SAG.CP34 (Attach. E)
DAP-E-C/S-153 Vol. I, Book 13 DAP-E-C/5-121 Paper on bolt hole oversize DAP-E-C/S-183 Paper on anchor bolt hole interaction ratio inventory DAP-E-C/S-183 (Impell)
PI-02 DAP-CLC-C/S-404
- All relevant project and CPRT third party documents are listed in Appendix E i
i to this supplement.
l Comanche Peak SSER 15 48 Appendix A l
Project Document
- CPRT Review Document
- PI-03 DAP-CLC-C/S-404 PI-06 DAP-CLC-C/S-404 i
DAP-E-C/S-124 PI-11 DAP-E-C/S-170 M-51 DAP-E-C/S-124 M-73 DAP-E-C/5-183 Report No. 09-0210-0017 DAP-E-C/S-147 (Test Laboratory)
ANCO Document No. A-000181 DAP-E-C/S-146 CCL Procedure No. 1903.22-1 DAP-E-C/S-130 1
CCL Report No. A-717-86 DAP-E-C/S-133 14.1 Slenderness Ratio This issue is discussed in the cable tray hanger results report (Sections 3.2.7.4 and 3.2.7.14).
The Ebasco and Impell resolutions of this issue are provided in
~
the cable tray hanger project status report (Subappendices A4 and A14).
The DAP evaluation is summarized in the cable tray hanger results report (Sec-tion 3.2.7.4).
The staff evaluated this issue in Section 4.1 of this appendix.
14.2 Unbraced Length This issue is discussed in the cable tray hanger results report (Section 3.2.7.14).
The Ebasco and Impe11 resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A14).
The DAP evaluation is sum-marized in the cable tray hanger results report (Section 3.2.7.14).
In its IAP, CYGNA identified concerns that in the initial designs of cable tray hangers, the determination of the unbraced member length - when checking the allowable bending stress as specified in the AISC specification (Reference A7),
Equation 1.5 was inappropriate.
Ebasco and Impell validated the design of the cable tray supports in accordance with Equation 1.5-7 of the AISC specification, which requires that allowable flexural stress be determined on the basis of the unbraced length of the com-pression flange.
- All relevant project and CPRT third party documents are listed in Appendix E i
i to this supplement.
2 Comanche Peak SSER 15 49 Appendix A
,.. _ _,. ~,
Ebasco and Impell considered the unbraced length of the compression flange of trapeze support posts to be the distance from the face of the concrete to the centerline of the first tier and the distance between centerlines of adjacent tiers for other support levels.
For L-shaped hangers, tier-to-tier distance was considered only between tiers supporting a tray.
Unbraced length used for the design validation of cantilever supports are described in Section 4.3 of this appendix.
The DAP review confirmed that Ebasco's and Impell's design validation procedures (SAG.CP34, PI-03, and PI-11) require the use of Equation 1.5-7 of the AISC spec-ification to determine the allowable flexural stress as a function of unbraced length of the compression flange.
The DAP evaluation included the review of the method for determining the unbraced lengths (e.g., distance between tiers for trapeze hanger posts) used by Ebasco and Impell to determine allowable flexural stress and found it to be acceptable.
The staff concludes that the inclusion of appropriate guidelines to satisfy the requirements of the AISC specification regarding the determination of allowable flexural stress as a function of unbraced compression flange length in Ebasto's and Impell's design validation procedures provides an adequate basis for resolv-ing the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 14B).
14.3 Section Property Reduction Oue to Bolt Holes This issue is discussed in the cable tray hanger results report (Sections 3.2.7.9 and 3.2.7.14).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendices A9 and A14).
The OAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.9).
~
The staff evaluated this is Lue in Section 9.1 of this appendix.
14.4 Composite Compression Members Without Lacing This issue is discussed in the cable tray hanger results report (Sections J.2.7.7 and 3.2.7.14).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendices A7 and A14).
fne OAP evaluation is summarized in the cable tray hanger results report (Section 4
3.2.7.7).
The staff evaluated this issue in Section 7.1 of this appendix.
14.5 Connection Eccentricities This issue is discussed in the cable tray hanger results report (Sections 3.2.7.7, 3.2.7.14, and 3.2.7.16).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendices A7, A14, 4
4 4
9' Comanche Peak SSER 15 50 Appendix A
h and A16).
The DAP evaluation is summarized in the cable tray hanger results report (Sections 3.2.7.7 and 3.2.7.16).
The staff evaluated this issue in Sections 7.1, 7.2, and 16.1 of this appendix.
14.6 Oversized Bolt Holes This issue is discussed in the cable tray hanger results report (Sections 3.2.7.14 and 3.2.7.31).
The Ebasco and Impell resoluttons of this issue are provided in the cable tray hanger project stctus report (Subappendices A14 and A31).
The DAP evaluation is summarized in the cable tray hanger results report (Sec-tions 3.2.7.14 and 3.2.7.31).
In its IAP, CYGNA identified a concern regarding ovcrsized bolt holes in cable tray supports.
The AISC code (P.eference A7} specifies that bolt holes be 1/16 inch larger than the nominal bole diameter.
It also specifies that bolt holes for anchor bolts in base plates / angles and for tray clamps be 1/8 inch larger than the nominal bolt diameter.
The effects of oversized bolt holes have been evaluated by Ebasco and Impell through the use of analytical methods at.d test data.
This evaluation has con-firmed that the methodology used in the design validation is adequate.
Impell Report No. 09-0210-0017 and ANC0 tests (A-000181) have shown that oversized bolt holes had an insignificant effect c6 the dynamic characteristics and seis-mic response of the cable tray system.
Ic was demonstrated that the same modeling procedure was appropriate whether or not oversized bolt holes were present.
Impell calculation M-73 and Ebasco study, "Effect of Bolt Hole Over-size on CTH System Adequacy," demonstrate that anchorage design margin is not significantly affected by the presence of oversized bolt holes.
The DAP review of tray clamp tests (CCL, Procedure No. 1903.22-1 and Report No. A-717-86) confirmed that results of the tests are valid and representative of as-built conditions, including oversizing of bolt holes.
The DAP review of Ebasco's and Impell's design validation procedures (SAG.CP19 and PI-06) con-firmed that the test results are properly incorporated in the qualification of tray clamps.
The DAP review of Ebasco's and Impell's design validation proce-dures and related special studies (Vol. I, Book 13; PI-06; and M-51) concluded that flanges of hanger tiers are adequately checked for reduction in tear-out capacity due to oversizing of clamp bolt holes.
The DAP review findings agreed with the findings of Ebasco's and Impell's special studies (Ebasco study, "Effect on Colt Hole Oversize on CTH System l
Adequacy," and "CTH Anchor Bolt vle Interaction Ratio Inventory," and Impell's l
calculation M-73) which concluded that the effects of oversized bolt holes can l
be ignored in the design validation of base angles and base plates of cable l
tray scoports.
l The staff concludes that Ebasco's and Impell's special studies and tests, found l
acceptable by the DAP review, which demonstrate that there is no adverse effect of bolt hole oversize in cable tray hangers at CPSES provide an adequate basis to resolve the concerns raised in this issue and are, thus, acceptable.
The staff review and evaluatinn of oversized bolt holes are further discussed in Section 4.1.1.4 of this supplement.
Comanche Peax SSER 15 51 Appendix A
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 14F).
14.7 Bracing Members s
This issue is discussed in the cable tray hangers results report (Section 3.2.7.14).
The Ebasco and Impell resolutions of this issue are piovided in the cable tray hanger project status report (Subappendix A14).
The DAP evaluation is sum-marized in the cable tray hanger results report (Section 3.2.7.14).
In its IAP, CYGNA identified a concern that in the initial design by Gibbs &
Hill of a cable tray hanger,'a longitudinal brace was designed as secondary member, whereas its function would require it to be designed as a primary mem-ber.
To resolve this issue, Ebasco and Impell established guidelines in their design validation procedures (SAG.CP3 and PI-03) which require that all bracing members be validated using AISC specification (Reference A7) primary member allowable stresses.
The OAP review of the Ebasco and Impell design validation procedures confirmed that Ebasco and Impell require all bracing members to be evaluated as primary members.
l l
d The staff concluor.
"at the inclusion of guidelines requiring all bracing l
l members to be evaluated as primary members in Ebasco's and Impell's design validation procedures provides an adequate basis to resolve the concerns raised
(
in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue t
i No. 14G).
14.8 Conclusiong Considering these evaluations, the staff concludes that the concerns associated with nonconformance with the AISC specification have been adequately resolved.
The cable tray hanger technical issue concerning nonconformance with the AISC specification is, therefore, closed for CPSES.
i i
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i Comanche Peak SSER 15 52 Appendix A
15 MEMBER SUBSTITUTION A concern was raised by CYGHA in its IAP regarding the initial Gibbs & Hill design specification for cable tray supports which allowed substitution of structural members with larger members having potentially lower section moduli without adequate documentation of these substitutions.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequcy Program (DAP), identified two related issues from various source l
documents.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP34 DAP-CLC-C/S-204 (Impell)
PI-11 DAP-E-C/S-170 15.1 Member Design Considerations TM issue is c;escribed in the cable tray hanger results report (Section 3.2.7.15).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A15).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.15).
The CYGNA review found that the Gibbs & Hill design specification allowed structural members for cable tray hangers to have substituted for them struc-tural members heavier than, but of the same depth as, the member shown on the design drawings.
This variance would allow substitute members to be installed that are heavier but that have a lower section modulus.
CYGNA's walkdown veri-fled that this substitution had been made and that no requirements existed for documenting member substitutions.
The Ebasco and Impell resolutions involved a complete as-built walkdown of all cable tray hangers in CPSES to ensure that design drawings existed for each cable tray hanger and accurately represented the installed configurations.
The Ebasco and Impell cable tray hanger design validation procedures (SAG.CP34 and PI-11) require the use of as-built information for design validation.
In addition, an engineering study was performed (Ebasco, Vol. I, Book 18) which determined the acceptability of using the as-designed member size when the as-built size could not be ascertained.
The results of the study were incor-porated in the design validation procedures.
Member substitutions are
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
4 Comanche Peak SSER 15 53 Appendix A
accounted for in these procedures by considering the potential substitution of a member one step heavier with a reduced section modulus.
The CPRT third party review of as-built precedures, including the determination of properties for inaccessible attributes, confirmed that appropriate member sizes are documented on the design drawings.
The staff concludes that the use of verified as-built properties for cable _ tray members and the approach used for addressing inaccessible cable tray member sizes in the design validation effort provides an adequate basis to resolve the 4
concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issuas list for cable tray hangers (Reference A4, Issue No. 15).
4 15.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with member substitutions which were previously allowed at CPSES have been adequately resolved.
The cable tray hanger technical issue concerning member substitutions is, therefore, closed for CPSES.
1 e
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i Comanche Peak SSER 15 54 Appendix A
i 16 WELD DESIGN AND SPECIFICATIONS i
Concerns were raised about certain discrepancies in Gibbs & Hill's design of cable tray support welds with regard to weld details and sizes, eccentric con-nections, base metal thickness, and minimum weld length.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified 12 related issues from various source docu-i ments.
In the cable tray hanger results-report,.TENERA combined these concerns into the five primary issues that follow.
(1) weld details (2) weld sizes (3) eccentric connections (4) base metal thickness (5) minimum weld length These five issues are discussed in the three subissues that follow.
The relevant project documents and the corresponding CPRT third party review t
documents for this issue follow.
Project Document
- CPRT Review Document
- 3 (Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-120 t
SAG.CP4 DAP-CLC-C/S-204 t
DAP-E-C/S-120 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 i
j (Impell)
PI-03 DAP-CLC-C/S-404 M-12 DAP-E-C/S-115 i
(TV Electric)
TE-FVM-C/S-001 DAP-E-C/S-102 TE-FVM-C/S-003 DAP-E-C/S-123 16.1 Weld Details, Weld Sizes, and Minimum Weld Length The issue is described in the cable tray hanger results report (Section 3.2.7 16).
The Ebasco and Impe11 resolutions of tt.is issue are provided in
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
I Comanche Peak SSER 15 55 Appendix A L
2 i
the cable tray hanger project status report (Subappendix A16).
The DAP evalu-ation is summarized in the cable tray hanger results report (Section 3.2.7.16).
In its IAP, CYGNA identified several concerns related to weld details, weld sizes, and minimum weld length.
Specifically', CYGNA found that the design drawings were missing wsid details for several support types, the weld sizes shown on the assembly drawings differed from those shown on the design drawings and from those assumed in the design calculations, anJ the~ design calculations assumed an incorrect minimum weld length from the beam / hanger base angle connection.
To resolve these concerns, Ebasco and Impell validated the design of all cable tray hanger welds using as-built weld data as required in procedures SAG.CP4, i
SAG.CP34, and PI-03.
As-built hanger drawings have been developed for each cable tray hanger which provide weld details, weld sizes, and weld length.
The DAP review of as-built procedures (TV Electric. TE-FVM-C/S-001 and TE-FVM-C/S-003) and Ebasco's and Impell's design validation procedures confirmed that the designs of walds are properly validated using as-built data.
The DAP review confirmed that as-built procedures require the documentation of all weld attributes necessary for design validation (e.g., weld size, length, thickness, and geometry).
The DAP review concluded that the concerns regarding weld de-e tails and dimensions are adequately addressed by validating welds using as-built properties.
The staff concludes that the development and use of as-built design drawings for the design validation of cable tray hanger welds as specified in the i
Ebasco and Impell procedures provide an adequate basis to resolve the concerns raised in this issue, and are, thus, acceptable.
l CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA': review issues list for cable tray hangers (Reference A4, Issue Nos. 16A, dB, 16E, 16F, 16G, 16H, and 161).
16.2 Eccentric Connections Tnis issue is discussed in the cable tray hanger results report (Section 3.2.7.16).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A16).
The DAP evaluation 1
is summarized in the cable tray hanger results report (Section 3.2.7.16).
In 2
its IAP, CYGNA raised a concern that the load eccentricities were not consid-ered in the design of welds for brace / gusset plate / base connections, lap joints between channels, and base angle connections.
The Ebasco and Impell resolutions consisted of developing guidelines in their design niidation procedures (SAG.CP3, SAG.CP4, SAG.CP34, and PI-03) to address load eccentricities in the design of welds.
Impell's approach to neglect load eccentricity effects on certain connections was ju:tified by an engineering study (M-12) using as-built data which demonstrated that the effects of eccentric loads on welds are insignificant.
]
The DAP review of Ebasco's and Ir;:dl's procedures, related studies, and se-l lected calculations confirmed that welds are adequately design validated for loading eccentricities when such eccentricities are significant.
Review of 1
I Comanche Peak SSER 15 56 Appendix A a
I
.I
selected Ebasco calculations (DAP-E-C/S-187) found that eccentricities are ex-plicitly considered in determining loads on welds.
Review of Impell's design validation procedures found that load eccentricities are explicitly considered in the design validation of gusset plate welds and base connection welds.
On the basis of the results of Impell's study M-12, the DAP review also found that the effects of load eccentricities are insignificant and can be ignored in the design validation of lap joints (e.g., ticr-to post welds).
The staff concludes that the inclusion of detailed guidelines to evaluate eccentricity effects on welds in the Ebasco design validation procedure and the justification to neglect the load eccentricities contained in the Impell study 1
provide an adequate basis to resolve the concerns identified in this issue, and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 16C).
16.3 Base Metal Thickness This issue is described in the cable tray hanger results report (Section 3.2.7.16).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A16).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.16).
In its IAP, CYGNA identified a concern that the weld designs did not consider the thickness of the connected parts.
Fillet welc'; with throat dimension a
greater than the connected plate dimension were specified.
Ebasco and Impell, in their resolutions of this issue, developed guidelines in j
their design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, and PI-03) j which require appropriate considerations of base metal thickness in accordance with the AISC specification (Reference A7).
The DAP review of Ebasco's and Impell's design validation procedures confirmed that the base material thickness is adequately considered when checking stress in welds.
The staff concludes that the inclusion of guidelines that consider the thick-I ness of connected parts and satisfy the AISC specification in Ebasco's and Impell's procedures for the design validation of welds provides an acceptable basis to resolve the concerns identified in this issue, and is, thus, acceptable.
)
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 160).
16.4 Conclusions l
Considering these evaluations, the staff concludes that the concerns associated with the design of welds in cable tray hangers have been adequately resolved.
The cable tray hanger technical issue concerning weld design and specifications is, therefore, closed for CPSES.
Comanche Peak SSER 15 57 Appendix A
17 EMBEDDED PLATE DESIGN This issue addresses concerns raised regarding certain aspects of Gibbs &
Hill's design procedures for embedded plates.
The CPRT third party revi(wer (TENERA, L.P.), in conjunction with the Design Adequacy Program (OAP), identified eight related issues from various source-documents.
In the cable tray hanger results report, TENERA combined these concerns into the six primary issues that follow.
1 (1) prying action (2) stiffening criteria (3) capacity reduction J
(4) separation criteria (5) tributary span (6) expansion anchors These six issues are discussed under the single subissue that follows.
4 i
The relevant project documents and the corresponding CPRT third party review l
documents for this issue follow.
r a
l Project Document
- CPRT Review Document *
(TV Electric) l TE-FVM-C/S-001 DAP-E-C/S-102 TE-FVM-C/5-003 DAP-E-C/S-123 17.1 Desian Considerations for Embedded Plates i
This issue is discussed in the cable tray hanger results report (Section 3.2.7.17).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A17).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.17).
In its IAP, CYGNA identified a concern that the Gibbs & Hill design calcula-tions qualified an embedded plate on the basis of a tributary cable tray span of 7'-6", whereas the design drawings allowed spans up to 9'-0".
The responsibility for addressing tha concerns raised in this issue, with the exception of tributary spans, has been assigned to the civil / structural area of the Corrective Action Program.
The staff evaluation of this issue will be performed in conjunction with its review of the civil / structural CAP.
i The issue of tributary spans is addressed in the design validation effort by the use of as-built cable tray spans in the design validation of all cable tray systems at CPSES.
The ar-built procedures (TV Electric, TE-FVM-C/S-001 and
- All relevant project ar.d CPRT third party documents are listed in Appendix C to this supplement, i
Comanche Peak SSER 15 58 Appendix A 1
TE-FVM-C/S-003) were reviewed under the DAP and were found to contain adequate requirements for determining tray span length.
The staff concludes that the use of as-built design drawings in the design validation of the cable tray systems at CPSES provides an adequate basis to resolve the concerns identified ip this issue, and is, thus, accepteble.
CYGNA's review of the resolution of this issue closed the issue as documented in Refererce A12.
17.2 Crnclusions Concern!.7g this evaluation, the staff concludes that the concerns associated with tributary spans have been adequately-resolved.
The design of embedded plates will be discussed by the staff in conjunction with its evaluation of the civil / structural area of the Corrective Action Program, i
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Comanche Peak SSER 15 59 Appendix A l
J
1 18 CABLE TRAY CLAMPS Concerns were raised by CYGNA about the assumptions used by Gibbs & Hill to model load transfer between cable trays and supports at friction-type clamps.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified four related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP9 DAP-CLC-C/S-204 SAG.CP11 DAP-E-C/S-169 SAG.CP19 DAP-E-C/S-124 SAG.CP34 DAP-CLC-C/S-204 (Impell)
PI-02 DAP-CLC-C/S-404 M-10 DAP-E-C/S-110 M-19 DAP-E-C/S-110 Report No. 09-0210-0017 DAP-E-C/S-147 (Test Laboratory)
ANC0 Document No. A-000181 DAP-E-C/S-146 18.1 Design Considerations for Cable Tray Clamps This issue is discussed in the cable tray hanger results report (Section 3.2 7.18).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A18).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.18).
In its IAP, CYGNA raised several questions regarding the Gibbs & Hill assump-tions that cable trays provide bracing to cable tray hangers.
The assumptions are valid only if the clamps can provide suitable displacement and rotation compatibility between the tray and support beam.
To provide the assumed com-patibility, friction-type clamps must be cinched sufficiently enough so that
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 60 Appendix A
friction develops between the tray / beam and tray / clamp interfaces.
Installa-tion gaps may preclude the development of the normal contact force required for i
friction resistance, and thus may prevent the cable trays from providing i
bracing for the cable tray hangers.
l Full-scale dynamic tests of cable tray systems were performed (ANC0, Document No. A-000181) to evaluate experimentally the capacity of friction-type clamps to transfer force between trays and supports.
Subsequently, Impell performed special studies (M-10, M-19, and Report No. 09-0210-0017) to evaluate the tests and to correlate test results with various analytical modeling assumptions.
Considering the test results and correlation studies, Ebasco and Impell have i
developed tray clamp modeling procedures (SAG.CP11, SAG.CP19, SAG.CP34, and PI-02) that assume that friction-type clamps transmit force between the tray and the support in all directions.
The DAP review of the results of full-scale dynamic tests of cable tray systems 1
(ANC0, Document No. A-000181) found the relative longitudinal slip between the tray and the beam at the transverse supports to be small, even when installa-i tion gaps between clamps and tray were deliberately incorporated into the test specimens.
The OAP review of Impell Report No. 09-0210-0017 found that dis-placements obtained from the tull-scale dynamic tests were, in general, en-veloped by displacements predicted by analyses that assumed trays to be con-nected to supports in all directions.
On the basis of the results of the tests and the correlation studies, the DAP review concluded that friction-type clamps may be assumed to transmit force parallel to the axis of the tray and found that these clamps are appropriately modeled as such.
]
The staff concludes that the performance of full-scale dynamic tests of cable i
tray systems to confirm the tray clamp modeling assumptions used in the design validation of cable tray systems and the test results found acceptable by the DAP review provide an adequate basis to resolve the concerns identified in this issue, and are, thus, acceptable.
The staff review and evaluation of the test results which demonstrate that trays provide bracing to cable tray hanger arc j
discussed in Section 4.1.1.4 of this supple.nent.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 18).
1 1
18.2 Conclusions l
Considering this evaluation, the staff concludes that the concerns associated j
with load transfer between the cable tray and supports have been adequately resolved.
The cable tray hanger technical issue concerning cable tray clamps is, therefore, closed for CPSES.
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j Comanche Peak SSER 15 61 Appendix A l
t 19 FINAL SAFETY ANALYSIS REPORT (FSAR) LOAD COMBINATION For cable tray systems installed in the CPSES reactor building, the loadings associated with a loss-of-coolant accident (LOCA) may be applicable, ir.cluding
~
pipe-whip, jet impingement, and thermal loads.
A concern was raised that Gibbs
& Hill considered only deadweight and seismic inertia load in the initial design of cable tray supports.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified three related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project document and the corresponding CPRT third party review document for this issue follow.
Project Docurent*
CPRT Review Document *
(Impell)
M-27 DAP-E-C/S-119 19.1 Loss-of-Coolant-Accident (LOCA) Design Leadings This issue is discussed in the cable tray hanger results report (Section 3.2.7.19).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A19).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.19).
Several concerns were identified regarding tne applicable loadings which are required to be evaluated as a result of a LOCA.
The TV Electric Systems Interaction Program under the mechanical area of the Corrective Action Program has the responsibility of demonstrating that safety-related cable trays are either shielded from, or not in the path of, pipe-whip and jet impingement loads postulated by the FSAR.
Tne staff will evaluate the Systems Interaction Program in conjunction with its evaluation of the mechanical area under the CAP.
The FSAR states that thermal loads may be neglected when they are secondary and self-limiting and the material is ductile.
Impell verified in study M-27 that these conditions are applicable to cable tray systems.
Thus, Ebasco and Impell do not explicitly analyze cable tray systems for LOCA thermal loads in the design validation.
1 The DAP review of this issue concluded that thermal loads under accident condi-i tions are not applicable to cable tray systems that possess the capacity to absorb thermal movements without brittle failure of their components, and that l
Impell study M-27 provides adequate validation that thermal growth will not cause brittle failure of cable tray system anchorages.
l I
]
- All relevant project and CPRT third party documents are listed in Appendix E I
to this supplement.
l Comanche Peak SSER 15 62 Appendix A
. =.
The staff concludes that because the DAP review finds Impell's special study
_ acceptable (confirming that LOCA thermal loads will not cause cable tray systems inside the CPSES reactor building to collapse), an adequate basis exists for resolving the concerns identified in this issue.
The staff review and evalua--
i tion of the LOCA thermal load effects are discussed further in Section 4.1.1.1 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 19).
19.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with LOCA thermal load effects on cable tray systems have been adequately resolved.
The cable tray' hanger technical issue concerning FSAR loed combina-l tions with regard to LOCA thermal loads is, therefore, closed for CPSES.
I I
a i
I l
t i
l 1
1 4
Comanche Peak SSER 15 63 Appendix A i
i
..-I
4 L
I 20 DIFFERENCES BETWEEN THE INSTALLATION AND THE DESIGN / CONSTRUCTION ORAWINGS 1
l WITHOUT APPROPRIATE DOCUMENTATION 1
l CYGNA's walkdown of cable tray supports raised concerns regarding certain s
differences between the as-built support. configurations and Gibbs & Hill's j
1 l
design documents, i
j The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design l
4 Adequacy Program (OAP), identified 15 related issues from various source docu-i i
ments.
In the cable tray hanger results report, TENERA combined these concerns into (1) differences between installation and design drawings, (2) expansion f
anchor embedment, and (3) minimum separation between cable tray systems.
{
l These three issues are discussed undar a single subissue.
5 i
The relevant project documents and the corresponding CPRT third-party review documents for this issue follow.
Project Document
- CPRT Review Document
- l (Ebasco)
SAG.CP3 OAP-CLC-C/S-204 OAP-E-C/S-120 a
SAG.CP4 DAP-CLC-C/S-204 i
DAP-E-C/5-120 j
(Impell) l PI-02 DAP-CLC-C/S-404 j
(TV Electric) j I
l TE-FVM-C/S-001 OAP-E-C/5-102 i
i i
TE-FVM-C/S-003 OAP-E-C/S-123 l
i 20.1 Consideration of As-Built Differences
]
This issue is discussed in the cable tray hanger results report (Section 3.2.7.20).
I The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A20).
The OAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.20).
4 j
In its IAP, CYGNA identified several construction-related concerns regarding differences between installation and design drawings, expansion anchor embed-1 ment in floor slabs with 2-inch topping, and minimum separation between cable trays and other components.
J l
l l
- All relevant project and CPRT third-party documents are listed in Appendix E to this supplement, i
Comanche Peak SSER 15 64 Appendix A
I i
The design validation of cable trays and cable tray hangers is based on as-built data developed by Ebasco and Impell and used in Ebasco and Impell proce-
~
dures (TV Electric TE-FVM-C/S-001 and TE-FVM-C/S-003; Ebasco, SAG.CP3 and i
SAG.CP4; and Impell, PI-02) thus resolving the issue of discrepancies between l
l as-built hanger configurations and hanger design documentation.
In addition, l
clearance requirements between cable tray hangers and other plant components are being addressed in the mechanical area of the Corrective Action Program j
(CAP) under the Post-Construction Hardware Validation Program (PCHVP)
(References A10 and All).
Any clearance discrepancies identified for cable tray and cable tray hangers were resolved by Impell and Ebasco.
The as-built procedures were reviewed by TENERA and were found to be adequate i
for design validation.
In addition, TENERA found that Ebasco's and Impell's design validation procedures conservatively excluded the 2-inch topping to deter-mine the appropriate embedment length for anchor bolts and, thus, no structural credit is taken for the 2-inch topping, p
I The staff concludes that the use of as-built data in design validation of i
cable tray system components provides an adequate basis to resolve the' concerns raised by this issue (with the exception of minimui separation, which will be addressed by the staff in its supplement to the Safety Evaluation Report on the civil / structural area of the CAP) and is, thus, acceptable.
i CYGNA's review of the resolution of this issue closed the issue in Revision 15 i
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue I
No. 20).
s 20.2 Conclusions l
j Considering this evaluation, the staff concludes that the concerns associated with differences between installation and design drawings for cable tray r
]
hangers have been adequately resolved.
The cable tray hanger technical issue l
concerning differences between the installation and the design / construction drawings without appropriate documentation is, therefore, closed for CPSES.
j i
1 1
i i
1 l
1
]
Comanche Peak SSER 15 65 Appendix A l
4
=
i 4
i i
21 DESIGN CONTROL t
i Numerous concerns were raised regarding control of design changes -validation of as-built conditions, adequacy of design criteria, and evaluation of supports i
with fire protection material (Thermo-Lag).
The CPRT third party (TENERA, l
L.P.), in conjunction with the Design Adequacy Program (DAP), identified 22-l s
related concerns from various source documents which were grouped into four l
j primary issues:
(
)
(1) design changes and as-built conditions (2) evaluation of supports with Thermo-Lag 4
(3) design control and quality assurance procedures (4) design criteria consistency with FSAR i
l I
i The relevant project documents and the corresponding CPRT third party review t
i documents for this issue follow.
1 t
Project Document
- CPRT Review Dacument*
l (Ebasco) 1:
SAG.CP3 DAP-CLC-C/S-204
)
i DAP-E-C/S-120 i
SAG.CP4 DAP-CLC-C/S-204 I
DAP-E-C/S-120 1
SAG.CP34 DAP-CLC-C/S-204 i
(Impell)
PI-02 DAP-CLC-C/S-404 i
i i
]
PI-03 DAP-CLC-C/S-404 l
1 l
M-39 DAP-E-C/S-122 j
(TV Electric)
TE-FVM-C/S-001 DAP-E-C/S-102 TE-FVM-C/S-003 DAP-E-C/S-123 r
TE-fVM-C/S-019 OAP-E-C/S-123 i
i i
21.1 Design Changes and As-Built Conditions i
This issue it, described in Section 3.2.7.21 of the cable tray hanger results j
report.
The Ebasco and Impell resolution methodologies and corrective actions J
- All relevant project and CPRT third-party documents are listed in Appendix E to this supplement.
i
{
Comanche Peak SSER 15 66 Appendix A i
r l
l are presented in Sub ppendix A21 of the cable tray hanger project status report.
The third party evaluation is summarized in Section 3.2.7.21 of the i
cable tray hanger results report.
i Identified as concerns were that design changes for cable tray supports were not adequately controlled, documented, and validated.
In addition, design and installation tolerances, including support geometry, loadings, and span lengths, were violated in some cases.
Ebasco and Impell resolved this issue by using reverified as-built information in the design validation of individual cable tray supports.
The Ebasco and Impell design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, PI-02, and PI-03) require that as-built information obtained using walkdown procedures (TV Electrit., TE-FVM-C/S-001, TE-FVM-C/S-003, TE-FVM-C/S-019, TE-FVM-C/S-036, and TE-FVM-C/S-048) be used as design input.
TENERA concluded that the Ebasco and Impell design validation procedures, using as-built information, adequately 4
address the concerns raised by the issue.
The staff cont.ludes that the design validation of individual cable tray hangers using as-built data as specified in Ebasco and Impell procedures provides an adequate basis to resolve the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 l
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
Nos. 21A, 21B, 21C, 21E, 21F, and 211).
21.2 Evaluation of Supports With Thermo-Lag This issue is described in Section 3.2.7.21 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A21 af the cable tray hanger project status report.
i The CPRT third party evaluation is summarized in Section 3.2.7.21 of the cable tray hanger results report.
I Identified as concerns were that in the evaluation of cable tray systems with Thermo-Lag fire protection (1) tray cover weights were not considered (2) fire-i protection (Thermo-Lag) weight was not considered in longitudinal support I
analysis. (3) tray spans with excessive tray weight were not evaluated as required, and (4) side rail extensions were not specifically evaluated.
Ebasco and Impell resolved this issue by including the weight of Thermo-Lag and tray covers in their design validation procedures (SAG.CP3, SAG.CP4, SAG.CP34, and PI-02) for cable trays and supports unless as-built information showed that Therme lag or covers were not present.
Cable tray fill weight was based on the i
actual cable tray fill for Unit 1, and was taken as the full design weight for Unit 2.
Ebasco includeri side rail extension weights in its cable tray qualifi-cation without taking a n structural credit.
Impell excluded the we'ght of the side rail extensions based on the special study (M-39) which justifies this
- approach, 1
Comanche Peak SSER 15 67 Appendix A
l TENERA, as the third party reviewer, confirmed that the Ebasco and Impell design validation procedures and studies were adequate to ensure that weights due to Thermo-Lag, cable fill, and tray components were included in the design valida-i tion of cable trays and supports or that any exclusion was adequately justified.
The staff concludes that the inclusion of guidelines for evaluating the effects of the Thermo-Lag weight and cable fill in the Ebasco and Impell design valida-tion procedures and the special studies that justify the effect on cable tray 1
side rail extensions provide an adequate basis to resolve the concerns identified in this issue, and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
No. 210).
21.3 Design control and Quality Assurance Procedures This issue is described in Section 3.2.7.21 of the cable tray hanger results report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A21 of the cable tray hanger project status report.
The CPRT third party evaluation is summarized in Section 3.2.7.21 1
of the cable tray hanger results report.
i l
1 Identified as concerns were that Gibbs & Hill design control procedures did not effectively control design changes during construction and that it was diffi-cult to assemble complete support design calculation packages.
Ebasco and Impell design validation procedures require that calculations and drawings be controlled by the respective company's quality assurance (QA) manuals, and that design changes be controlled to ensure that cable tray and j
cable tray support modification are properly documented and incorporated in the i
design calculation packages.
TENERA, as the CPRT third party reviewer, con-firmed that the Ebasco and Impell design validation procedures are governed by their respective QA manuals.
The staff concludes that the development of effective design change procedures
)
by Ebasco and Impell provides an adequate basis to resolve the concerns raised l
by this issue, and is, thus, acceptable.
The staff review and evaluation of d
cable tray hanger design control are further discussed in Section 5 of this supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 i
l to CYGNA's review issues list for cable tray hangers (Reference A4, Issue 4
No. 21G).
1 q
21.4 Design Criteria Consistency With FSAR l
This issue is described in Section 3.2.7.21 of the cable tray hanger results j
report.
The Ebasco and Impell resolution methodologies and corrective actions are presented in Subappendix A21 of the cable tray hanger project status i
i report.
The CPRT third party evaluation is summarized in Section 3.2.7.21 of the cable tray hanger results report.
Comanche Peak SSER 15 68 Appendix A
Identified as a concern was that the design criteria used by Gibbs & Hill for the initial design of the cable tray supports were not sufficient to ensure that cable tray support designs were performed in a consistent manner and that the designs were in compliance with the CPSES FSAR commitments.
Ebasco and Impell have developed design criteria, procedures, and project in-structions to ensure consistency and compliance with FSAR commitments for the-design validation of cable trays and supports.
TENERA, as the CPRT third party reviewer confirmed that the Ebasco and Impell procedures are consistent with the CPSES FSAR.
The staff concludes that the inclusion of FSAR commitments in-the Ebasco and Impell design criteria, procedures, and project instructions provides an adequate basis to resolve the concerns identified in this issue, and is, thus, acceptable, CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 21H).
21.5 Conclusions Considering these evaluations, the staff concludes that the concerns associated with design control of cable tray hangers have been adequately resolved.
The cable tray hanger technical issue is, therefore, closed for CPSES.
Comanche Peak SSER 15 69 Appendix A
22 DESIGN OF SUPPORTS EMBEDDED IN NON-SEISMIC CATEGORY I WALLS Cable tray support No. 3136, located at the auxiliary building / safeguards building boundary, is embedded-in a fire wall.
Concerns were raised regarding the initial design calculations for this support.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified two related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
22.1 Design Considerations for Supports in Seismic Category II Structures This issue is discussed in the cable tray hanger results report (Section 3.2.7.22).
The Ebasco and Impe11 resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A22).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.22).
In its IAP, CYGNA identified a concern regarding a cable tray support embedded in a fire wall - a seismic Category II structure.
Isolated cases of cable tray hangers supported from Category 11 structures are identified and evaluated by Ebasco and Impe11 on a case-by-case basis. The i
designs of seismic Category II structures are validated under the civil /
structural areas of the Corrective Action Program.
l The support identified by CYGNA (support No. 3136) is in Ebasco's scope of work.
For design validation of this support, Ebasce assumed that the seismic Category II structures do not provide support for the cable tray system.
However, the effects of the structure's response on the support were considered in the design validation.
The OAP review of Ebasco's calculation for support No. 3136 (DAP-E-C/S-187) confirmed that the effects of the structure's response were considered in the design validation of this support.
The staff concludes that concerns related to the design adequacy of support i
No. 3136 have been adequately resolved by design validation considering the effects of secondary wall response on attached supports, i
CYGNA's review of the resolution of this issue closed the issue in Revision 15 l
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 22) and in Reference A12.
I 22.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with cable tray supports attached to non-sei:mic Category I structures have been adequately resolved.
The cable tray hanger technical issue concerning the design of supports embedded in non-seismic Category I walls is, therefore, closed for CPSES.
Comanche Peak SSER 15 70 Appendix A
=
23 LOADING IN STRESS H00ELS In its IAP, CYGNA identified concerns regarding the analytical methodologies used by Gibbs & Hill in its finite element analyses of some hangers using the computer program STRESS with regard to load application locations, tributary t
loads, and dimensions.
l The CPRT third party reviewer (TCNERA, L.P.), in conjunction with the Design i
Adequacy Program (DAP), identified one related issue from various source docu-ments.
In the cable tray hanger results report, TENERA divided this concern into (1) tray load application points, (2) tributary load calculations, and (3) modeling of support frame height.
l The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
t Project Document
- CPRT Review Document
- l (Ebasco)
I SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-120 i
1 SAG.CP4 DAP-CLC-C/S-204 3
DAP-E-C/S-120 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 t
Vol. I, Book 7 DAP-E-C/S-109 3
3 (Impell)
PI-02 DAP-CLC-C/S-404 M-12 DAP-E-C/S-115 1
(TV Electric)
I l
i TE-FVM-C/S-001 DAP-E-C/S-102 i
TE-FvM-C/S-003 OAP-E-C/S-123 1
l 23.1 Tray Load Application Points
?
This issue is discussed in the cable tray hanger results report (Section 3.2.7.23).
The Ebasco and Impell resolutions of this iiisue are provided in the cable tray hanger project status report (Subappendix A23).
The DAP evaluation is summarized
]
in the cable tray hanger results report (Section 3.2.7.23).
I I
i 1
- All relevant project and CPRT third party documents are listed in Appendix E I
to this supplement.
i Comanche Peak SSER 15 71 Appendix A i
4 CYGNA raised the concern that in the STRESS standard support models, tray loads were applied at the beam / post intersection instead of at an appropriate loca-tion within the span, j
I l
ThecomputerprogramSTRESShasnotbeenusedinthedesignvalidationof 4
hangers.
Ebasco s and Impell's procedures require load to be applied at l
the centerline of the tray for response spectrum method (RSM) analysis.
For equivalent static method (ESH) analysis, Ebasco's procedures required vertical and longitudinal loads to be applied at the centerline of the tray.
Transverse-loads are applied at the beam / post intersection.
j The DAP review of Ebasco's and Impell's design validation procedures (SAG.CP3, j
SAG.CP4, SAG.CP34, and PI-02) and related special studies (Ebasco, Vol. I, Book 7; and Impell, M-12) confirmed that load from trays is applied to the 7
i support beam at the actual location of the tray on the support, in all cases, except for the application of transverse load in ESM analysis used by Ebasco.
In this case, the OAP review found that transverse load may be appropriately applied at the beam / post intersection of hangers, rather than at the tray loc.ation because application of the transverse load to the tier would result in a fictitious torsional moment on the post in the computer analysis of the hanger.
The torsicnal load due to the transverse eccentricity between post and 1
tier is resisted by the tray, which is much stiffer than the post.
The staff concludes that the inclusion of appropriate guidelines for load point application in cable tray models in Ebasco's and Impell's design validation t
procedures provides an adequate basis for resolving the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 t
to CYGNA's review issues list for cable tray hangers (Reference A4, Issue
)
No. 23A).
i i
j 23.2 Tributary Load Calculations 1
This issue is discussed in the cable tray hanger results report (Section 3.2.7.23).
i The Ebasco and Impell resolutions of this issue are provided in the cable tray l
hanger project status report (Subappendix A23).
The DAP evaluation is summarized i
in the cable tray hanger results report (Section 3.2.7.23).
CYGNA raised the concern that in the STRESS analysis, applied loads were based j
on tributary tray spans that did not account for installation tolerances which resulted in longer spans.
The computer program STRESS has not been used in the design validation of hangers.
Ebasco and Impell validated the designs of cable tray supports based i
on as-built drawings which document actual hanger dimensions and tray spans.
The DAP review of the as-built procedures (TU Electric. TE-FVM-C/S-001 and TE-FVM-C/S-003) confirmed that appropriate hanger dimensions and tray spans are obtained for use in design validation.
The staff concludes that the use of as-built data in Ebasco's and Impell's design validation analyses provides an adequate basis for resolving the concerns identified in this issue, and is, thus, acceptable, j
Comanche Peak SSER 15 72 Appendix A
)
L
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 238).
23.3 Modeling of Support Frame Height This issue is discussed in the cable tray hanger results report (Section 3.2.7.23).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A23).
The OAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.23).
CYGNA raised the concern that the STRESS standard support model did not use dimensions from the face of the concrete to the centerline of members.
The computer program STRESS has not been used in the design validation of hangers.
Ebasco and Impell design validation procedures specify the use of centerline-to-centerline dimensions for model development.
The DAP review con-firmed that Ebasco's and Impell's design validation procedures prescribe appro-priate dimensions for elements of cable tray support models.
The staff concludes that the inclusion of appropriate modeling guidelines in Ebasco's and Impell's design validation procedures provides an adequate basis for resolving the concerns identified in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 23C).
23.4 Conclusions Considering these evaluations, the staff concludes that the concerns associated with the analytical methodologies used by Gibbs & Hill in its finite element i
analyses have been adequately resolved.
The cable tray hanger technical issue concerning loading in STRESS models is, therefore, closed for CPSES.
l l
l l
l Comanche Peak SSER 15 73 Appendix A
r j
j 24 DESIGN OF FLEXURAL MEMBERS
[
l j
In its IAP, CYGNA raised several concerns regarding Gibbs & Hill's dasign of i
flexural members for the effect of load application eccentricities, bolt holes, e
3 weld undercuts, and torsional shears on member capacity, as well as the use of improper unbraced lengths of compression flanges to determine allowable bending stresses.
i 3
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design l
Adequacy Program (DAP), identified 10 related issues from various source docu-1 ments.
In the cable tray hanger results report, TENERA combined these concerns into the five primary issues that follow.
1 I
(1) major axis bending due to vertical eccentricity (2) minor axis bending due to horizontal eccentricity l
j (3) torsion of tier members (4) bolt holes and weld undercut (5) unsupported length of compression flange l
4 The relevant project documents and the corresponding CPRT third party review l
documents for this issue group follow.
}
l Project Document
- CPRT Review Document
- i j
l l
(Ebasco) 1 SAG.CP3 DAP-CLC-C/S-204 j
DAP-E-C/S-120 a
t SAG.CP4 DAP-CLC-C/S-204 i
DAP-E-C/S-120
[
i j
SAG.CP11 DAP-E-C/S-169 1
]
SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 Vol.I. Book 2 DAP-E-C/S-112 i
i
]
(Impell) i f
PI-02 DAP-CLC-C/S-404 4
i PI-03 DAP-CLC-C/S-404 1
M-12 DAP-E-C/S-115 l
M-46 DAP-E-C/S-168 24.1 Major Axis Bending Due to Vertical Eccentricity k
This issue is discussed in the cable tray hanger results report (Section 3.2.7.24).
The Ebasco and Impell resolutions of this issue are provided in the cable tray i
1
- All relevant project and CPRT third party documents are listed in Appendix E j
to this supplement.
Comanche Peak SSER 15 74 Appendix A i
i 1
t I
hanger project status report (Subappendix A24, Section 2.A).
The DAP evaluation l
i is summarized in the cable tray hanger results report (Section 3.2.7.24).
1 Of primary concern was that major axis bending of tier members under transverse i
load due to vertical eccentricity between the tray center and tier member neutral axis was ignored.
Ebasco and Impell procedures (SAG.CP11, SAG.CP34, PI-02, and PI-03) require that eccentricities be modeled in the analytical models to more accurately pre-dict major axis bending of tier members.
For equivalent static analyses, 2
Ebasco applied a major axis bending moment equal to the applied transverse load times the vertical distance from the tier centroid to the bottom of the l
tray.
For system analyses, both Ebasco and Impe11 included a vertical eccentri-t l
city equal to the distance from tray mid-height to tier centroid.
The DAP review of Ebasco's and Impe11's design validation procedures and related special studies (Vol. I, Book 2; and M-12) confirmed that the effects of verti-cal eccentricity between the tray and tier are appropriately accounted for by j
incorporating such eccentricity in the analytical models.
i The staff concludes that the inclusion of appropriate guidelines for evaluating major axis bending of tier members under transverse load due to vertical eccen-2 tricities in the Ebasco and Impell design validation procedures and the develop-ment of special studies to verify the methods provide an adequate basis for i
{
resolving the concerns identified in this issue, and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue
}
No. 24A).
a 24.2 Minor Axis Bending Due to Horizontal Eccentricity j
This issue is discussed in the cable tray hanger results report (Section 3.2 7.24).
I The Ebasco and Impe11 resolutions of this issue are provided in the cable tray 1
hanger project status report (Subappendix A24, Section 2).
The DAP evaluatior.
I is summarized in the cable tray hanger results report (Section 3.2.7.24).
Of primary concern was that minor axis bending of tier members under transverse load due to horizontal eccentricity between beam neutral axis and clamp bolt j
holes in the top flange was not considered.
1 Ebasco and Impell procedures (SAG.CP11, SAG.CP34, PI-02, and PI-03) require that 1
l eccentricities be modeled in th-analytical models to more accurately predict minor axis bending of tier members.
For equivalent static analyses Ebasco applied a minor axis bending moment equal to the applied transverse load times the horizontal distance between the tier centroid and the location of the clamp bolt.
For system analyses, Ebasco included a horizontal eccentricity equal to the distance from the centroid of the web to the shear center of the tier.
Impell neglected the horizontal eccentricity between the tier centroid and the 4
location of the tray clamp and has shown in special study M-12 that the effect of this eccentricity is not significant.
i 1
i Comanche Peak SSER 15 75 Appendix A
1 i
4, i
The DAP review of Ebasco and Impell design validation procedures and related l
special studies (Vol. I, Book 2; and M-12) confirmed that the effects of hori-i l
zontal eccentricity between the tier and tray are appropriately accounted for l
by incorporating the eccentricity in the analytical models.
l 1
}
The staff concludes that the inclusion of appropriate guidelines for evaluating the effects of horizontal eccentricity in Ebasco's design validation procedures and the justification for neglecting the horizontal eccentricity as documented in Impell's special study provide an adequate basis for resolving the concerns
(
identified in this issue, and are, thus, acceptable, i
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 24B).
l i
24.3 Torsion of Tier Members d
This issue is discussed in the cable tray hanger results report (Section 3.2.7.24).
f The Ebasco and Impell resolutions of this issue are provided in the cable tray 4
hanger project status report (Subappendix A24, Section 2.B).
The DAP evaluat 5 I
is summarized in the cable tray hanger results report (Section 3.2.7.24).
The primary issues were that torsion in the tier induced by vertical loads due
~
to horizontal eccentricity between tier shear center and clamp location was 1
i ignored, and that torsional moment under tray longitudinal loads due to i
vertical eccentricity was ignored.
6 j
Ebasco and Impell addressed torsion due to vertical loads and horizontal loads in design validation procedures (SAG.CP11, SAG,CP34, and PI-02) by incorporating 4
eccentricities in their analytical models.
Ebasco and Impell require the tor-i 4
sional stresses (including warping effects) to be combined with the direct (flexural) shear stresses.
4 Ebasco has generated design aids for use by the analysts and designers of cable l
tray supports.
The design aids were developed using computer programs written l
1 by Ebasco.
The design aids fall into the four categories described below.
1 These are included under Sections I, II, III, and IV of Volume I, Book 2, and in the general instructions, SAG.CP34, Attachment M:
l (1) Tables of the shear center, principal axes locations, and moments of i
inertia with respect to principal axes for composite sections made up of two structural steel channels, l
j (2) Tables of warping stresses for single channels for three different end-j condition cases and loading applied at different locations along the j
channel.
4 (3) Tables of warping stresses for composite channels for three end-condition i
cases and loading applied at different locations along the composite j
section.
(4) A computer program for the calculation of stresses in composite channel sections subject to torsion and bending.
i f
Comanche Peak SSER 15 76 Appendix A 1
4
Methods for calculating torsional stresses (including warping) for various sections, e.g.,
channels and T-channels (Impell, M-12 and M-46), were reviewed l
under the DAP and found acceptable.
Under the DAP, the design validation pro-cedures for combining torsional shear with flexural shear were also reviewed and found adequate.
The staff concludes that the inclusion of appropriate guidelines for calculat-J ing and evaluating the effects of torsion due to vertical and horizontal loads in the Ebasco and Impell design validation procede es along with the accepta-bility of those methods as confirmed by the OAP review of Impell's special q
studies provides an adequate basis for resolving the concerns identified in this issue and is, thus, acceptable.
i CYGNA's review of the resolutinn of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue Nos. 24C, 240, and 24H).
24.4 Bol+. Holes and Weld Undercut l
This issue is discussed in the cable tray hanger results report (Sections 3.2.7.4 3.2.7.9, and 3.2.7.24).
The Ebasco and Impell resolutions of this issue are pro-vided in the cable tray hanger project status report (Subappendices A4, A9, and A24).
The DAP evaluation is summarized in the cable tray hanger results report (Sections 3.2.7.4, 3.2.7.9, and 3.2.7.24).
j The primary issues were that reduction in section property due to flange holes in cable trays was not considered consistently and the effects of weld undercut in reducing section properties were ignored.
See Section 4.4 of this appendix for the staff evaluation of the weld undercut issue and Section 9.1 of this appendix for the staff evaluation of the bolt-i holes issue.
24.5 Unsupported Length of the Compression Flange This issue is discussed in the cable tray hanger results report (Sections 3.2.7.14, 3.2.7,18, and 3.2.7.24).
The Ebasco and Impell resolutions of this issue are pro-vided in the cable tray hanger project status report (subappendices A14, A18, and A24).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.14, 3.2.7.18 and 3.2.7.24).
The primary concerns were that capacity reduction due to the unsupported length of the compression flange per the AISC code (Reference A7) was not properly consideied and unrealistic tray clamp behavior assumptions were used i
to justify ignoring capacity reduction.
See Section 14.2 of this appendix for the staff evaluation of the urbraced length issue and Section 18.1 of this appendix for the staff evaluation of the issue pertaining to the load *ransfer between cable trays and supports at friction-type clamps.
Comanche Peak SSER 15 77 Appendix A 1
i 24.6 Conclusions E
i Considering these evaluations, the staff concludes that the concerns associatua with the design of flexural members in cable tray hangers have been adequately resolved. The cable tray hanger technical issue concerning the design of i
flexural member is, therefore, closed for CPSES.
i I
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i Comanche Peak SSER 15 78 Appendix A l
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l 25 CABLE TRAY QUALIFICATION l
In its IAP, CVGNA raised several concerns regarding Gibbs & Hill's qualification of cable trays.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design j
Adequacy Program (DAP)., identified seven related issues from various source documents.
In the cable tray hanger results report, TENERA combined these concerns into the four primary issues that follow.
(1) dynamic amplification factor (2) cable tray capacity (3) cable tray nodification (4) cable tray moment of inertia The relovant project documents and the corresponding CPRT third party review documents for this issue follow.
1 Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP18 DAP-E-C/S-124 SAG.CP34'(Attach. A-Z)
DAP-CLC-C/S-204 Vol. I, Book 1, Parts 1-6 DAP-E-C/S-124 Vol. I, Book 15 DAP-E-C/S-149 Letter No. EB-T-3185 DAP-E-C/S-124 i
1 (Impell)
PI-06 DAP-CLC-C/S-404 DAP-E-C/S-124 M-03 DAP-E-C/S-113 M-34 DAP-E-C/S-124 DAP-E-C/S-161 M-35 DAP-E-C/S-161 i
M-36 DAP-E-C/S-161 M-39 DAP-E-C/S-122 M-66 DAP-E-C/S-113 DAP-E-C/S-124
- All relevant project and CPRT third party documents are listed in Appendix E i
to this supplement, j
Comanche Peak SSER 15 79 Appendix A m
Project Document
- CPRT Review Document *
(Test Laboratory)
CCL Report No. A-744-87 DAP-E-C/S-132 25.1 Dynamic Amplification Factor This issue is discussed.in the cable tray hanger results report (Section 3.2.7.25).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A25, Section 2.A).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.25).
The primary concern was that Gibbs & Hill had qualified cable trays by the equivalent static method (ESM) analysis without using an increased dynamic amplification factor (a DAF of 1.0).
When ESM analysis was used by Ebasco, cable trays were qualified using a 1.25 DAF (see Section 8.1 of this appendix).
The 1.25 factor is justified by engi-neering studies documented in Ebasco's special study (Vol. I, Book 15).
Whcn 1
response spectrum method (RSM) analysis was used by either Ebasco or Impell, cable trays were qualified using loads obtained directly from the RSM analyses.
The DAP review found the use of a 1.25 DAF for the qualification of cable trays by ESM analysis acceptable.
Ebasco's and Impell's cable tray qualification procedures (SAG.CP18 and PI-06) were reviewed under the DAP and found accept-able.
Loads obtained from RSM analysis inherently include the effects of dynamic amplification and are, thus, acceptable.
j The staff concludes that inclusion of an appropriate dynamic amplification factor in Ebasco's and Impell's design validation procedures and the justifica-tion for the dynamic amplification factor as documented in related special studies provide an adequate basis for resolving the concerns identified in I
this issue, and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 25A).
25.2 Cable Tray Capacity This issue is discussed in the cable tray hanger results report (Section 3.2.7.25).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A25, Section 2.B).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.25).
The primary issue was that testing and qualification of trays was based on an 8'-0" simple span.
For esoluation of trays with spans greater than 8'-0",
a capacity comparison was made based on the total load on the' tray.
Capacity comparisons based on tray bending moment would result in a lower tray capacity for tray spans greater than 8'-0".
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 80 Appendix A
Ebasco and Impell qualified cable trays with simple spans greater than 8'-0" on the basis of ultimate moment capacities obtained from tests of trays with 8'-0" simple spans (Vol. I, Book 1, Parts 1 through 7; and M-03, M-34, M-35, and M-36).
Cable tray capacity for spans greater than 8'-0" is based on com-parisons of tray bending moment with the test bending moment capacities, rather than total lead on the tray.
The DAP review of Ebasco and Impell cable tray qualification procedures (SAG.CP18 and PI-06) and related special studies (Vol. I, Book 1, Parts 1, 2, and 3; and M-66) confirmed that capacities of trays with spans greater than 8'-0" are appropriately extrapolated from the results of tests of trays with an 8'-0" span on the basis of the bending moment in the tray.
l The staff concludes that the use of an appropriate capacity comparison based on tray bending moment as specified in Ebasco's and Impell's design validation procedures and related special studies constitutes an adequate basis for resolv-i ing the concerns identified in this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 25B).
25.3 Cable Tray Modification This issue is discussed in the cable tray hanger results report (Section 3.2.7.25).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A25, Section 2.C).
The DAP evalua-tion is summarized in the cable tray hanger results report (Section 3.2.7.25).
CYGNA identified several instances of modifications to cable trays without I
justification or documentation.
Cable trays, fittings, and splice plates were qualified by Ebasco and Impell en the basis of as-built data (SAG.CP18 and PI-06), including documentation of modifications to cable tray components.
Side rail extensions are relatively light components and structural credit is net taken for these extensions.
Ebasco included the weight of side rail extensions in the qualification of trays.
Impell excluded the weight of side rail extensions, based on the results of a special study.
Splice plates are qualified separately from trays and fittings by considering a combination of test and analysis.
Modified splice plates in Unit 1 were iden-tified through walkdowns, and dimensions were obtained by considering the as-built configuration.
Specimens representative of modified splice plates were tested to determine capacity.
A similar approach is in progress for qualifying de nant splice plates in Unit 2.
The DAP review of cable tray, fittings, and splice plate qualification proce-dures (Ebasco, SAG.CP18; Impell, PI-06) and related special studies (Ebasco, Vol. I, Book 1, Parts 1 through 6; Impell, M-34 and M-66) confirmed that these components are properly qualified using as-built properties.
The DAP review findings agreed with the findings of an Impell special study (M-39) that the Comanche Peek SSER 15 81 Appendix A
weight of side rail extensions can be ignored in the qualification of cable trays.
The DAP review of Ebasco's and Impell's qualification procedures for splice plates (SAG.CP18 and PI-06) confirmed that modified splice plates are properly qualified by test and analysis.
Review of the selection methods and test re-sults (Ebasco, Vol. I, Book 1, Part 6; CCL, Report No. A-744-87) confirmed that the capacity of modified splice plates in Unit 1 (T J. Cope trays) is properly established.
The DAP review of Ebasco Letter No. EB-T-3185 found use of the same approach will resolve modified splice plate concerns for Unit 2 (Burndy/ Husky trays).
The staff concludes that the inclusion of appropriate guidelines for the quali-fication of cable tray modifications in Ebasco's and Impell's design validation procedures and the justification for the method as demonstrated by tests and analyses in related special studies provide an adequate basis for resolving the concerns identified in this issue, and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 25C).
25.4 Cable Tray Moinent of Inertia This issue is discussed in the cable tray hanger results report (Section 3.2.7.25).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A25, Section 2.0).
The DAP evalua-tion is summarized in the cable tray hanger results report (Section 3.2.7.25).
The primary concern was that cable tray moment of inertia for horizontal trans-verse loading of ladder-type trays was based on observed tray defonnations in tests assuming that all deforestions were flexural; shear deformations were not considered.
This assumption affects tray properties used in support frequency and displacement calculations.
In the moment-of-inertia computations, the measured test deformation, which includes both shear and flexural, is equated to a flexural formula for a simply supported beam.
In the Ebasco and Impell design validation procedures (SAG.CP18 and PI-02), trays are considered as flexural members using these properties.
In a special study (M-66), Impell provided justification for this approach, which assumes that shear behavior does not need to be explicitly considered.
The DAP review of an Impell special study (M-66) confirmed that trays may be appropriately modeled as flexural members (i.e., shear need not be considered in determining response in the transverse direction of the tray because of the nature of flexural members to fail in bending rather than shear).
The staff concludes that the inclusion of appropriate guidelines for the model-ing of trays as flexural members in Ebasco's and Impell's design validation procedures and the jus,tification for the approach taken in related special studies provide an adequate basis for resolving the concerns identified in l
this issue and are, thus, acceptable.
i
(
Comanche Peak SSER 15 82 Appendix A
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 250).
25.5 Conclusions Considering these evaluations, the staff. concludes thit the concerns associated with cable tray qualification have been adequately resolved.
The cable tray technical issue concerning cable tray qualification is, therefore, closed for
.,PS E S.
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l Comanche Peak SSER 15 83 Appendix A I
26 BASE ANGLE DESIGN In its IAP, CYGNA identified several concerns regarding Gibbs & Hill's design of base angles in cable tray hangers.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified nine~related issues from various source documents.
In the cable tray hanger re:sults report, TENERA combined these concerns into the four primary issues that follow.
(1) stiffening _ effects of concrete (2) principal axis properties (3) Richmond insert spacing (4) design adequacy The relevan+. project documents and tne corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP3 DAP-CLC-C/S-204 DAP-E-C/S-120 SAG.CP4 DAP-CLC-C/S-204 l
DAP-E-C/S-120 SAG.CP34 (Attach. A-Z)
DAP-CLC-C/S-204 (Impell)
PI-07 DAP-CLC-C/S-404 DAP-E-C/S-120 M-12 DAP-E-C/S-115 (TV Electric)
-l TE-FVM-C/S-001 DAP-E-C/S-102 TE-FVM-C/S-003 DAP-E-C/S-123 26.1 Stiffening Effects of Concrete This issue is discussed in the cable tray hanger results report (Section J.2.7.26).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A26, Section 2.A).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.26).
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 84 Appendix A
The primary issue w:.s that base angles were modeled as simply supported beams, ignoring the stiffening effects of concrete bearing at the angle ends.
Ebasco and Impell design validstion procedures (SAG.CP3, SAG.CP4, SAG.CP34, and PI-07) account for concrete stiffness in calculations of base angle flexibility and in the determination of support stiffness (see Section 3.9 of this appen-dix).
However, Ebasco and Impell ignored the stiffening effects of concrete in stress analysis of base angles, since this is a conservative approach for design validation.
The DAP reviewed this resolution and concluded that ignor-ing the stiffening effects of concrete is conservative for the stress analysis of the specific base angle configuration of concern.
The staff concludes that the inclusion of appropriate guidelines considering the stiffening effects of concrete in Ebasco's and Impell's design validation procedures provides an adequate basis to resolve the concerns raised in this issue, and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 26A).
26.2 Principal Axis Properties This issue is discussed in the cable tray hanger results report (Section 3.2.7.26).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A26, Section 2.B).
The OAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.26).
Ebasco considered the principal axis properties of angles in design validation (SAG.CP34).
Impell evaluated base angles using geometric axis properties per instruction PI-07 and applied a correction factor to account for the difference between geometric and principal axis properties.
Ebasco's use of principal axis properties of base angles in design validation has been confirmed under the DAP by a review of SAG.CP34.
The DAP review of Impell study M-12 concluded that Impell's use of a correction factor and bending stresses based on the geometric axis of base angles is acceptable.
j The staff concludes that the inclusion of a method for appropriately considering principal axis properties in Ebasco's and Impell's design validation procedures j
and the justification for the method used in related special studies provide an adequate basis for resolving the concerns raised with regard to this issue and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 26B).
26.3 Richmond Insert Spacing This issue is discussed in the cable tray honger results report (Section 3.2.7.26).
The Ebasco and Impell resolutions of this issue are provided in the cable tray Comanche Peak SSER 15 85 Appendix A
hanger project status report (Subappendix A26, Section 2.C).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.26).
The primary concern was that the base angle lengths resulting from the maximum spacing of the Richmond inserts were not considered in the Gibbs & Hill Working Point Deviation Study.
The design of base angles is validated by considering as-built data, which in-cludes the spacing of Richmond inserts.
The DAP review has confirmed, through' reviews of as-built procedures (TU Electric, TE-FVM-C/S-001 and TE-FVM-C/S-003),
that such spacing is being documented.
The DAP review concluded that the use of as-built data in design validation of base angles in cable tray hangers addresses this concern adequately.
The staff concludes that the use of as-built data in Ebasco's and Impell's de-sign validation analyses provides an adequate basis for resolving the concerns raised in regard to this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 26C).
26.4 Base Angle Design Adequacy This issue is discussed in the cable tray hanger results report (Section 3.2.7.26).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A26, Section 2.0).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.26).
CYGNA identified several support types for which the design calculations did not include an evaluation of the base angle.
Ebasco and Impell design validation procedures (SAG.CP34 and PI-07) require the evaluation of base angles in each cable tray hanger.
The DAP review has confirmed that the design of all base angles must be validated in accordance with Ebasco's and Impell's procedures.
The staff concludes that the inclusion of a requirement for the design valida-tion of all base angles in Ebasco's and Impell's design validation procedures provides an adequate basis for resolving the concerns identified in this issue and is, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 260).
26.5 Conclusions Considering these evaluations, the staff concludes that the concerns associated with cable tray hanger base angle design have been adequately resolved.
The cable tray hanger technical issue concerning base angle design is, therefore, closed for CPSES.
l Comanche Peak SSER 15 86 Appendix A
i 27 SUPPORT QllALIFICATION BY SIMILARITY In its IAP, CYGNA identified several concerns regarding Gibbs & Hill's qualifi-cation of cable tray supports based on similarity to other supports.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified three related issues from various source documents.
In the cable tray hanger results report, TENERA combined these con-cerns into qualification by similarity in the (1) initial design calculations l
and (2) Working Point Deviation Study.
l l
These two issues are discussed under the single subissue that follows.
l The relevant project documents and the corresponding CPRT third party review j
documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
Vol. I, Book 4 DAP-CLC-C/S-204 Vol. I, Book 8 OAP-CLC-C/S-204 27.1 Considerations for Similar Designs This issue is discussed in the cable tray hanger results report (Section 3.2.7.27).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A27).
The DAP evaluation is summarized 1
in the cable tray hanger results report (Section 3.2.7.27).
The primary concern was that Gibbs & Hill had qualified several types of cable tray supports by assuming their similarity to other supports that CYGNA found j
dissimilar.
The qualification by similarity in the Working Point Deviation Study is dis-cussed in Section 12.1 of this appendix.
For a limited number of supports, Ebasco grouped cable tray supports on the basis of similarity, considering support geometry, connection details, and other relevant attributes using procedures specified in a special study (Vol. I, Books 4 and 8).
When details of a grouped support differ from the representative support, such details are separately validated.
The majority of supports have been design validated individually.
Impell does not use the qualification-by-similarity approach and validates the design of cable tray supports individually.
The DAP review of Ebasco's grouping procedures, documented in special studies (Volume I, Books 4 and 8), found that the support selected to represent a group of supports was conservatively chosen and that all relevant cable tray hanger attributes were carefully considered.
The DAP concluded that concerns raised
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 87 Appendix A
in this issue are satisfactorily addressed by Ebasco's procedures for grouping supports and do not apply to Impell's procedures.
The_ staff concludes that the design validation of individual supports or.the use of a conservative method to qualify supports by similarity provides an adequate basis for resolving the concerns raised with regard to this issue and is, thus, acceptable.
CYGNA's review of the resolution of this. issue closed the issue'in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue-No. 27).
27.2 Conclusions
' Considering this evaluation, the staff concludes that the concerns associated with qualification of supports by similarity have been. adequately resolved.
The cable tray hanger technical issue concerning support qualification by simi-larity is, therefore, closed for CPSES.
3 I
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Comanche Peak SSER 15 88 Appendix A I
1 i
28 CRITICAL SUPPORT CONFIGURATIONS AND LOADINGS In its IAP, CYGNA identified a concern that initial Gibbs & Hill design calcu-lations for trapeze-type supports considered only a limited number of critical support configurations and loading patterns.
Other cable tray supports were qualified by comparison to these critical configurations and loading patterns.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Lesign Adequacy Program (DAP), identified four related issues from various source documents.
In the cable tray hanger resuli.s report, TENERA combined these concerns into (1) critical configuration and (2) critical loading.
These two issues are discussed under the single issue that follows.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
Vol. I, Book 4 DAP-CLC-C/S-204 Vol. I, Book 8 DAP-CLC-C/S-204 28.1 Considerations of Critical Support Configurations and Loadings This issue is discussed in the cable tray hanger results report (Section 3.2.7.28).
The Ebasco and Impell resolutions of this issue are provided in the cable tray.
hanger project status report (Subappendix A28).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.28).
The primary concern was that Gibbs & Hill design calculations for trapeze-type supports considered only a limited number of support aspect ratios.
Nojusti-fication was provided to demonstrate that the chosen aspect ratios would provide the critical configuration to evaluate all components of the support design.
Design validation was performed using as-built information which adequately accounted for significant hanger attributes including actual tray locations.
The majority of the hangers have been design validated individually.
In the limited number of instances in which hangers were grouped, the grouping was performed in accordance with Ebasco's special studies (Vol. I, Books 4 and 8).
DAP's review of Ebasco's grouping procedure is discussed in Section 27.1 of l
this appendix.
DAP's review of the use of as-built support configurations and 1
loading conditions found it adequately addresses concerns raised in this issue.
1 The staff concludes that the use of a conservative grouping method in Ebasco's procedure and the use of as-built data in Ebasco's and Impell's design valida-tion analyses provide an adequate basis for resolving the concerns raised with regard to this issue and are, thus, acceptable.
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 89 Appendix A
CYGNA's review of the resolution of this issue closed-the issue in Revision 15 to CYGNA's review issues list for cable tray hangers-(Reference A4, Issue Nos. 28A and 288).
'28.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with the'use of critical support configurations and loadings for qualifying groups of supports have been adequately resolved.
The cable tray hanger tech-nical issue concerning critical support configurations and loadings is, there-fore, closed for CPSES.
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Comanche Peak SSER 15 90 Appendix A
29 CUMULATIVE EFFECT OF REVIEW ISSUES In its IAP, CYGNA raised the concern that small non-conservatisms resulting from separate issues may have a significant cumulative effect for cable tray supports affected by more than one issue.
The CPRT third party reviewer (TENERA, L.P.), identified this issue in Discrepancy / Issue Resolution Report (DIR) E-1140.
There are no relevant project documents or CPRT third party review documents for this issue.
29.1 Cumulative Effects This issue is discussed in the cable tray hanger results report (Section 3.2.7.29).
The Ebasco and Impe11 resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A29).
The Design Adequacy Program (DAP) evaluation is summarized in the cable tray hanger results report (Sec-tion 3.2.7.29).
The primary concern was that a number of cable tray issues identified by CYGNA when occurring alone in a specific support design might be acceptable.
- However, the large number of issues when evaluated cumulatively against a generic cable tray support design, could have had a significant effect.
The Ebasco and Impell resolutions of this issue address the cumulative effect of the cable tray hanger technical issues through a systematic approach to the design validation of the CPSES cable trays and supports.
The overall design validation approach addressed each of the cable tray hanger tet.hnical issues, provided a complete as-built documentation of the cable tray system designs including resolution of improper installation or construction, and confirmed the conservatism of the design approach through extensive testing.
The DAP review of this issue concluded that the overall approach followed by Ebasco and Impell, which involves the as-built program, design validation procedures, and confirmatory testing, provides reasonable assurance that CPSES cable tray systems possess adequate safety margins.
The staff concludes that the ir.clusion of guidelines in Ebasco's and Impell's design validation procedures which analyze the caDie trays and supports as a system and the development of special studies and tests which appropriately resolve each cable tray issue provide an adequate basis for resolving the con-cerns raised with regard to the cumulative effects of the cable tray issues.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue No. 29).
29.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with the cumulative effects of the CYGNA review issues have been adequately resolved.
The cable tray hanger technical issue concerning cumulative effects of review issues is, therefore, closed for CPSES.
Comanche Peak SSER 15 91 Appendix A i
30 CABLE TRAY SYSTEM DAMPING VALUES Concerns were raised regarding the validity of 4 percent damping for the operating-basis earthquake (0BE) and 7 percent damping for the safe shutdown earthquake (SSE) used in the design of CPSES cable tray systems.
The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identifed four related issues from various source docu-ments.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Impell)
Report No. 09-0210-0017 DAP-E-C/S-147 (Test Laboratory)
ANC0 Document No. A-000181 DAP-E-C/5-146 30.1 Damping Values This issue is discussed in the cable tray hanger results. report (Section 3.2.7.30).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A30).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.30).
The primary concern was that because welded structural steel members are used I
in the cable tray supports at CPSES, the damping values for bolted structures (i.e., 4 percent for the OBE and 7 percent for the SSE) are not applicable.
Results of full-scale cable tray system dynamic tests (ANC0, Document No.
A-000181, and Impell, Report No. 09-0210-0017) have demonstrated the validity of using 4 percent and 7 percent damping in the evaluation of OBE and SSE seismic ioads, respectively, for cable tray systems representative of those i
used at CPSES.
The DAP review of the results of the cable tray system dynamic tests (ANC0, j
1 Document No. A-000181\\ and Impell's system analysis / test correlation study (Report No. 09-0210-0017) found that the effective damping of CPSES cable tray system configurations exceeds the 4 percent and 7 percent damping ratios per-mitted by the FSAR for design of bolted-steel structures.
The DAP review found the use of 4 percent damping for OBE and 7 percent damping for SSE design vali-dation of CPSES cable tray systems acceptable.
The DAP concluded that full-scale dynamic tests of representative cable tray systems confirmed the validity of design validating cable tray systems using 4 percent damping for the OBE and 7 percent damping for the SSE.
- All relevant project and CPRT third party documents are listed in Appendix E to tnis supplement.
Comanche Peak SSER 15 92 Appendix A
l The staff concludes'that the verification of damping values used for cable tray systems at CPSES documented in ANC0 tests and Impell reports provides an ade-quate basis for resolving the concerns identified in this issue and is, thus, acceptable.
The staff review and evaluation of the cable tray system damping values are further discussed in Section 4.1.1.2 of this_ supplement.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4,-Issue No. 30).
30.2 Conclusions i
Considering this evaluation, the staff concludes that the concerns associated with damping values applicable to CPSES cable tray systems have been adequately resolved.
The cable tray hanger technical issue concerning cable tray system damping values is, therefore, closed for CPSES.
1 J
i Comanche Peak SSER 15 93 Appendix A
31 MODELING OF BOUNDARY CONDITIONS Concerns were raised regarding anchorage boundary conditions, including the effects of oversized bolt holes, and the techniques used to represent anchor-l age behavior in analytical models.
f The CPRT third party reviewer (TENERA, L.P.), in conjunction with the Design l
Adequacy Program (DAP), identified 11 related issues from various source docu-ments.
In the cable tray hanger results report, TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
l 1
Project Document
- CPRT Review Document *
(Ebasco)
Vol. I, Book 1 DAP-E-C/S-124 Vol. I, Book 12 DAP-E-C/S-139 Vol. I, Book 22 DAP-E-C/S-181 (Impell)
M-04 DAP-E-C/S-139 M-73 DAP-E-C/S-183 Report No. 09-0210-0017 DAP-E-C/S-147 (Test Laboratory)
ANC0 Document No. A-000181 DAP-E-C/S-146 31.1 Design Considerations for Anchorage Modeling This issue is discussed in the cable tray hanger results report (Section 3.2.7.31).
The Ebasco and Impell resolutions of this issue are provided in the cable tray hanger project status report (Subappendix A31).
The DAP evaluation is summarized in the cable tray hanger results report (Section 3.2.7.31).
Several concerns were identified related to the modeling of boundary conditions at cable tray support anchors including anchor bolt stiffness, base plate flexi-bility, base angle effects, and oversized bolt holes.
Appropriate boundary conditions were determined in studies by Impell (M 04) and Ebasco (Vol. I, Book 12) and further confirmed under the Dynamic Testing Program (Impell, Report No. 09-0210-0017, and ANC0, Document No. A-000181).
The cable tray system dynamic tests demonstrated that variance in bolted anchorages did
' relevant project and CPRT third party documents are listed in Appendix E his supplement.
n unche Peak SSER 15 94 Appendix A
not significantly influence dynamic response to the cable tray systems.
In addition, engineering studies (Impell, M-73; Ebasco, Vol. I, Book 22) showed that the oversized bolt holes have insignificant effects on the behavior of the base angles.
Additional assurance concerning the adequacy of the anchor-ages was provided by a review of the level of stress in the design validated anchorages (Impell, M-73; Ebasco, Vol. I, Book 22).
The DAP review of Ebasco's and Impell's design validation procedures confirmed that appropriate boundary conditions are used to model base plate flexibility in cable tray support anchorages.
The DAP review of system test results con-firmed that the dynamic response of a cable tray system with slightly loose anchorages was no greater than the response of the same cable tray system with tight anchorages.
The DAP review concurred that the effects of oversized bolt holes found at CPSES on cable tray system response need not be considered in design validation.
The DAP review concluded that Ebasco's and Impell's design validation procedures adequately address concerns raised in this issue.
The staff concludes that the inclusion of appropriate methods for modeling boundary conditions in Ebasco's and Impell's design validation procedures and the justification for the methods provided in related special studies provide an adequate basis for resolving the concerns identified in this issue and are, thus, acceptable.
Also see Sections 3.7, 3.9, 13.1, 14.6, and 26.1 of this appendix.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray hangers (Reference A4, Issue i
Nos. 31 and 14F).
31.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with the modeling of cable tray hanger boundary conditions have been adequately resolved.
The cable tray hanger technical issue concerning the modeling of boundary conditions is, therefore, closed for CPSES.
i Comanche Peak SSER 15 95 Appendix A
i 32 CONDUITS ATTACHED TO CABLE TRAYS OR SUPPORTS Concerns were raised that conduits attached to cable trays and cable tray hangers may not have been properly included in design validation.
The relevant project documents and the corresponding CPRT third party review documents for this issue follow.
Project Document
- CPRT Review Document *
(Ebasco)
SAG.CP18 DAP-E-C/S-1?4 SAG.CP34 DAP-CLC-C/S-204 (Impell)
PI-02 DAP-CLC-C/S-404 32.1 Design Validation of Conduits Attached to Cable Trays or Supports This issue and the Ebasco and Impell resolutions of this issue are described in the cable tray hanger project status report (Subappendix A32).
Ebasco's and Impell's design validation procedures (SAG.CP34 and PI-02) for cable trays and cable tray hangers require that the effects of attached conduit be included in the validation.
The appropriate conduit modeling and evaluation techniques are specified in Ebasco document SAG.CP34 and Impell instruction PI-02.
For the equivalent static analysis, the system frequency was evaluated based on mass participation as specified in SAG.CP34.
The design validation procedures used to model the conduits attached to cable trays or cable tray hangers have been developed and documented in the cable tray and cable tray hanger design-basis document.
Cable tray and cable tray hangers have been designed validated in accordance with the procedures in the above project documents.
Considering its review of the project procedures, the staff concludes that Ebasco's and Impell's design validation procedures and related special studies use adequate techniques to determine cable tray and cable tray hanger response and are, thus, acceptable.
CYGNA's review of the resolution of this issue closed the issue in Revision 15 to CYGNA's review issues list for cable tray nangers (Reference A4, Issue Nos. 32A, 32B, and 32C).
32.2 Conclusions Considering this evaluation, the staff concludes that the concerns associated with conduits attached to cable trays or supports have been adequately resolved.
- All relevant project and CPRT third party documents are listed in Appendix E to this supplement.
Comanche Peak SSER 15 96 Appendix A
The cable tray hanger technical issue concerning conduits attached to cable trays or supports is, therefore, closed for CPSES.
Comanche Peak SSER 15 97 Appendix A
33 REFERENCES A1.
Ebasco Services Incorporated, Generic Issues Report, "Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers," Revision 2, March 13, 1987,- transmitted in a letter from W. G. Counsil (TV Electric) to NRC, dated April 13, 1987.
A2.
TU Electric, "CPSES Unit 1 and Common Corrective Action Program - Project Status Report for Cable Trays and Cable Tray Hangers," Revision 0, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to NRC, dated November 6, 1987.
A3.
Comanche Peak Review Team, "Discipline Specific Results Report: Civil /
Structural - Cable Trays and Supports," DAP-RR-C/S-001, Revision 1, Docket Nos. 50-445/446, September 25, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to NRC, dated December 7, 1987.
A4.
Letter from N. H. Williams (CYGNA) to W. G. Counsil (TV Electric),
Subject:
Cable Tray Support Review Issues List - Revision 15, Docket Nos. 50-445/446, July 9, 1988.
AS.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.92, "Combining Modal Responses and Spatial Components in Seismic Response Analysis."
A6.
ACI 349-76, "Code Requirements for Nuclear Safety Related Concrete Structures," American Concrete Institute.
A7.
AISC, Manual of Steel Construction, Seventh Edition, 1970, American Institute of Steel Construction.
A8.
U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2,"
NUREG-0797, July 1981 and Supplements 1 through 4 and 6 through 14.
A9.
"Comanche Peak Steam Electric Station - Final Safety Analysis Report,"
Docket Nos. 50-445/446, up to and including Amendment 71.
A10. Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
Post-Construction Hardware Validation Program Engineering Evaluation Methodology, Docket Nos. 50-445/446, September 8, 1987.
Post-Co'struction All. Letter from W. G. Counsil (TV Electric) to NRC,
Subject:
n Hardware Validation Program Attribute Matrix, Docket Nos. 50-445/446, September 23, 1987.
A12. Letter from N. H. Williams (CYGNA) to W. G. Counsil (TV Electric),
Subject:
Technical Review Issues, Comanche Peak Steam Electric Station, Independent Assessment Program - All Phases, Docket Nos. 50-445/446, June 22, 1988.
Comanche Peak SSER 15 98 Appendix A t
l l
APPENDIX B RESOLUTION OF OPEN ITEMS FROM NRC INSPECTION REPORTS B.1 NRC INSPECTION REPORT 50-445/86-19; 50-446/86-16 The following open items pertaining to the cable tray and cable tray hanger discipline were identified in Inspection Report 50-445/86-19; 50-445/86-16.
The Design Adequacy Program (OAP) responses were provided in a followup audit held at the TENERA, L.P. offices (Berkeley, California) on September 28-October 1, 1987 (Appendix 0 to this supplement - Event 17).
The DAP responses and the staff's evaluation follow.
B.1.1 Open Item C-8 (Closed)
TERA Corporation used document DAP-C/S-S131, "Cable Tray Supports Design Proce-dures Review," Revision 1, dated June 30, 1986, to review Ebasco's and Impell's design procedures.
In its review, the-staff found that this document adequately addressed design process items associated with the cable tray external-source i
issues as well as most important design process factors.
However, the staff believes that the list of attributes should be expanded to address (1) controls for cable weight as they relate to maximum load capacity (2) the concern about interaction among design groups associated with the verification of the adequacy of structural walls, slabs, steel, embedded plates, and surface-mounted attachments and reverification when appropri-ate (e.g., because of load revisions) j (3) the re-evaluation of all affected calculations when hardware capacity reductions (e.g., due to ter. ting) are determined DAP Response l
(1) Cable weight used in design verification is a function of cable tray fill (weight per foot) and span length between supports.
At CPSES the deter-mination of cable tray fill involves both the civil / structural and the j
electrical disciplines.
The checklist (contained ir, document DAP-C/S-5131, Revision 1) reviewed by the staff gives attributes that address the ade-quacy of the procedures regarding cable tray dimension and weight. cable j
weight, and tray spans which are appropriate for the scope of work being reviewed.
More recent revisions of the checklist have left these attri-1 butes unchanged.
The adequacy of the selection of cable loads under the civil / structural discipline from electrical discipline documents was assessed under the DAP in document DAP-E-C/$-172, "Cable Fill Loads."
In q
Unit 2, project procedures require the assumption of maximum fill.
I l
Comanche Peak SSER 15 1
Appendix B
(2) The scope of Ebasco's and Impell's design verification of supports ends at the verification of the support connection to the supporting structure.
It does not include verifying the adequacy of structural walls, slabs, steel, etc. The adequacy of these elements is addressed under other pro-grams of the proje:t corrective action.
The responsibility of Ebasco and Impell is limited to making available the load information when asked for by the organization responsible for these programs.
The DAP effort in the cable tray area parallels the scope of Ebasco and Impell activities.
Reviews of the structural corrective actions (pertaining to walls, slabs, etc.) were to have been conducted by the CPRT third party under the corrective action overview of the workscope involved in the civil / structural discipline; however, this activity was terminated as described in Revision 4 of the Program Plan and as directed by the senior review team.
Other overview programs will ensure the adequacy of these interactions.
Under the DAP, hardware capacities determined by testing or special analysis were reviewed (e.g., in document DAP-E-C/S-132 - tray fitting test results, document DAP-E-C/S-133 - clamp test results, and document DAP-E-C/S-124 - tray /
fitting clamp qualification methods).
Appendix A to docament DAP-C/S-S131 identifies the requirements and limitations resulting from special studies and testing as they affect design verification procedures.
The document, including Appendix A, has been revised since the staff audit and is being revised peri-odically to reflect additional requirements.
Control of calculation revisions was examined in document DAP-C/5-S131, Revi-sion 1, Section 5.2.
This section has been expanded in Revision 2 of the document.
Staff Evaluation The DAP response clarifies the limits of the Ebasco and Impell responsibilities regarding cable tray fill and cable tray support connections to supporting structures.
The DAP review checklists used to assess the Ebasco and Impell efforts are consistent with the Ebasco and Impell workscope pertaining to i
cable tray hangers.
Elements beyond this scope are addressed in other civil /
structural overview programs.
The staff reviewed Revision 3 of document DAP-C/S-S131 and its appendices.
The revised and expanded document contains attributes that reflect the requirements and limitations resulting from testing and addressing the revision of calcula-tions to reflect revised criteria.
These attributes adequately address the stai'f's concern, and the issue is closed.
B.1.2 Open Item C-9 (Closed)
The staff reviewed the draft en modeResponseMultiplier(MRM),gineeringevaluationreportentitled"1.25 Multi-which was assigned number DAP-E-C/S-101.
The purpose of this third party review of the 1.25 MRM, developed by Ebasco for use in equivalent static analysis (ESA), was to determine whether the 1.25 MRM is conservative for cable tray systems at CPSES.
Comanche Peak SSER 15 2
Appendix B
i i
In this review, the third party performed several response spectrum and time history analyses of the same cable tray systems analyzed by Ebasco.
The objec-tive was to become familiar with the details of the analyses and to verify that Ebasco had correctly performed the calculations.
The third party concluded that the calculations were correct and that the 1.25 MRM is conservative for cable tray systems with similar supports when they are equally spaced and when the flexibility of the anchorages is included in the frequency analysis of the support.
The third party identified three areas of concern pertaining to the Ebasco development, which were documented in document DAP DIR C-0074.
In the third party and Ebasco response spectrum evaluations, the 10 percent method described in NRC Regulatory Guide 1.92, which provides absolute summa-tion between closely spaced modes, was used as the primary rule for modal combinations.
However, if high response ratio were found, alternate, lower estimates of the response were developed using simple square-root-of-the-sum-of-the-squares (SRSS) summation as the modal combination rule.
Since in the FSAR the applicant commits to use the 10 percent method of Regulatory Guide 1.92 for combining modal responses, the applicant must justify neglect-ing the summation effects of closely spaced modes in the 1.25 MRM study.
DAP Response In all design verification analyses of CPSES cable tray systems where the response spectrum method is used, Ebasco uses the 10 percent method from NRC Regulatory Guide 1.02.
Only in the special studies, where the use of the 1.25 MRM for ESA is justified, was the SRSS modal combination method used as described below.
In the first special study analysis performed by Ebasco, and independently verified by the third party, the 10 percent method and the SRSS method were both used to combine modal responses in the response spectrum analyses, which were compared with corresponding ESA runs to test the conservatism of the 1.25 MRM.
lhe 10 percent method was the primary approach used; however, the SRSS method was also used for cases where high MRM values (i.e., greater than 1.25) were found.
The SRSS method represented what would be expected if the time history were analyzed.
This was subsequently corroborated with additional analyses performed using a time-history method.
Both Ebasco and the third party found that the SRSS method was generally con-servative compared with the corresponding time-history analysis for the models used in the study.
In several locations, this was not the case.
This result was not a particular concern regarding the validity of the approach because the i
corresponding interaction ratios were relatively low.
As a final justifica-tion, interaction ratios from the time-history analysis were compared directly with those from the ESA.
In this case, the ESA approach always showed that the 1.25 MRM was conservative.
On the basis of the two perspectives for verifying that the 1.25 MRM is conservative (i.e., using the 10 percent /SRSS methods and time-history analysis directly), the third party concluded that the 1.25 MRM is acceptable for the cable tray systems modeled (i.e., systems with equal spans and supports with equal stiffness).
Comanche Peak SSER 15 3
Appendix B 1
s Staff Evaluation The staff reviewed the original Ebasce studies and confirmed the DAP observa-tions.
It also reviewed Ebasco's latest evaluation for the MRM studies, Volume 1, Book 23.
In that study, Ebasco evaluated the MRM factors based on stress interaction ratios for an actual CPSES cable tray / support system.
The system was highly irregular and consisted of two tray runs spanning 18 supports rang-ing from simple to complex types and containing both straight and elbow tray elements.
Again in this study, Ebasco developed the MRM factors using both the 10 percent and SRSS combination methods in the response spectrum computations.
For this system, comparable results were obtained for either combination.
method.
Both resulted in MRM factors well below 1.25 for locations where the interaction ratios had significant magnitudes, while both resulted in MRM factors exceeding 1.25 only for locations where the interaction ratios were insignificant.
These results are consistent with the results in all the earlier studies.
The two observations pertinent to the staff concern are:
(1) The SRSS and the 10 percent modal combination methods provide comparable results for MRM factors developed through the consideration of interaction ratios.
a (2) Response estimates based on the SRSS combination procedure were found to j
be conservative when compared with the corresponding time-history estimates of response.
The first observation was clearly evident in the study of the complex cable tray system and demonstrates the adequacy of the SRSS combination procedure for realistic systems.
The second observation analytically verifies this conclu-sion.
Additionally, only the 10 percent procedure is used in the design verification analyses of cable tray systems where the response spectrum method is used.
Taken together these observations provide an adequate basis to resolve the staff's concern, and the issue is closed.
B.2 NRC INSPECTION REPORT 50-445/87-39; 50-446/87-30 In its inspection held at the Ebasco office on November 2-5, 1987 (Appendix 0 to this supplement - Event 18) the staff identified the following open item regarding cable tray hanger design criteria and methodologies.
The open item was closed during a followup inspection at the site on June 13-16, 1988 (Appen-dix 0 to this supplement - Event 23).
The other cable tray hanger open items identified during the November 2-5, 1987, inspection were cicsed during a I
followup inspection held at the Ebasco office on March 30-31, 1988 (Appendix 0 to this supplement - Event 21) as documented in NRC Inspection Report 50-445/
87-39; 50-446/87-30, dated June 6, 1988.
]
B.2.1 Open Item CT-2.1-7 (Closed)
Because the calculated estimates of anchorage stiffness involve some uncer-tainty, the corresponding estimates of support frequency are affected, Ebasco developed a sensitivity study, Volume 1, Book 25, "HVAC Ducts and Hangers l
Comanche Peak SSER 15 4
Appendix B i
, _ _ _ _. - - -. _ - ~ _
i Anchor Bolt Sensitivity Study," Revision 0, February 29, 1988.
The study, initially developed for heating, ventilation, and air conditioning (HVAC) sys-tems, was reviewed by the staff to address a similar issue (0 pen Items HV-4.9-1 and HV-4.9-2 from Inspection Report 50-445/87-39; 50-446/87-30) pertaining to-the HVAC design and for its applicability to cable tray hanger design.
Because of the similarities of the designs used for anchorages and supports in both HVAC and cable tray supports, the staff found the study applicable to both design disciplines.
The purpose of the study was to determine the effect of variations in anchor bolt stiffness on the results of the seismic analysis of the cable tray hanger systems.
In the seismic analyses, the bolts are modeled as springs with only one set of spring rates for each size and inngth of bolts.
Test data, however, showed that there is scatter in bolt stiffness.
Two systems were analyzed:
(1) system A, which consisted of a run with two bends and a riser supported by four hangers, and (2) system B, which cnnsisted of an almost straight run with a bend at one end supported by four hangers.
Three analyses were performed for each system:
(1) a base analysis using anchor spring rates that closely resembled the nominal spring rates for the anchors, (2) an analysis using 50 percent of the base analysis spring rates, and (3) an analysis using 200 percent of the base analysis spring rates.
The results for system A showed that using the second analysis as the base, the frequency changes for the first and third analyses were -5.6 percent and 3.2 percent, respectively.
The maximum interaction ratio changes for the most highly stressed hanger in the first and third analyses were -26.6 percent and 22.5 percent for structural members and -34.0 percent and 35.5 percent for anchor bolts.
The second study (that of system B) resulted in ?ou r percentage differences.
Using the second analysis as the base, the fundamental frequency changes for the first and third analyses were -2.6 percent and 1.7 percent, respectively.
The maximum interaction ratio changes for the trost highly stressed hanger in the first and third analyses were 0.8 percent and -2.0 percent for structural members and -15.2 percent and 13.35 percent for anchor bolts.
The results for system B showed definite trends.
When the anchor bolt stiff-nesses increased, the member interaction ratios decreased while the anchor bolt interaction ratios increased.
The trends established by the system B analyses are considered to be representative of hanger systems.
The study concluded that the fundamental frequency and member stress inter-action ratios of the systems are not sensitive to large changes in anchor bolt stiffnesses.
The effects of stiffness variation due to scatter on system fre-i quencies and member stress interaction ratios are negligible.
Anchor bolt l
interaction ratios were found to be only moderately sensitive tu large changes in anchor bolt stiffnesses.
Staff Evaluation The staff reviewed Ebasco's report, Volume I, Book 25, in detail.
It reviewed the model used in the study for completeness and spot checked the data.
It Comanche Peak SSER 15 5
Appendix B
found that the results were consistent with engineering theory.
The staff concludes that the results of the system B analyses are applicable to cable tray hangers.
The stiffness variations considered in the study (i.e.,
one-half and twice the nominal base values) are much greater than would be anticipated in actual service.
If a more representative variation of approxi-mately -25 percent to +50 percent were used, the changes in frequency and interaction ratios would be negligible.
The results of this study provide an adequate basis for resolving the staff's concern reganding the sensitivity of the analytical results to variations in anchor bolt stiffness, and the issue is closed.
i
\\
Comanche Peak SSER 15 6
Appendix B
APPENDIX C.
RESOLUTION OF OPEN ITEMS FROM SUPPLEMENT 13 TO NUREG-0797 C.2 DSAP VIII - CIVIL / STRUCTURAL (INCLUDING CABLE TRAY / CONDUIT SUPPORTS)
Staff Comment C.2(4)
Inconsistencies exist between the Design Adequacy Program (DAP), Discipline-Specific Action Plan (DSAP) VIII, and Impe11 and Ebasco project instructions.
~
The inconsistencies involve the statements describing the methodologies that may be used to evaluate the cable tray supports.
The DAP states that the established Ebasco methodologies will be used; DSAP VIII allows the use of Impell and Ebasco design procedures.
Furthermore, DSAP VIII states that only two methods of dynamic analysis will be used in the-analysis / design verifica-tion of cable tray supports.
The Impe11 project instructions, however, permit the use of time-history methods, overlap methods, and multilevel response spectrum methods, in addition to the two methods referred to in DSAP VIII.
Staff Review and Evaluation l
Revision 4 to the Comanche Peak Response Team (CPRT) Program Plan and the estab-lishment of the TV Electric Corrective Action Program (CAP) have made certain project activities previously associated with Revision 3 to the CPRT Program Plan's DAP and DSAP VIII independent from the CPRT Program Plan.
The incon-sistencies that existed when Supplement 13 to the SER was issued have since been corrected as a result of the design validation activities for cable trays and cable tray hangers under the CAP by Ebasco and Impell for their respective workscopes.
The design methodologies used in the CAP are not governed by the approach de-scribed in the CPRT Program Plan.
The staff's evaluation of the acceptability of the Ebasco and Impe11 methodologies used in the cable tray and cable tray l
hanger design validation is provided in Section 4.1.1 of this supplement.
'f f
4 l
Comanche Peak SSER 15 1
Appendix C
APPENDIX D CHRONOLOGY OF NRC STAFF MEETINGS, AUDITS, AND INSPECTIONS i
RELATED TO CABLE TRAY HANGER DESIGN Event No.
Date Description 1
October 25, 1985 NRC staff audit at Ebasco office (New York) of the cable tray and conduit support activities 2
October 28-November 1, 1985 NRC staff inspection at TERA Corporation office (Bethesda, Maryland) of the Comanche Peak Response Team (CPRT)
Design Adequacy Program 3
November 8, 1985 NRC staff audit at Ebasco office (New York) of the cable tray and conduit support design criteria and procedt res 4
November 12-13, 1985 NRC staff attjit at TERA Corporation of fice (Bethesoc. Maryland) of the CF tT Design Adequacy Program 5
November 26, 1965 NRC staff audit at Ebasco office (New York) of the applicant's approach to determining the slenderness ratio limitations for cable tray hangers 6
December 2-3, 1985 NRC staff audit at TERA Corporation office (Bethesda, Maryland) of the CPRT Design Adequacy Program 7
February 13, 1986 NRC staff audit at Ebasco office (New York) of cable tray hanger design cri-teria and procedures (Volume I, Books 2-7) i 1
and of the applicant's approach to de-termining slenderness ratio limitations for cable tray hangers 8
March 20, 1986 NRC staff audit at Ebasco office (New York) of the applicant's approach to determining slenderness ratio limitations for cable tray hangers and supporting i
dynamic test results j
i Comanche Peak SSER 15 1
Appendix 0
a h
t Event No.
Date Description 9
May 13, 1986 NRC staff audit at the ANCO test facil-ity-(Culver City, California) of the cable tray hanger test activities and the witnessing of fragility tests for cable tray hanger configuration No. 7 10 June 9-13, 1986 NRC staff audit at Impell office (Walnut Creek, California) of the cable tray system analysis approach 11 July 7-10, 1986 NRC staff inspection at TERA Corporation office (Berkeley, California) of the-CPRT Program Plan implementation'for cable tray hangers 12
.n e y 26-27, 1987 Public meeting at CPSES site (Glen Rose, Texas) between CYGNA and TU Electric to d',scuss cable tray hanger issues 13 February 24, 1987 Public meeting at CPSES site (Glen Rose, Texas) between CYGNA and.TU Electric to discuss cable tray hanger issues 14 August 5, 1987 NRC staff audit at CPSES site (Glen Rose, Texas) of the cable tray hanger and conduit support activities under the TV Electric Corrective Action Program (CAP) 15 August 26-27, 1987 Public meeting between TV Electric and NRC staff at Ebasco office (New York)
]
to discuss the resolution of generic technical issues pertaining to cable j
tray hangers 16 September 8-10, 1987 NRC staff audit at CPSES site (Glen Rose, Texas) of the CAP as-built ver'fication of cable tray hangers 17 September 28-October 1, 1987 NRC staff audit at TENERA, L.P. office (Berkeley, California) of the CPRT activities related to its overview of cable tray hanger design validation 18 November 2-5, 1987 NRC staff inspection at Ebasco office (New York) of the design criteria and methodologies used in the CAP design validation of cable tray hangers, con-duit supports, and heating, ventilation, and air conditioning (HVAC) system Comanche Peak SSER 15 2
Appendix D
Event No.
Date.
Description 19 December 17-18, 1987 Public meeting (Dallas, Texas) between TV Electric and intervenor CASE (with J. Doyle) to discuss the CAP for piping c
and cable tray hangers 20.
February 18, 1988 Public meeting (Dallas, Texas) between TU Electric and intervenor CASE (with M. Walsti) to discuss the CAP for cable tray hangers and conduit supports 21 March 30-31, 1988 NRC staff followup inspection at Ebasco office (New York) of cable tray hanger, l
conduit support, and HVAC open items and l
root causes of design issues 22 April 18-21, 1988 NRC staff inspection at CPSES site (Glen Rose, Texas) of cable tray hanger design criteria and methodologies used by Impell in the CAP des'gn validation 23 June 13-16, 1988 NRC staff audit at CPSES site (Glen Rose, Texas) of cable tray hanger design validation implementation and of Technical Audit Program activities l
i t
i 1
l l
1 Comanche Peak SSER 15 3
Appendix 0 j
i
t P
APPENDIX E PROJECT AND CPRT DOCUMENTS FOR CABLE TRAY HANGERS Ebasco Documents SAG.CP3, "Seismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 2." Rev. 9.
SAG.CP4, "Scismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 1," Rev. 6.
SAG.CP9, "Instruction for Re-Evaluation of Cable Tray Hangers Affected by the Longitudinal Tie of Transverse Hangers to the Tray for CPSES Unit 2," Rev. O.
SAG.CP11, "System Analysis of Cable Tray and Hanger Assembly for Comanche Peak SES Units 1 and 2," Rev. 4.
SAG.CP18, "Procedure for Qualification of Cable Trays for Comanche Peak SES Units 1 and 2," Rev. 1.
SAG.CP19, "Design Criteria and Procedures for Design Validation of Cable Tray Clamps for CPSES Units 1 and 2," Rev. 3.
SAG.CP28, "Procedure for Screening of Cable Tray Hangers To Assess the Applicability of a 1.25 MRM in Equivalent Static Method Analysis in Hanger Design Validation for CPSES Units 1 and 2," Rev. 1.
SAG.CP34, "General Instructions for Cable Tray Hanger Analysis for Comanche 3
Peak SES Nos. 1 and 2," Rev. 11.
j l
j Ebasco Special Studies i
Volume I, Book 1, Part 1, "General Input Data," Rev. 3.
Volume I, Book 1, Part 2, "General Input Data," Rev, O.
Volume I, Book 1, Part 3, "General Input Data," Rev. O.
Volume I, Book 1, Part 4, "General Input Data," Rev. 4.
1 Volume I, Book 1, Part 5, "General Input Data," Rev. 2.
l Volume I, Book 1, Part 6, "General Input Data," Rev. O.
i Volume I, Book 1, Part 7, "General Input Data," Rev. O.
l Comanche Peak SSER 15 1
Appendix E
t l
Volume I, Book 2, "Computer Related Information," Rev. 3.
[
~
Volume I, Book 3, "Prying Action Factors and Formulas for Evaluating ANhor Bolts," Rev. 1.
i
~
Volume I, Book 4, "CTH Geometry Grouping," Rev. 3.
Volume I, Book 6, "CTH tluck1'ag Study," Rev. 2.
Volume I, Book 7, "Cable Tr Hanger Load Application Location Studies," Rev. 1.
Volume I, Book 8, "Cable' Tray Hanger Geometry Grouping," Rev. 1.
Volume I, Book 9, "Organization and Original Scope Summary Report for MRM and Related Load Distribution Studies," Rev. 1.
3 Volume I, Book 9, "Multimode Response Multiplier - Studies," Part 1, Rev. 2; Part 2, Rev. 1; Part 3, Rev. 1; Part-4, Rev. 2; Part 5, Rev. 0;.Part 6, Rev. 0; Part 7, Rev. 2.
Volume I, Book 10, "Multimode Response Multiplier Studies," Rev. 2.
I Volume I, Book 12, "CT9 Wnorage Base Plate Flexibility Study," Rev. O.
Volume I, Book 13. "CTH Tier Bolt Hole Edge Distance Study," Rev. O.
3 Volume I,~ Book 15, "Cable Tray Dynamic Load Redistribution Effects," Rev. 3.
Volume I, Book 16,Section II, "Out-of-Plumbness of L-Shaped Cable Tray j
Hangers," Rev. O.
Volume I, Book 18, "Hidden Attributes," Rev.1.
Volume I, Book 22, "Statistical Analysis of Bolt Holes / Edge Distance in Cable Tray Hangers," Rev. 2; Part 2, Rev. 6.
Volume I, Book 23, "MRM Studies for Actual Complex CPSES Cable Tray Systems,"
Rev. O.
Volume I, Book 25, "Reducea Section Properties for Channels," Rev. O.
Ebasco Miscellaneous "CTH Anchor Bolt Hole Interaction Ratio Inventory," Rev. O, June 17, 1987.
"Effects of Bolt Hole Oversize on CTH System Adequacy," Rev. 3.
j Letter No. EB-T-3185, dated July 1,1987, i
"Manual of Procedures, Comanche Peak SES."
"Position Paper on Base Metal Damage in Thermolagged CTHs," Rev.
1.-
I e
Comanche Peak SSER 15 2
Appendix E
Impe11 Documents Instruction PI-02, "Pynamic Analysis of Cable Tray Supports," Rev. 5,.with Addenda 20 and 25.
Insttuction PI-03, "Design Validation of Cable Tray Supports," Rev. 4, with Addenda 17, 22, and 34.
Instruction PI-06, "Tray and Clip Qualification," Rev. O, with Addenda 13,19, 23, and 32.
Instruction PI-07, "Design Validation of Base Plates, Base Angles, and Embedment Plates," Rev. 3, with Addenda 14 and 18.
Instruction PI-11, "Cable Tray System Analysis and Qualification Closeout,"
Rev. 2, with Addenda 25, 30, and 31.
M-03, "Cable Tray Properties," Rev. 4.
M-04, "Base Angle Stiffness," Rev. 1.
M-10, "Cable Tray Clip Angle Stiffness," Rev. 2.
M-12. "Qualification Procedures for Cable Tray Support Evaluations," Rev. 3.
M-19, "Clip Stiffness Production Values," Rev. 2.
M-25, "Prying Action Factors for 2-Bolt Base Plates," Rev. 3.
M-27, "Thermal Load Evaluation," Rev. 2.
"-34. "Straight Tray Allowables," Rev. 2.
M-35, "Elbow.01owables," Rev. 1.
M-36, "Tee & Cross Allowables," Rev. O.
M-39, "Side Rail Extensions," Rev. 1.
M-46, "T-Channel Warping Behavior," Rev.1.
l M-51, "Clamp Allowables From Test Data," Rev. 1.
M-65, "Evaluation of Potential Bolt Holes in Tier Members," Rev. O.
M-66, "Transverse Behavior of Cable Trays," Rev. 2.
M-68, "Evaluation of Diamond Cored Bolt Holes," Rev. O.
d M-73, "Oversized Bolt Holes," Rev. O.
j f
Comanche Peak SSER 15 3
Appendix E
Report No. 01-0210-1470, "Effective Length Factors for Buckling of Cable Tray Supports," Rev. 1.
Report No. 09-0210-0017, "CPSES Cable Tray System Analysis / Test Correlation,"
Rev. O.
Report No. 09-0210-0018, "Slenderness Ratio Limits for CPSES Cable Tray Supports," Rev. O.
Report No. 09-0210-0136, "Impell/Ebasco comparison of Computer Programs Used in CPSES Cable Tray System Analysis," April 18, 1988.
Report No. 09-0210-0137, "Impell/Ebasco Comparison of Modelling Procedures Used in CPSES Cable Tray System Analysis," Rev. O.
Report No. 09-0210-0138, "Impe11/Ebasco CPSES Cable Tray System - Comparison of Analysis Results and Test Measurements for Test Configuration 7,"
April 19, 1988.
Study B-03, "Effective Length Buckling Factors," Rev. O.
Study B-04, "Effective Length Factors for Longitudinal Cable Tray Supports,"
Rev. O.
Test Laboratory Documents I
ANCO Document No. A-000150, "Test Plan - Dynamic Testing of Typical Cable Tray Support Configurations," December 1985.
ANC0 Document No. A-000181, "Final Summary Report - Comanche Peak Cable Tray Tests," Rev. 1.
4 i
CCL Procedure No. 1903.20-1, "Test Plan - Static Tests of Cable Trays and Fittings," Rev. 1.
CCL Procedure No. 1903.22-1, "Test Plan - Monotonic and Cyclic Tests of Cable Tray Clamps," Rev. 1.
CCL Report No. A-717-86, "Test Report for Monotonic and Cyclic Tests of Cable Tray Clamps for CPSES," Rev. 0.
CCL Report No. A-719-86, "Test Report for Static Testing of Cable Trays and i
Fittings for CPSES," Rev. O.
CCL Report No. A-721-86, "Test Report for Additional Monotonic and Cyclic Tests of Cable Tray Clamps," Rev. O.
CCL Report No. A-737-86, "Test Report for Additional Static Tests of Cable Trays and Fittings."
CCL Report No. A-739-86, "Test Report for Additional Static Tests of Cable Trays and Fittings."
Comanche Peak SSER 15 4
Appendix E
CCL Report No. A-738-87, "Test Report for Cable Trays Shim Test for CPSES,"
Rev. O.
CCL Report No. A-742-87, "Test Report for Cable Tray Tee-Fitting Tests."
CCL Report No. A-743-87, "Summary Test Report for Monotonic and Cyclic Tests of Cable Tray Clamps for CPSES," Rev. O.
l CCL Report No. A-744-87, "Test Report for Cable Tray Deviated Splice Test With l
T.J. Cope Trays," Rev. O.
l l
TV Electric Documents l
l CPE-EB-FVM-CS-034, "Field Verification Method - Engineering Walkdown for Replace-l ment of Cable Tray Fittings in Units 1 and 2," Rev. O.
CPE-EB-FVM-CS-098, "Field Verification Method - Cable Tray Rung Spacing Walkdown
- Units 1 and 2."
CPE-EB-FVM-CS-100, "Field Verification Method - Cable Tray Hanger Walkdown for Clamp Identification for Unit 1."
CPE-SWEC-FVM-CS-068, "Field Verification Method - Commodity Clearance."
CPE-SWEC-FVM-EE/ME/IC/CS-086, "Post-Construction Hardware Validation (PCHV)
Program Construction / Quality Control Reverifications."
CPE-S\\iEC-FVM-EE/ME/IC/CS-088, "Post-Construction Hardware Validation (PCHV)
Program Engineering / Quality Control Reverifications."
CPE-SWEC-FVM-EE/ME/IC/CS-090, "Post-Construction Hardware Validation (PCHV)
Program Quality Control Reinspection."
CPSES Design Basis Document, OBD-CS-082, "Cable Tray and Cable Tray Hangers,"
Rev. O, July 31, 1987.
TE-FVM-C/5-001, "Field Verification Method - Unit 1 Cable Tray Hangers As-Builting and Design Adequacy Verification Program," Rev. 7, with Interim Change Notice (ICN) No. 1.
TE-FVM-C/S-003, "Field Verification Method - Unit 2 Cable Tray Hange/s As-Builting and Design Adequacy Verification Program,' Rev. 2.
TE-FvM-C/S-019, "Field Verification Method - Unit 2 Cable Tray Selected Attributes As-Builting Program," Rev. 1.
TE-FVM-C/S-036, "Field Verification Method - As-Built Verification of Attachments to the Main Structural Framework in the Cable Spread Room Supporting Unit 1 Designated Cable Trays and Selected Attributes of Unit 1 Cable Trays," Rev. O.
TE-FVM-C/S-048, "Field Verification Method - Unit 1 Cable Tray Selected Attri-butes As-Built Programs."
4 Comanche Peak SSER 15 5
Appendix E i
I
l TE-FVM-C/S-050, "Field Verification Method - T. J. Cope Tray Ladder Tee Fitting l
- Selected Attributes Data Collection."
CPRT (Design Adequacy Program) Review Documents j
DAP-CLC-C/S-204, "Ebasco - Design Procedure Review Checklist," September 25, i
1987.
DAP-CLC-C/S-404, "Impell - Design Procedure Review Checklist," September 25, l
1987.
DAP-E-C/S-101, "1. 25 Multimode Response Multiplier," Rev.-1.
i 0AP-E-C/S-102, "CTS As-Builting Procedures - Unit 1," Rev. 2.
i DAP-E-C/S-103, "K-Factor Studies," Rev.1.
DAP-E-C/S-106, "Slenderness Ratio Limits," Rev.1.
DAP-E-C/S-107, "P ying Action Factors," Rev. 0.
DAP-E-C/S-109, "Ebasco Cable Tray Hanger Load Application Studies," Rev. 1.
DAP-E-C/S-110. "Cable Tray Clamp Stiffness," Rev. 2.
f DAP-E-C/S-112, "CTS - Computer Related Studies," Rev.1.
l DAP-E-C/S-113 "Cable Tray Stif fness," Rev.1.
DAP-E-C/5-115, "Hanger Support Qualification," Rev. 2.
DAP-E-C/S-119, "Thermal Loads," Rev. 1.
j DAP-E-C/S-120, "CTS Anchorage Qualification," Rev. 2.
4 l
DAP-E-C/S-121, "CTH Bolt Hole Edge Distance," Rev. O, a
]
OAP-E-C/S-122, "Side Rail Extonsions," Rev. 2.
0AP-E-C/5-123, "CTH As-Built Procedures - Unit 2," Rev. 2.
f DAP-E-C/5-124, "Cable Tray / Fitting / Splice / Clamp Qualification," Rev. O.
DAP-E-C/S-130, "Cable Tray Clamp Test Plan," Rev. 1.
l DAP-E-C/S-132, "Cable Tray / Fitting Test Results," Rev. 2.
i DAP-E-C/S-133, "Cable Tray Clamp Test Results," Rev. O.
]
DAP-E-C/S-139, "Base Anchorage Stif fness," Rev. O.
t DAP-E-C/S-143, "CTH Out-of-Plumbness," Rev. 2.
i Comanche Peak SSER 15 6
Appendix E
DAP-E-C/S-146, "CTH Cyclic Load Hammer Test Results." Rev.
0.-
DAP-E-C/S-147, "Test Verification of Analytical Methods," Rev. O.
l l
DAP-E-C/S-149, "Ebasco's Consideration of System Effects in ESM Analysis,"
l l
Rev. O.
l l
DAP-E-C/S-151, "Ebasco Twist Buckling," Rev. 1.
DAP-E-C/S-153, "Ebasco XL/r Requirements," Rev. 1.
DAP-E-C/S-161, "Cable Tray Component Capacities," Rev.1.
DAP-E-C/S-168, "T-Channel Warping Stresses," Rev. O.
DAP-E-C/S-169, "Ebasco Guidelines for the Structural Analysis of Cable Tray i
Systems," Rev. 1.
DAP-E-C/S-170, "Evaluation of Impe11 Project Instruction PI-11," Rev. 1.
[
i DAP-E-C/S-180, "Impe11 Calculation on Bolt Holes in Tier Members," Rev.1.
I DAP-E-C/S-181, "Bolt Hole / Edge Distance Statistics," Rev. O.
DAP-E-C/S-182, "CTS - Inaccessible Attribute Design Verification Criteria,"
Rev. O.
3 DAP-E-C/S-183, "Oversized Bolt Holes in CTS Anchorages," Rev. O.
DAP-E-C/S-184, "Reduced Section Properties for Channels," Rev.~ 0.
1 DAP-E-C/S-187, "Review of Ebasco's CTH Procedure Related Issues," Rev. O.
l DAP-E-C/S-188, "Review of Impe11's CTH Procedure Related Issues," Rev. O.
DAP-E-C/S-190, "K-Factors for Longitudinal Supports," Rev. O.
1 2
1 i
i i
l i
Comanche Peak SSER 15 7
Appendix E
l l
APPENDIX F CYGNA HEARING ISSUES RELATED TO CABLE TRAYS AND CABLE TRAY HANGERS During the February 20-24, 1984, Atomic Safety and Licensing Board (ASLB) hearing sessions, Board Exhibit No. 1, "Independent Assessment Program Final Report," Volumes 1 and 2, prepared by CYGNA Energy Services (CYGNA) was intro-duced.
At the conclusion of the February 1984 hearings, witnesses J. Doyle and M. Walsh for the intervenor, Citizens Association for Sound Energy (CASE),
l submitted a set of 30 written cross-examination questions to CYGNA.
CYGNA developed its responses and adopted those responses as its prefiled testimony entitled "Testimony of Nancy H. Williams in Response to CASE Questions of February 22, 1984 to CYGNA's Energy Services," dated April 12, 1984 (testimony of N. H. Williams).
CYGNA's Independent Assessment Program and its prefiled testimony on the 30 CASE questions were used as the subject matter for litiga-tion during the April 24-27 and May 1-3, 1984, hearing sessions..
The staff's evaluation included in this appendix addresses those five questions that concern cable tray and cable tray hanger design.
The questions associated with piping and pipe support design were addressed in Supplement 14 to the SER.
The five questions addressed herein have been categorized into the issues discussed below, i
A description of CASE's question, CYGNA's response from its prefiled testimony, the relevant discussions from the hearings, and the staff evaluation of the issue with respect to the Ebasco and Impell design validation are provided under each hearing issue.
i (1) Modeling Assumptions Used in Cable Tray Frame Analysis i
RASEQuestion: Walsh #5)^
CASE raised several questions concerning CYGNA Observation CTS-00-03 from its Independent Assessment Program Final Report (Board Exhibit No. 1).
The concerns were related to assumptions used by Gibbs & Hill in modeling the frame analyses cf cable tray systems and involved I
(a) the basis for allowable bending stress (b) the assumption that the operating basis earthquake (OBE) controls the cable tray support design (c) the appropriateness of damping values used in cable tray system analyses
- The descriptor for CASE questions corresponds to the numerical listing of the cross-examination questions provided by CASE (J. Doyle and M. Walsh) to CYGNA on February 22, 1984 (Attachment 1 to testimony of N. H. Williams).
Comanche Peak SSER 15 1
Appendix F
(d) the dynamic analysis of cable trays (e) the load transfer capacity around cable tray bends with no axial restraint and supporting documentation (f) baseplate flexibility In its prefiled testimony, CYGNA explained the derivation of the allowable bending stress for channel sections that was calculated per Equation 1.5-7 of the American Institute of Steel Construction Manual of Steel Construction (Seventh Edition).
The calculated value of 21.6 ksi was rounded off to 22 ksi.
For evaluating the controlling load combination for cable tray support design, CYGNA determined that the operating load combination (which includes the OBE) resulted in the governing design for cable tray support members except for concrete expansion anchor bolts.
For the anchor bolts, where no increase is recommended by the manufacturers for safe shutdown earthquake loadings, CYGNA determined that a safety factor of three was achieved.
For cable tray systems subjected to OBE loadings, CYGNA concluded that the use of 4 percent damping - corresponding to the damping value in NRC Regulatory l
Guide 1.61, "Damping Values for Seismic Design of Nuclear Power Plants,"
l applicable to bolted structures - was appropriate.
i For the seismic design of cable tray systems, a static analysis approach was used, which assumed 100 percent of the tray weight and peak acceleration values.
Because peak accelerations were used, the flexibility of the cable tray did not have to be calculated.
For the load transfer around cable tray bends, CYGNA demonstrated that the tray system in question was adequately supported with an axial restraint near each bend.
For baseplate flexibility, CYGNA verified the Gibbs & Hill analysis with a subsequent analysis by CYGNA using its own baseplate computer program.
The baseplate analyzed by CYGNA was a two-bolt baseplate that provided a three-l directional restraint to the cable tray system.
t During the May 1984 hearing, the discussions focused on the acceptability of a safety factor of three for anchor bolts (Tr. 13,179-13,188; 13,196-13,203; 13,209A-13,222; 13,649-13,652), the acceptability of using damping values for bolted structures (4 percent) rather that welded structures (2 percent) in analyzing cable tray systems for the OBE (Tr. 13,191-13,196; 13,203-13,209A; 13,303-13,325), the assumptions used in the dynamic analysis of cable 2
tray systems (Tr. 13,325-13,346; 13,364-13,374), and the acceptability of assuming a rigid baseplate in plate stress and bolt loads (Tr. 13,440-13,455).
Staff Evaluation The staff's evaluation of the controlling load case for the design of cable tray hanger members under the TV Electric Corrective Action Program (CAP) is provided in Section 1.1 of Appendix A to this supplement, i
~
Comanche Peak SSER 15 2
Appendix F
The staff's evaluation of the safety factor used for concrete expansion anchors and inserts is provided in Sections 3.2 and 3.4 of Appendix A to this supplement.
The staff's evaluation of the dynamic analysis methods used for cable tray systems under the CAP, including the justification of a 1.25 multimode response multiplier, is provided in Section 8.1 of Appendix A to this supplement.
The staff's evaluation of the base angle flexibility and prying action is pro-vided in Sections 3.7, 3.9, and 13.1 of Appendix A to this supplement.
(2) Weak Axis Bending in Cable Tray DJpport Channel Members (CASE Question: Walsh #6)
CASE raised questions concerning CYGNA Observation CTS-00-05 from its "Indepen-dent Assessment Program Final Report" (Board Exhibit No.-1).
The concerns were based on CASE's assumption that bending around the weak axis of a steel channel member used in a cable tray support was not addressed by CYGNA.
CYGNA clari-fied, in its prefiled testimony, that the purpose of the observation in ques-tion was to evaluate the baseplate to which the channel member was attached.
The channel was properly analyzed by Gibbs & Hill as noted by CYGNA.
Staff Evaluation There was no apparent concern associated with this issue which remained open from the May 1984 hearings.
The staff's evaluation of the design of flexural members for bending in the weak axis in cable tray hangers as established in the CAP design validation activities is discussed in Section 24.2 of Appendix A to this supplement.
(3) Design Margins in Cable Tray Hanger Desians (CASE Question: Walsh #7)
CASE raised questions concerning CYGNA Observation CTS-00-06 from its "Indepen-dent Assessment Program Final Report" (Board Exhibit No. 1).
The concerns were related to the cumulative effects of potentially unconservative assumptions eroding the safety margins in the design of cable tray hangers.
In its prefiled testimony, CYGNA provided its basis for concluding that "sig-nificant design margin" existed in cable tray designs.
As demonstrated by a Gibbs & Hill calculation, which was performed to verify the adequacy of a judgment made qualifying certain design details similar to a standard detail, the maximum interaction ratio for a channel section member was 0.94.
The cal-culation included the conservative assumption that the cable tray load was 22 percent greater than the actual loads.
In the May 1984 hearings, CASE's questions focused on the design considerations used by Gibbs & Hill to account for the bolt holes in the channel flanges used for cable tray supports (Tr. 13,479-13,483) and the appropriateness of the K value used to evaluate column buckling in cable tray support members (Tr.
13,483-13,503).
Comanche Peak SSER 15 3
Appendix F
i Staff Evaluation The staff's evaluation of the reduction in channel section properties due to clamp bolt holes is provided in Sections 9.1 and 14.3 of Appendix A to this supplement.
The staff's evaluation of the adequacy of column buckling considerations is provided in Sections 4.3 and 14.1. of Appendix A to this supplement.
The staff's evaluation of the approach for qualifying specific cable tray hanger designs to standard details is provided in Sections 27.1 and 28,1 of Appendix A to this supplement.
(4) Base 11 ate Flexibility and Prying Effects on Bolts (CASE Questions: Walsh #8 and Walsh #12)
CASE raised questions concerning CYGNA Observation CTS-00-07 from its "In-dependent Assessment Program Final Report" (Board Exhibit #1).
The concerns were related to the effects of baseplate flexibility and its prying effects on anchor bolts.
In its prefiled testimony, CYGNA calculated the effects of baseplate flex-ibility ano prying action on the anchor bolt shear and tension loads.
Using a design interaction exponent of 5/3, CYGNA demonstrated that the shear-tension i
interaction ratio was less than the 1.0 allowable value for all bolts.
l In the May 1984 hearings, CASE's question focused on the justification for the 5/3 exponent used in the shear-tension interaction equation for Hilti concrete expansion anchor bolts (Tr. 13,153-13,156; 13,520-13,545; 13,658-13,662).
Staff Evaluation 1
The staff's evaluation of the appropriateness of the exponent used in the shear-tension interaction equation for concrete expansion anchors is addressed in j
conjunction with the Corrective Action Program for civil / structural design.
I i
1 1
l 5
d Comanche Peak SSER 15 4
Appendix F j
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E**>'8 BIBLIOGRAPHIC DATA SHEET NUREG-0797 Supplement No. 15 u n iu,.uc e.o o,.....u l
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Safety Evaluatiot Report related to the operation of Comanche Peak Steam Electric Station, Units 1 and ?
. o. n..c., cc.a,. o
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Technical Same as 7. above D *..ioo CQv t a t o f,,s=.4e se ws October 1985 - June 1988
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Sunplement 15 to the Safety Evaluation Report related to the cperation of the Conanche Peak Steam Electric Station (CPSES), Units 1 and 2 (IlVREG-0797), has been prepared by the Office of Special Projects of the U. S. ?!uclear Regulatory Commission (NRC). The facility is located in Sonervell County, Texas, approximately 40 miles southwest of Fort Worth Texas.
This supplement presents the staff's evaluation of the applicants' Corrective Action Program (CAP) related to the design of cabic trays and cable tray hangers. The scope and methodologies for the CAP workscope as survarized in Revision 0 to tne cable tray and cable tray hanger project status report and as detailed in related documents referenced in this evaluation were developed to resolve various design issues raised by the Atomic Safety and Licensing Board ( ASLB), the intervenor, Citizens Association for Scund Eneroy (CASE), the Conanche Peak Response Team (CP3T), CYGilA Eneroy Services (CYG!!A), and the ll?,C staff.
l The NRC staff concludes that the CAP workscope for cable trays and cable tray hangers provides a comprehensive program for resolving the associated technical concerns identified by the ASLB, CASE, CPRT, CYGNA, and the NRC staff and its implementation ensures that the design of cable trays and cable tray hangers at CPSES satisfies the applicable requirements of 10 CFR 50.
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