ML20151W333
| ML20151W333 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/31/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| References | |
| NUREG-0797, NUREG-0797-S16, NUREG-797, NUREG-797-S16, NUDOCS 8808240054 | |
| Download: ML20151W333 (164) | |
Text
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i NUREG-0797 i
Supplement No.16 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 Regulatory Commission Office of Special Projects July 1988 pa %,,,
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NOTICE
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Avaliability of Reference Materials Cited l'n NRC Publications -
Most documents cited in NRC publications will be available from one of the following sources:
- 1. The NRC Public Document Room,'1717 H Street, N.W.
(
Washington, DC 20555
- 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.
Although the listing that follovn represents the majority of documents cited in NRC publications,;
it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Docu-ment Room include NRC correspondence and internal NRC memoranda; NRC Office of Inspection and Enforcement bulletins, circulars, information notices,' inspection %nd investigation notices;.
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 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 National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
- L Documents available from public and special technical libraries include all open literature items,-
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'l American National Standards Institute,1430 Broadway, New York, NY 10018.
i I
NUREG-0797 Supplement No.16 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 Regulatory Commission Office of Special Projects July 1988 5
j aug' /:
i ABSTRACT e
Supplement 16 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-
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(CAP) related to the design of conduit supports.
The scope and methodologies i
for the CAP workscopes as summarized in Revision 0 to the conduit support project status reports and as detailed in related documents referenced in this evaluation were developed to resolve various design issues raised by the Comanche Peak Response Team (CPRT); CYGNA Energy Services (CYGNA); and the NRC staff.
The NRC staff concludes that the CAP workscopes for conduit supports provide a comprehensive program for resolving the associated technical concerns identified by the CPRT, CYGNA, and the NRC staff.
The NRC staff further con-cludes that implementation of the CAP workscope for conduit supports ensures that the design of conduit supports at CPSES satisfies the applicable require-ments of 10 CFR Part 50.
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TABLE OF CONTENTS Page ABSTRACT................................................................
iii PRINCIPAL CONTRIBUTORS..................................................
vii ABBREVIATIONS...........................................................
ix 1 INTRODUCTION.........................................................
1-1 2 SOURCE OF ISSUES.....................................................
2-1 2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diamete 2-1 2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.....................................................
2-2 3 OVERVIEW
SUMMARY
3-1 3.1 CPRT Program Plan...............................................
3-1 3.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................................
3-1 3.1.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter....................................
3-2 3.2 TV Electric Corrective Action Program...........................
3-3 3.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................................
3-3 3.2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.....................................
3-4 4 CORRECTIVE ACTIONS...................................................
4-1 i
4.1 Applicant Actions - TV Electric Corrective Action Program Process 4-1 4.1.1 Design Criteria Development..............................
4-3 4.1.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................
4-3 4.1.1.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.........................
4-11 4.1.2 Design Validation........................................
4-16 4.1.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................
4-16 4.1.2.2 Conduit Supports fo* Train C Less Than or Equal to 2 Inches in Diactter.........................
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Comanche Peak SSER 16 v
TABLE OF CONTENTS (Continued) i Pagg 5
4.1.3 Hardware Validatlan......................................
4-28 4.1.3.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................ 4-28 4.1.3.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.........................
4-29 4.1.4 Final Reconciliation.....................................
4-29 4.1.5 Final Documentation......................................- 4-30 4.2 Third-Party Actions.............................................
4-30 4.2.1 CPRT Third-Party Review (TENERA, L.P.)...................
4-30 4.2.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................
4-30 4.2.1.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.........................
4-33 4.2.2 TU Electric Technical Audit Program......................
4-35 4.2.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter................
4-35 4.2.2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter.........................
4-36 4.2.3 CYGNA Energy Services....................................
4-37 5 PREVENTIVE ACTIONS...................................................
5-1 6 CONCLUSIONS..........................................................
6-1 7 REFERENCES...........................................................
7-1 i
APPENDICES A RESOLUTION OF TECHNICAL ISSUES FOR CONDUIT SUPPORTS B LIST OF PROJECT AND CPRT DOCUMENTS FOR CONDUIT SUPPORTS C CHRON0 LOGY OF NRC STAFF MEETINGS, AUDITS, AND INSPECTIONS RELATED TO CONDUIT SUPPORT DESIGN D RESOLUTION OF OPEN ITEMS FROM NRC INSPECTION REPORTS f
i Comanche Peak SSER 16 vi j
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PRINCIPAL CONTRIBUTORS NRC Staff Organization D. Terao Comanche Peak Project Division /
Office of Special Projects Consultants G. DeGrassi Brookhaven National Laboratory J. Braverman Brookhaven National Laboratory W. P. Chen Independent J. Tsacoyeanes Teledyne Engineering Services l
Comanche Peak SSER 16 vii
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l ABBREVIATIONS ACI American Concrete Institute AISC American Institute of Steel Construction AISI American Iron and Steel Institute ANCO ANCO Engineers, Incorporated ANSI American National Standards Institute ASLB Atomic Safety and Licensing Board AWS American Welding Sociecy Brown & Root Brown & Root, Incorporated CAP Corrective Action Program CASE Citizens Association for Sound Energy CCL Corporate Consulting and Development Company Ltd.
CFR Code of Federal Regulations CMC component modification card CPRT Comanche Peak Response Team CPSES Comanche Peak Steam Electric Station CQC complete quadratic combination CSD conduit support detail 1
CSM civil, structural, mechanical i
CYGNA CYGNA Energy Services 1
DAF dynamic amplication factor DAP Design Adequacy Program i
DBCP Design Basis Consolidation Program j
DBD design-basis document DIR discrepancy / issue resolution report l
4 DSAP discipline-specific action plan 1
DVP design validation package P
I Ebasco Ebasco Services Incorporated ECE Engineering and Construction Engineering EDO Executive Director for Operations EFE engineering functional evaluation ESM equivalent static method FSAR final safety analysis report 2
l FVM field verification method
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G&H Gibbs & Hill, Incorporated IAP Independent Assessment Program Impell Impe11 Corporation IN-FP individually engineered fire protected IR inspection report ISAP issue-specific action plan l
Comanche Peak SSER 16 ix i
r NEO Nuclear Engineering and Operations NRC U.S. Nuclear Regulatory Commission 0BE operating-basis earthquake PCHVP Post-Construction Hardware Validation Program QA quality assurance QC quality control QOC quality of construction 4
RFI request for information RG regulatory guide i
RIL review issues list RSM response spectra modal SDAR significant deficiency analysis report SER safety evaluation report SRSS s qua re-roo t-o f-the-s um-o f-th e-s q ua re s SRT Senior Review Team 4
1 SSE safe-shutdown earthquake
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SSER supplemental safety evaluation report SWEC Stone & Webster Engineering Corporation i
TAP Technical Audit Program i
TENERA TENERA, L.P. (formerly TERA Corporation)
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TRT lechnical Review Team TV Electric j)
Texas Utilities Electric Company (formerly TUGCO)
TUGC0 Texas Utilities Generating Company ZPA zero period acceleration I
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Comanche Peak SSER 16 x
1 INTRODUCTION In September 1984, Texas Util: ties Electric Company (TV Electric), lead applicant 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 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, TV 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 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 (S) large-bore piping (6) small-bore piping (7) cable trays and cable tray hangers (8) conduit supports (Trains A and B, and Train C larger than 2 inches in diameter)
(9) conduit supports (Train C less than or equal to 2 inches in diameter) l (10) heating, ventilation, and air-conditioning (11) equipment qualification The applicant contracted with three major design organizations - Ebasco Services Incorporated (Ebasco), Impell Corporation (Impell), and Stone &
Webster Engineering Corporation (SWEC) - to perform the activities related to the 11 design sorkscopes.
This supplement presents the NRC staff's safety evaluation of the CAP design wnrkscopes for (1) conduit supports - Trains A and B, and Train C larger than 2 inches in diameter (hereinafter referred to as "Trains A and B conduit supports") and (2) conduit supports - Train C less than or equal tc 2 inches in l
Comanche Peak SSER 16 1-1
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l diameter (hereinaf ter referred to as "Train C conduit supports").
For conduit and conduit supports, Trains A and B contain safety-related seismic Category I components.
Train C contains non-seismic Category I components.
- However, Train C conduit larger than 2 inches in diameter and supports that conform to Position C.2* of NRC Regulatory Guide (RG) 1.29, "Seismic Design Classifica-l tion," are either seismically supported or seismically restrained at CPSES and are analyzed in accordance with the seismic criteria used for Trains A and B.
t Train C conduit larger than 2 inches in diameter and supports that are not i
safety related and do not conform to Position C.2 of RG 1.29 are addressed as part of the systems interaction program associated with the CAP mechanical systems workscope.
Train C conduit, 2 inches in diameter and less, and supports are evaluated using alternative seismic design criteria from those of Trains A and B.
The CAP contractor for Trains A and B conduit supports is Ebasco; for Train C conduit supports, the CAP contractor is Impell.
The staff's reviews of the other nine CAP design workscopes have been or will be addressed in other i
safety evaluation reports.
The staff's evaluation of the CPSES conduit support activities provided in this supplement covers a wide range of subjects that cannot be presented appropri-ately in the usual Safety Evaluation Report (SER) format used for licensing l
activities.
Therefore, the format in this supplement will be used for the staff evaluations of the TV Electric CAP.
l In each section that follows, Trains A and B conduit systems are addressed i
i separately from Train C conduit systems because of the differences between the background of the issue, CAP contractor, functional requirements, and design l
validation approach for the two CAP workscopes.
Trains A and B conduit systems j
are discussed first; the discussion of Train C conduit systems follows.
Sec.-
tion 2 of this supplement discusses the background and source cf the issues of i
1 concern for Trains A and B conduit supports and Train C conduit supports.
Similarly, Section 3 provides an overview summary of the corrective actions taken by the applicant for the two workscopes.
Section 4 discusses the staff's evaluation of the corrective actions including the respective design criteria i
and methodologies used in the CAP.
Section 5 provides the staff's evaluation L
of the applicant's preventive actions including the programmatic and quality i
assurance aspects.
Section 6 presents the staff's overall conclusions on conduit supports.
Section 7 lists the references cited in this report.
Avail-ability of all reference risaterial cited is described on the inside front cover l
of this report and, where special notation is needed, availability is noted on 1
the reference lists in Section 7 and Appendix A.
Appendix A provides the staff's review and evaluation of the external source issues associated with conduit supports.
Appendix B is a listing of design procedures and criteria i
l used by Ebasco and Impell in the CAP conduit support design validation and of
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i the CPRT engineering ovaluations and review checklists which document the CPRT review of the Ebasco and Impell documents.
Appendix C provides a chronology
- Position C.2 states:
Those portions of structures, systems, or components t
whose continued function is not required but whose failure could reduce the functionino of any (seisr ic Category I) plant feature...to an unacceptable safety level or could result in incapacitating injury to occupants of the control room should be designed and constructed so that the SSE [ safe-shutdown j
earthquake) would not cause such failure.
l Comanche Peak SSER 16 1-2 1
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1 of NRC staff meetings, audits, and inspections associated with the two work-scopes.
Appendix D provides the resolution to open items identified in pre-a vious NRC inspection reports related to conduit supports design criteria.
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.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 following address:
Mr. Christopher I. Grimes Director ComanchePeakProjectDivIsion OfficeofSpecialProjects Mail Stop 7H-17 U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Copies of this supplement are available for public inspection at (1) the NRC's l
Public Document Room located at 1717 H Street, NW, Washington, DC 20555,(2) the Local Public Document Room located at the Somervell County Public Library on the Square, P.O. Box 1417, 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.
i Comanche Peak SSER 16 1-3
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I 2 SOURCE OF ISSUES i
i 2.1 Conduit Supports for Traing,A and B, and Train C larger Than 2 Inches in Diameter 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 i
i Board (ASLB).
The primary contention was Contention 5.*
Contention S was
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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, i
Citizens Association for Sound Energy (CASE), to raise questions related to potential design deficiencies that allegedly were not caught by the design a
control program.
Hearings held on design issues in 1982 and 1983 focused primarily on piping and pipo supports.
In early 1983, concurrent with the ASLB hearings, the staff asked the appli-cant to conduct an independent verification program in regard to the quality of design and construction activities at CPSES.
In requesting this independent j
verification program, the staff was seeking additional assurance that the design process used at CPSES complied with NRC regulations and licensing commitments.
The applicant submitted a plan for an Independent Assessment Program (IAP) for CPSES to be perfermed by CYGNA Energy Services (CYGNA).
In a
November 1983, CYCNA submitted the results of the draft IAP Phases 1 and 2 i
(Reference 1) to the staff and the applicant, The CYGNA IAP report (Phases 1
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and 2) was a limited-scope assessment of a portion of the design control
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process and its implementation which included design control, pipe stress, j
pipe supports, equipment qualification and structural (cable tray hangers),
electrical, and walkdown results.
InItsIAP,CYGNAconcludedthattheover-j all design activities at CPSES were adequate and were properly implemented.
i Subsequently, the ASi.B issued its preliminary findings on the design issues in j
its Memorandum and Order ("Quality Assurance for Design"), dated December 28, j
1983 (Reference 2).
The ASLB found that the applicant had not demonstrated
- Contention 5 in the ASLe hsirings on CPSES stated:
The applicant's failure to adhere to the quality :ssurance/ quality i
control (QA/QC) provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B j
of 10 CFR Part 50, and the construction practices employed, speci-fica 11y in regard to concrete work, mortar blocks, steel, fracture l
toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC), and trainfrg and organization of QA/QC personnel, have l
raised substantial questions as to the adequacy of the construction i
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.
I Comanche Peak SSER 16 2-1
the existence of a system to promptly correct design deficiencies and concluded that the applicant was not in compliance with 10 CFR Part 50, Appendix B.
The ASLB urged that a third party independently review the technical issues addressed in the hearings.
The applicant again contracted with CYGNA to per-form this review and referred to this review as Phases 3 and 4 of the CYGNA IAP.
Phase 3 was directed primarily toward a review of the piping and pipe j
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 j
Unit 1 which included design control, as-bo walkdown, pipe stress, pipe supports, mechanical systems, electrical s; cems, instrumentation and control systems, cable tray support, and conduit support reviews.
Because of the conclusions stated in the draft IAP report for Phases 1 and 2, CYGNA personnel appeared as witnesses before the ASL8 in hearings held during February, April, and May 1984 to testify on the quality of design at CPSES.
In the course of their testimony, CYGNA witnesses responded to numerous questions posed by CASE 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 iiidicated that several items required further explanations by CYGNA. When errata completing the CYGHA IAP Phases 1 and 2 report were issued on October 12, 1984 (Reference 3), these hearing items had not been fully resolved.
In a letter from N. H. Williams (CYGNA) to V. Neonan (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 conc'usions affected by a cumulative effects assess-ment across all phases of the IAP and (2) identified many open and unresolved issues remaining from 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 f:om Phases 1, 2, 3, and 4 of the IAP.
The CYGNA IAP (Phases 1, 2, 3, and 4) revealed many design con-cerns related to pipe stress, cable tray, and conduit support design.
2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter On March 12, 1984, the NRC's Executive Director for Operations (E00) issued a directive establishing a program for assuring the overall coordination and integration of regulatory issues and their resolution before the staff made its licensing decision.
Many technical concerns and allegations about the design and construction of CPSES were included in these issues to be resolved.
By the end of April 1984, the staff identified approximately 400 concerns and allegations related to the construction of the Comenche Peak facility, in-cludir.g tinci..gs by NRC's Special Review Team (Reference 6).
On July 9, 1984, the NRC established a Technical Review Team (TRT) to conduct an inteitsive onsite effort designed to review the many technical concerns and allegations.
The TRT effort covered a number of areas, including the installa-tion of non-safety-related conduit supports in selected seismic Category I areas of the plant.
- TUGC0 = Texas Utilities Generating Company Comanche Peak SSER 16 2-2
In a letter from D. G. Eisenhut (NRC) to M. D. Spence (TUGC0) dated September 18, 1984 (Reference 7) and in Supplement 8 to the CPSES Safety Evaluation Repor+
(SER) (Reference 8), the staff discussed the TRT findings for the civil /
structural area, which included the non-safety-related conduit supports.
lne support installation for non-safety-related (Train C) conduits less than or equal to 2 inches in diameter was_found to be inconsistent with seismic require-ments and no evidence could be found that substantiated the adequacy of the installation for non-safety-related conduit of any size.
The TRT requested that the applicant propose e program that assures the adequacy of the seismic support system installation for non-safety-related conduit in all seismic Category I areas of the plant.
The program was to (1) provide the results of seismic analysis which demonstrate that all non-safety-related conduit and their support systems, satisfy the provisions of RG 1.29 (Reference 9) and i
the CPSES Final Safety Analysis Report (FSAR) and (2) verify that non-safety-related conduits less than or equal to 2 inches in diameter which are not required to be installed in accordance with the requirements of RG 1.29, satisfy applicable design requirements.
1 Comanche Peak SSER 16 2-3
i 3 OVERVIEW
SUMMARY
3.1 CPRT Program Plan 2.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter i
Because of many. design issues identified by Cygna Energy Services (CYGNA) in its Independent Assessment Program (IAP) in regard to conduit supports at Comanche Peak Steam Electric Station (CPSES), the Comanche Peak Response Team (CPRT) i developed an action plan to identify and correct design deficiencies relating to these components.
This discipline-specific action plan (DSAP) was part of 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,"
l 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 (Reference 8).
In regard to Trains A and B conduit supports, DSAP VIII was developed as part of the Design Adequacy Program (DAP) under the charter of the CPRT Program Plan.
DSAP VIII (Appendix C of the CPRT Program Plan) described project ** and third party activities pertaining to the resolution of concerns rslated to the civil / structural discipline including Trains A and B conduit supports.
The j
action plan included project activities involving a conduit su verification program rnd a third party review of this program.pport design The project activities were to be performed by Ebasco Services Incorporated (Ebasco) and the third party activities were to be performed by TENERA, L.P. (formerly known as TERA Corporation).
In addition to providing for the resolution of all identified technical concerns, the plan included a self-initiated evalua-tion of the CPSES quality of construction and adequacy of design to investi-gate additional areas so that its conclusions could be extended to the balance of the CPSES plant.
In the civil / structural action plan, the scope of the i
conduit support design verification program was essentially all-encompassing.
A self-initiated review was conducted for all other safety-related civil /
structural discipline design processes that were not covered by the cable tray l
and cable tray hanger or conduit support design verification activities, i
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- Revisions 0 and 1 of the CPRT Program Plan, 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 (TRT's) inspection at CPSES conducted from July to September 1984.
The Trains A and l
B conduit support issues identified by CYGNA were not included.
zation and its contractors (e.g., Ebasco) responsible for design activities.
Comarche Peak SSER 16 3-1 i
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In Section 3.5.3 of Supplement 13 (Reference 8), the staff, in its evaluation of f
the cable tray and conduit supports 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 the program objectives through technical audits performed during the implementation of the program.
3.1.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter In response to the TRT concern, the Comanche Peak Response Team, in Revision 0-l to its Program Plan (Reference 10), developed Issue-Specific Action Plan (ISAP)
I.c to address this concern and to ensure compliance H,th regulatory require-ments and FSAR commitments.
ISAP I.c, initially titled "Electrical Conduit Supports," specifically addressed the issue related to Train C conduit less than or equal to 2 inches in diameter.
The title was subsequently changed to "Train C Conduit and Supports" to reflect the fact that ISAP I.c pertains only to non-safety-related conduit.
In Revision 0 to the CPRT Program Plan, ISAP I.c specified that the seismic analysis of a sample of 2-inch-diameter-and-less conduit runs be performed to confirm the original assumption of restraint adequacy.
Two samples were selected.
The first sample was selected to obtain a distribution of support types that would be statistically representative of supports throughout the plant.
The second sample was selected on the basis of an engineering criterion that would identify supports more susceptible to seismic excitation.
Since the conduit had been field run, isometric drawings and support details were gener-ally not available.
Tnus, it was necessary to develop as-built information for the sample conduit runs to be design verified.
The first sample consisted of 126 conduit runs selected from the population of approximately 3738 runs of 1-1/2-inch-diameter and 2-inch-diameter conduit using a table of random numbers, thus providing an equal chance that any single conduit run might be selected regardless of its identity, physical attributes, or quality.
Runs so selected that were found in the field to be inaccessible for evaluating the as-built configuration, "as-builting," were excluded from the sample for reasons of practicality.
The second sample of 131 conduit runs was selected for evaluation based upon engineering factors such as conduit size, span length, number of supports, and type of supports.
The intent of this selection was to defined a subset of the population of conduit runs that might exhibit more extreme behavior in a seismic event.
The analysis of the sample conduit runs, which were performed by Gibbs & Hill, l
Inc. (Gibbs & Hill), indicated that there was an approximate 10 percent fail m e rate of the supports in the sample.
Subsequent to this stuay, Gibbs & Hill and the Impell Corporation (Impell) jointly performed a second sampling study using l
a refined set of acceptance criteria.
This study resulted in a failure rate of I
1.8 percent.
Although it might have been possible to demonstrate seismic adequacy with a more rigorous analytical approach (e.g., non-linear analyses),
TO Electric chose to resolve the concern through a complete design validation effort.
Comanche Peak SSER 16 3-2
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, TU Electric became aware of the numerous and broad-scope findings of 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 (Stone & Webster Engineering Corporation, SWEC)*-
(2) civil / structural (SWEC)
(3) electrical systems (SWEC)
(4) instrumentation and control (SWEC)
(5) large-bore piping (SWEC)
(6) small-bore piping (SWEC)
(7) heating, ventilation, and air-conditioning (Ebasco)
(8) cable trays and cable tray hangers (Ebasco/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 applicant described the CAP to the NRC staff in letters from W. G. Counsil, dated January 29, June E August 20, August 28, September 8, and September 23, 1987 (References 11, 12, 13, 14, 15, and 16, respectively).
As a result of the establishment of the CAP and the completion of the CPRT investigative activities, Revision 4 to the CPRT Program Plan was issued on June 18, 1987 (Reference 17) to reflect 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 18).
3.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches j
in Diameter The scope of the Trains A and B conduit supp 1 sign verification program being imple.nented by Ebasco under Revision 3 one CPRT Program Plan (DSAP s
VIII) was expanded from a sampling program to a complete validation by the 4
establishment of the CAP.
The conduit support design verification program was incorporated into the CAP and reformatted so that it was consistent with the l
Design Basis Consolidation Program (OBCP)** (Reference 19).
The conduit l
support design verification program as described in Attachments 3 and 4 of DSAP l
VIII of the CPRT Program Plan (Reference 17) evolved into the design validation component of the CAP for Trains A and B conduit supports.
1
- Impell is validating the design of the fire protection system and Ebasco is i
evaluating the design of systems interaction.
- The applicant used the OBCP to manage the CAP and ensure consistency of each contractor's activities and products.
Comanche Peak SSER 16 3-3
The CAP process in regard to Trains A and B conduit supports consists of design criteria development, design validation, hardware validation, final reconciliation, and final documentation.
This supplement addresses the overall CAP process, each of its components, and the effectiveness of the third party reviews.
The staff evaluated the activities completed by the third party (TENERA) under the CPRT Program Plan's DAP for conduit supports (DSAP VIII) through several design audits and inspections.
The staff's evaluation of TENERA's activities and associated reports is provided in Section 4.2.1.1 of 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 described in the foreword to Appendix A to Revision 4 of the CPRT Program Plan (Reference 17).
The staff's review and evaluation of the effectiveness of the TAP activities related to Trains A and B conduit supports are provided in Sec-tion 4.2.2.1 of this supplement.
The open items identified in the Independent Assessment Program conducted by CYGNA from 1983 to 1985 have been addressed under both the CPRT Program Plan and the Corrective Action Program.
In addition, since November 1986, TU Electric has been actively pursuing the resolution of the open IAP issues with CYGNA in meetings between CYGNA and the CAP contractors.
The staff's evalua-tion of CYGNA's activities is provided in Section 4.2.3 of this supplement.
The staff has completed its audits and inspections of the Trains A and B con-duit support design validation and third party activities and concludes that the effectiveness and completeness of the program's implementation are suffi-cient to ensure that licer. sing commitments are satisfied and that the conduit support issues identified in the CYGNA IAP are being properly resolved.
The staff reviews and evaluations of the corrective actions taken in the design cf Trains A and B conduit supports are provided in Section 4 of this supplement.
3.2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter The design validation of Train C conduit supports was developed and implemented by Impell under the TV Electric Corrective Action Program.
The CPRT third party continued its review and evaluated the CAP methodology used by Impell for Train C conduit supports.
The CAP process in regard to Train C conduit supports consists of design cri-teria development, design validation, hardware validation, final recoaciliation, and final documentation.
This supplement addresses the overall CAP process, each of its components, and the effectiveness of the third party reviews.
The staff evaluated the activities completed by the third party (TENERA) under the CPRT Program Plan's ISAP I.c through several design audits and inspections.
The staff's evaluation of the CPRT's activities and associated results report is provided in Section 4.2.1.2 of this supplement.
The third-oarty review activities that were transferred from the CPRT to the TV Electric Technical Audit Program (TAP) as a result of the CPRT redirection are described in the foreword to Appendix A to Revision 4 of the CPRT Program Plan Comanche Peak SSER 16 3-4
(Reference 17).
The staff's review and evaluation of'the. effectiveness of the:
TAP activities related to Train C conduit supports are provided in Section 4.2.2.2 of this supplement.
The staff has completed its audits and inspections of the CAP Train C-conduit support design validation and CPRT third party activities and concludes that the effectiveness and completeness of the program's implementation'are suffi-cient to ensure that licensing commitments are satisfied and that the Train C conduit support issues identified by the NRC's TRT are being properly resolved.
The staff review and evaluation of the corrective actions taken in the design of Train C conduit supports are provided in Section 4 of this supplement.
i l
1
-Comanche Peak SSER 16 3-5
4 CORRECTIVE ACTIONS The sections that follow provide the staff's review and evaluation of the corrective actions taken by the applicant to ensure the structural integrity of the Trains A, B, and C conduit supports at Comanche Peak Steam Electric Station (CPSES), including third party oversight of the Corrective Action Program (CAP) activities.
(1) Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter To evaluate the design of Trains A and B conduit supports at CPSES, the staff reviewed the Comanche Peak Response Team (CPRT) Program Plan up to and includ-ing Revision 4 (Reference 17), the applicant's letters describing its CAP (References 11, 12, 13, 14, 15, and 16), and the Trains A and B conduit support project status report (Reference 20).
The NRC staff audited and inspected the CPRT Program Plan and CAP activities related to conduit supports at CPSES from October 1985 thrcugh June 1988 (see Appendix C to this supplement for a chronology of staff audits and inspections of conduit support activities).
(2) Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter As part of the staff's assessment of the design validation for Train C conduit supports, the staff reviewed the CPRT Program Plan up to and including Revision 4 (Reference 17), the applicant's letters describing the CAP (References 11,12, 13, 14, 15, and 16), and the Train C project status reports (Reference 21).
In addition, the staff audited the CPRT Program Plan and CAP activities from October 1985 through May 1988 (see Appendix C to this supplement for a chronology of staff audits and inspections of conduit support activities).
4.1 Applicant Actions _TO Electric Corrective Action Program Process Two project status reports also describe the CAP process for (1) Trains A and B (Reference 20) and (2) Train C (Reference 21) conduits and conduit supports.
The major elements of the CAP process are design criteria development, design-validation, hardware validation, final reconciliation, and final documentation.
(1) Design Criteria Development The Trains A and B conduit support design-basis dccument (DBD), "Conduit and Conduit Supports Design Trains A, B, and Greater than Two Inches Diameter Train C Conduit," 080-C5-90, which includes project design criteria and procedures has been developed by Ebasco for its scope of work under the CAP design valida-tion of Trains A and 8 conduit supports.
The Train C conduit support design criteria and methodology used in the imple-mentation of the CAP design validation process were developed by Impell Corpora-tion and are described in the Train C conduit support design-basis document (DRD), "Seismic Adequacy of Train C Conduits (Two Inch Diameter and Less),"
l Comanche Peak SSER 16 4-1 l
DBD-C/S-093, dated November 4, 1987.
These criteria and evaluation methods address tne potential for failure of non-safety-related Train C conduits and supports and the subsequent interaction potential with safety related plant features and with control room personnel.
The technical bases for the CAP design criteria were established through ex-tensive testing and engineering studies performed specifically for CPSES.
The DBD ensures that licensing commitments including those in the CPSES final safety analysis report (FSAR) (Reference 22) are properly documented and appro-priately addressed in the design procedures.
(2) Design Validation The design validation for Trains A and B conduit support provides a comprehen-
<! u program for the structural analysis and qualification of safety-related conduit supports at CPSES.
The scope of the CAP implemented for CPSES Unit l' and for common areas
- includes both seismic Category I Trains A and B and non-seismic Category I (Train C larger than 2 inches in diameter) conduit supports as defined in RG 1.29 (Reference 9), Position C.2 (also referred to as "seismic Category II").
The design validation for Train C conduit systems provides a comprehensive pro-gram for demonstrating that their seismic design and installation comply with applicable regulatory and licensing provisions for CPSES.
The scope of the CAP implemented for CPSES Unit 1 and for common areas
- includes Train C conduit supports as defined in RG 1.29 (Reference 9) Position C.2 (also referred to as "seismic Category II").
Design validation includes (a) establishing design input for conduit and con-duit support analytical models, (b) conducting design analyses and evaluations of conduit and conduit supports (including fittingt and clamps), (c) identify-ing hardware modifications to satisfy design criteria, and (d) reconciling analyses, modifications, and inspection results to ensure consistency between Trains A, B, and C conduit support design documentation and hardware installa-tion.
The results of design validation are documented in conduit support design validation packages (DVPs) consisting of as-built conduit support data, and design-validated conduit support drawings.
The OVPs provide the necessary documentation to ensure compliance with the design criteria and licensing commitments.
(3) Hardware Validation The applicant established the Post-Construction Hardware Validation Program (PCHVP) (References 15 and 16) as a complete validation of final acceptance attributes; it includes those attributes for the reinspection of Trains A, B, and C conduit and conduit supports.
Reinspection by either physical verifica-tion or engineering evaluation is performed for those inspection attributes associated with (a) CPRT recommendations to reinspect, (b) changes to design or to a hardware final acceptance attribute that is more stringent than the original acceptance attribute or those attributes not inspected by the CPRT, or (c) modifications to existing conduit and conduit supports.
- Common areas refers to the areas of the CPSES plant containing systems, components, and equipment that serve both Units 1 and 2.
Comanche Peak SSER 16 4-2
The PCHVP provides assurance that as-installed Trains A and B conduit supports and as-installed Train C conduit supports are in conformance with validated design documents.
(4) Final Reconciliation The final reconciliation consolidates analysis, hardware modification, and in-spection documentation to ensure consistency of the installed Trains A, B, and C conduit supports with the supporting design documentation.
The conduit support results are also confirmed by interfacing organizations to ensure compatibility with their validated design.
The final reconciliation ensures that the conduit support DVPs adequately validate the installed hardware.
(5) Final Documentation The final documentation requires that all conduit support DVPs are transmitted to the permanent records facilities and ensures that the results of the CAP are adequately maintained and retrievable.
On the basis of its review, the staff finds that the overall CAP process for Trains A, B, and C conduit supports provides a complete program for ensuring 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 Development 4.1.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter In conjunction with the Design Basis Consolidation Prcgram (Reference 19),
Ebasco identified and documented the design criteria for Trains A and B conduit and conduit supports in the conduit support design-basis document (DBD-CS-90).
On the basis of the design criteria established in the design-basis document, Ebasco develuped design procedures (see Appendix B to this supplement) to be used in the Trains A and B conduit support design validation.
The design pro-cedures included the methodologies used in the resolution of technical issues raised by sources external to the TU Electric project organization (i.e., CYGNA, CPRT, and the NRC staff).
The design procedures, based on licensing commit-ments, regulatory guides, industry codes, and standards, utilized the collective design experience of Ebasco in the design of conduit supports in other nuclear facilities.
The Trains A and B conduit support design procedures were validated through extensive testing and engineering studies discussed herein.
The design criteria and methodology discussed in the following sections were reviewed and evaluated by the staff during audits and inspections conducted at the offices of Ebasco Services Incorporated and at the CPSES site.
Appendix C of this supplement provides a brief description for each of these audits and inspections.
The criteria and methodology reviewed and evaluated by the staff are presented in the following sections which address:
(1) load and load combinations (2) seismic analysis methods Comanche Peak SSER 16 4-3
)
(3) structural acceptance criteria (4) test programs (5) special studies Additional items relating to criteria and methodology developed to resolve con-duit support technical issues raised by external sources are discussed in Appendix.A of this supplement.
Many open items raised during the staff audits and inspections of the conduit design criteria and methodology have been resolved and their closure was docu-mented in NRC Inspection Reports 50-445/87-39, 50-446/87-30, dated June 6,1988.
The remaining open items were resolved and found acceptable by the staff during the staff audit at the CPSES site on June 13-16, 1988.
The description of these remaining open items and the basis for their closure are presented in Appendix D to this supplement.
(1) Loads and Load Combinations Trains A and B conduit systems, which include conduits, junction boxes, and supports, are required to remain functional under all normal operating and acci-dent plant conditions.
All of the applicable loads and load combinations to be utilized in design are specified in the design-basis document and in design procedures listed in Appendix B to this supplement.
The primary design pro-cedures for Trains A and B conduit systems that define the loads and load com-binations to be used in design validation are Ebasco criteria SAG.CP2 (for Unit 2 conduit and supports), SAG.CP10 (for Unit 1 conduit and supports),
SAG.CP12 (for Unit 2 junction boxes), and SAG.CP17 (for Unit 1 junction boxes).
The loads include deadweight load, operating-basis earthquake (OSE) load, safe-shutdown earthquake (SSE) load, thermal load, and pipe break loads.
For struc-tural steel components, load combinations for service load condition and factored load condition were specified in accordance with those defined in the CPSES FSAR (Reference 22).
For conduits cast in place in concrete walls and slabs, load combinations applicable to concrete structures were specified consistent with the CPSES FSAR.
To address a concern raised by CYGNA regarding the selection of the OBE load combination as the governing load case used in the original design, Ebasco required that conduits and supports be evaluated for both OBE loads and SSE i
loads separately.
See Appendix A (Section 1) to this supplement, for further details on this issue.
To address the effects of thermal loads on generic conduit systems, Ebasco per-formed special studies.
These studies evaluated the effect of thermal loads that result from normal operating and accident conditions in combination with deadweight and seismic loads.
With some limitations, as discussed later in this section, the results of the studies demonstrated that thermal loads do not have to be explicitly considered in the design validation effort based on the conservative criteria and analysis methodology utilized at CPSES.
Other loads, which include jet impingement, pipe whip, missiles, and tornado effects, have been addressed by Ebasco and are discussed in Appendix A (Sec-tion 6) to this supplement.
Comanche Peak SSER 16 4-4
The staff reviewed the criteria presented in the Trains A and B conduit support design-basis document and in Ebasco criteria SAG.CP2, SAG.CP10, SAG.CP12, and SAG.CP17 with respect to the definition of.the required loads and load combina-tions. The loads and load combinations specified in these documents were determined.to be in agreement with those specified in the CPSES FSAR and are, thus, acceptable.
(2) Seismic Analysis Methods Ebasco used the equivalent static method and response spectra method for evalu-ating the seismic response of the conduit systems.
The criteria established by Ebasco for the seismic analysis methods are specified in SAG.CP10 and SAG.CP2 for Units 1 and 2, respectively.
The equivalent static method (ESM) first requires that the conduit frequency (f ) and support frequency (f ) be calculated separately.
The system frequency c
s is calculated using the equation:
1 1
1_
+
2 2
2 f
f I
c s
Seismic design acceleration values are tabulated for the various buildings and elevations based on minimum frequency requirements.
The dynamic amplification effects are considered by using a dynamic amplification factor (DAF) which is dependent on the system frequency.
If the system frequency is not calculated or if the frequency is calculated and is equal to or less than the frequency corresponding to the peak of the floor spectra, then a DAF of 1.5 is utilized.
If the system frequency is greater than the frequency at the spectrum peak, then a DAF of 1.25 is utilized.
See Appendix A (Section 2) to this supplement for the staff's evaluation of the DAFs.
On the basis of its review of the equivalent static method, the staff finds that the analytical method conservatively predicts the seismic response of conduit i
systems and uses a technically justified dynamic amplification factor.
The j
method is an accepted method in accordance with Section 3.9.2 of the NRC j
Standard Review Plan (Reference 23) and is thus acceptable for use at CPSES.
Ebasco presented its guidelines for performing response spectra modal (RSM) analysis in SAG.CP20 and SAG.CP25 for conduits and supports and SAG.CP17 for i
conduit systems with junction boxes for Unit 1.
RSM analysis was used to justify the DAFs of 125 used in the ESM described above and to evaluate the conduit isometrics which did not satisfy the acceptance criteria specified in Ebasco drawings 2323-S-0910.
Supports satisfying the minimum frequency requirements are modeled as equivalent springs in each of the three directions.
The STRUDL computer program was utilized for the RSM analysis and was upgraded to include (1) the 10 percent combination method for closely spaced modes in accordance with RG 1.92, "Combining Modal Responses and Spatial Components in Seismic Response Analysis" (Reference 24) and (2) missing mass for rigid modes in accordance with NRC Standard Review Plan Section 3.9.2 (Reference 23).
l On the basis of its review of the RSM analysis method, the staff finds that the l
RSM analysis method utilizes a modal combination method in accordance with the
)
l l
Comanche Peak SSER 16 4-5 4
guidelines of RG 1.92 (Reference 24) and uses an adequate number of masses to determine the response of the system in accordance with Section 3.9.2 of the NRC Standard Review Plan (Reference 23).
The staff concludes that the RSM analysis method is a suitable method for performing dynamic analysis of conduit systems at CPSES and is thus acceptable.
Damping values used for the ESM and RSM analysis methods are generally 2 per-cent for OBE and 3 percent for SSE as specified in the CPSES FSAR and are in accordance with RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants" (Reference 25).
The use of these damping values is thus acceptable.
Higher damping values are utilized in two instances.
The design of CSR (air-craft cable) supports is based on 7 percent damping for the SSE and the design validation of SP-type supports (attached to the spread room frame) utilizes 4 percent damping for OBE and 7 percent for SSE.
Ebasco justified the use of 7 percent damping fo-CSR supports on the basis of the Impell report, "Justification of Damping Value," Report No. 01-0210-1527, Rev. 1, December 1986.
This report justifies the use of 7 percent damping for Train C conduit under the SSE and is discussed in detail in Section 4.1.1.2 of this supplement.
Additional justification given by Ebasco for the use of 7 percent damping was (1) the similarity of the CSR support components with bolted steel structures where 7 percent damping is considered acceptable and (2) the non-safety-related classification of Train C conduits which could per-mit their deformation beyond the elastic limit resulting in higher "equivalent" damping.
The staff evaluation of the use of 7 percent damping for Train C' conduit supports is provided in Section 4.1.1.2 of this supplement.
Based on its review of the applicable test results and Impell Report No. 01-0210-1527, the staff finds the use of 7 percent damping under SSE loadings for CSR supports to be acceptable.
For SP supports, Ebasco justified the use of 4 percent and 7 percent for OBE and SSE, respectively, by requiring SP supports and conduits to be in the rigid range of the seismic spectra.
Thus, their response is determined by the excitation of the spread room frame to which they are attached.
Ebasco concluded that because the spread room frame is a bolted steel structure, the use of 4 percent damping for OBE and 7 percent damping for SSE to obtain the seismic acceleration response of the spread room frame is in acccrdance with the guidelines of RG 1.61 (Reference 25).
Thus, the SP supports are designed to the peak of the floor response spectra corresponding to 4 percent and 7 percent damping for 0BE and SSE, respectively, with the appropriate DAFs.
Because SP supports are required to be designed so that their fundamental frequency falls within the rigid range of the seismic response spectra, the staff finds that the response of the SP supports is determined by the excitation of the spread room frame (a bolted steel structure).
For bolted steel structures, the staff finds the use of 4 percent damping for OBE loadings and 7 percent damping for SSE loadings is in accordance with RG 1.61 (Reference
The staff reviewed Ebasco criteria SAG.CP10, SAG.CP2, SAG.CP20, and SAG.CP25 with respect to seismic analysis methods.
The criteria methodology used by Comanche Peak SSER 16 4-6
Ebasco to perform equivalent static and response spectrum method of analysis for seismic loads is consistent with industry practice.
The methods of analysis including damping values meet CPSES licensing commitments, the NRC Standard Review Plan, and applicable regulatory guides as discussed above, and thus are' acceptable.
(3) Structural Acceptance Criteria Ebasco criteria for conduits, welds, and supports members required that stresses meet allowable values specified in the applicable governing specification / code.
Thus, the American Institute of Steel Construction (AISC)
"Specification for the Design, Fabrication and Erection of Structural Steel for Buildings" (Reference 26) was adhered to for structural steel components.
The allowable values for Unistrut members were based on the AISI, "Specification for the Design of Cold-Formed Steel Structural Members" (Reference 27).
The weld allowable values were in accordance with American Welding Society (AWS)
Code D 1.1-79, "Structural Welding Code" (Reference 28).
The 33 percent increase in allowable stress due to seismic loadings allowed by the codes was not permitted by Ebasco procedures.
However, allowable stresses were increased for load combinations, in accordance with the acceptance limits specified in the CPSES FSAR.
Specific acceptance criteria were developed for Nelson stud connections.
Local stress, due to pre-tension from the Nelson stud welded directly to structural tubing, was permitted to exceed the yield stress in the local region.
- However, j
the ductility ratio (maximum permissible deflection of a structural system to the deflection at "effective yield" for the system) was limited to 10.0.
The use of ductility ratios to demonstrate the structural adequacy of structural steel elements in a non-linear response due to impactive or impulsive loads is an accepted method per Section 3.5.3, Appendix A, of the NRC Standard Review Plan (Reference 23).
Because the Ebasco methodology calculates the ductility ratio for the Nelson-stud-to-tube connection under seismic loads and limits the i
ratio to 10.0 in accordance with the limits specified in Section 3.5.3, l
Appendix A, to the Standard Review Plan, the staff concludes that this approach is acceptable.
For shim plates, the local stress resulting from the pre-tension of Nelson studs was design verified in accordance with the plastic design method of the AISC Code (Reference 26).
The use of the plastic design method in accordance with the AISC Code is an accepted method per NRC Standard Review Plan (Reference 23) Sections 3.8.3 and 3.8.4, and is thus acceptable for use at CPSES.
For conduits embedded in concrete walls or slabs, loads acting in the longi-tudinal direction (parallel to the conduit) were considered.
However, moments, shears, and other forces transferred to the concrete by bearing were not con-sidered because of the minimal stresses resulting in the concrete. To check for longitudinal loads, the allowable bond strength for conduit penetrations was developed by Ebasco in accordance with the ultimate strength section of American Concrete Institute (ACI) 318-63 Code (Reference 29).
The ACI 318-63 Code was used.because the ACI 318-71 Code (Reference 30), referenced in the CPSES FSAR, does not address plain bars (which more closely simulate the conduits).
The staff finds the ACI 318-63 Code provides applicable design t
Comanche Peak SSER 16 4-7 l
l
guidelines for establishing the ultimate bond strength of conduit embedded in concrete, and its use is thus acceptable.
(4) Test Programs Ebasco established allowable conduit clamp loads on the basis of tests per-formed by Corporate Consulting and Development Company Ltd. (CCL).
The purpose of the tests was to develop conduit clamp capacities based on the as-built conditions found in the field.
The test program was also intended to address the concerns raised regarding proper clamp usage (see Appendix A, Section 18 to this supplement).
The test program consisted of two phases.
Phase I test results are documented in CCL Report No. A-699-85, "Conduit Clamp Test Report, Phase I," December 17, 1985, and Phase Il test results are documented in CCL Report No. A-702-86, "Conduit Clamp Test Report, Phase II," April 7, 1986.
In Phase I, 29 test con-figurations were examined both statically and cyclically.
Three identical samples were tested for each configuration.
The test configurations consisted of various combinations of clamp type, clamp size, number of anchors, anchor type, anchor size, anchor spacing, filler plate thickness, and preload.
In Phase II of the test program, cyclic load tests and additional static tests were performed on a total of 73 configurations.
Various combinations of clamp connections were tested as in Phase I.
However, additional types and ranges of parameters were considered in Phase II and cyclic tests were performed for 62 of the configurations in addition to static tests.
The test configurations that were examined correspond to the conduit clamp details specified on the design drawings.
The test program included configura-tions that address the issues raised regarding pruper clamp usage such as over-sized bolt holes, clamp distortions, and reduced edge distances.
The static test results were used in determining clamp stiffnesses and the preliminary allowable clamp loads.
The cyclic tests were performed to demonstrate the adequacy of clamps when they are subjected to load reversals representative of the design seismic loads.
The staff evaluation of the con-duit support ciamp tests is discussed further in Appendix A (Section 18) of this supplement.
Testing was also utilized to establish the allowable support capacities for Unistrut supports.
The test results are documented in CCL Report No. A-678-85, "Seismic Qualification Test Report of Conduit Support Systems," Volumes I and II, October 9, 1985.
These tests were performed to address concerns regarding the torsional capacity of Unistrut members, the use of Unistrut components in ways not intended by the vendor, and the loading of joint configurations for which no design allowable values were available.
CCL statically tested 16 support configurations (12 in the CCL laboratory and 4 on site).
Loads were simultaneously applied in the three orthogonal directions in increments.
The supports were loaded to failure which was defined as anchor pullout or fracture, member buckling, or large deformation of the support.
To address additional concerns with the test configurations and test procedure /
setup, Ebasco reviewed and evaluated the test results (see Appendix A, Section 8 to this supplement).
Only those Unistrut supports that adequately repre-sented the support confiaurations at CPSES and were not affected by inadequate l
Comanche Peak SSER 16 4-8
l l
testing were deemed acceptable by Ebasco for use at CPSES.
Thus, many Unistrut l
supports were replaced, except support types CA-1, CA-2, CA-8, JA-1, JA-2, and i
JA-3.
These support types are all comprised of Unistrut sections attached directly to concrete (i.e., with no cantilevered or extended components).
On the basis of the test results, Ebasco performed calculations to develop allowable capacities for the Unistrut supports which were enveloped by the tested configurations (support types CA-la, CA-2a, JA-1, and JA-2).
Other support types (CA-lb, CA-2b, CA-8, and JA-3) were also qualified, by comparison l
l and analysis because of their similarities to the qualified supports with only minor changes.
All other Unistrut supports were to be replaced.
The calculations performed by Ebasco to establish the allowable values for the
{
Unistrut supports accounted for differences between tested configurations and qualified supports such as member and anchor bolt size substitution and toler-ances in bolt spacing.
The test results presented in CCL's test reports for j
each configuration were based on the worst-case results of the three tests performed on each configuration.
The calculations conservatively assumed that the support failure was governed by anchor bolt failure.
Thus, a safety factor of four was used for the SSE load conditions, and a safety factor of five was used for the normal (design) and OBE load conditions.
l The staff evaluation of the test program and analysis performed by Ebasco for Unistrut supports finds that the resulting allowable support loads were developed appropriately and resolve the external irisues not addressed by other Ebasco documents.
(5) Special Studies Ebasco performed numerous special studies for CPSES to establish design cri-teria for the design validation of conduit systems at CPSES.
The special studies were used to provide the bases for resolving specific external source issues related to the design of conduit and conduit supports.
Ebasco performed special studies to address the effects of thermal loads on generic conduit systems.
As explained in Section 4.1.2.1.1 of this supplement, the generic conduit span allowable values and conduit support capacities are documented in Ebasco drawings 2323-S-0910 and 2323-S2-0910 for Units 1 and 2, respectively.
Because of the large number of combinations of variables for conduit systems (e.g., number of conduits on a support, size of conduit (s),
span lengths, conduit support, and clamp stiffnesses), thermal load effects are 1
not explicitly evaluated in the generic design verification.
To use enveloping yet conservative values for these variables would result in unreasonable limi-tations on the conduit systems.
Thus, Ebasco performed thermal analyses for numerous conduit configurations intended to be representative of the various conditions applicable to the CPSES facility.
These analyses were performed for normal operating thermal load and accident thermal load (resulting from a loss-of-coolant accident) in combina-tion with deadweight and seismic loads.
Refined analyses were performed using_
the conservatisms inherent in the conduit and support designs which meet the requirements of drawings 2323-5-0910 and 2323-S2-0910.
From these analyses, Comanche Peak SSER 16 4-9
Ebasco concluded that, for normal thermal load combination, the support capaci-ties computed on the basis of deadweight and seismic loads are not required.to be reduced to accommodate thermal effects.
This conclusion limits total con-duit length in the reactor building to 45 feet or less between expansion joints and 75 feet or less for the other buildings.
The same conclusion was reached for the accident thermal load combination with the total conduit length limited to 45 feet and certain support types requiring accident thermal load evaluation on a case-by-case basis.
The staff reviewed the approach that Ebasco had used in performing its studies.
The scope, method of analysis, and ccceptance criteria were found acceptable.
However, when evaluating the accident thermal load combination, Ebasco did not consider peak accident thermal load with seismic load.
Instead, the following two load conditior.s were considered:
(a) seismic plus accident thermal load occurring during the short duration of the seismic event (b) peak accident thermal load with no seismic load To justify the above approach, Ebasco performed an additional study whe'reby seismic load plus peak accident thermal load was considered simultaneously for the worst-case configuration determined from the earlier studies.
The results of this study verified that the general conclusions reached previously regard-ing thermal load effects remain unchanged.
This occurs because thermal load effects are most significant for stiff conduit / support configurations, while the additional effect of seismic loads on stiff conduit / support configurations are generally small or negligible.
On this basis, the staff finds the approach acceptable.
Ebasco performed another study to confirm the span-allowable values specified in drawings 2323-S-0910 and 2323-S2-0910.
This study also verified the support design acceleration values (design "g") tabulated in SAG.CP2 and SAG.CP10.
i Ebasco prepared guidelines for performing the analyses of conduit systems and presented these guidelines in SAG.CP20.
The study consisted of performing response spectrum analyses for 14 span configurations selected as the governing cases.
These configurations covered all in plane straight runs, bends, saddles, and their combinations listed in drawings 2323-S-0910.
The design of i
out-of plane bend configurations were not validated generically in the span study.
They have been deleted from the 2323-5-0910 drawings and are to be l
4 qualified on a case-by-case basis during isometric design validation.
Span configurations in Unit 2 drawings 2323-52-0910 are the same as those in the 2323-5-0910 drawings for Unit 1.
The conduits were modeled as beam elements, and supports were modeled as equivalent translational springs in each of the three orthogonal directions.
Bends were modeled using a series of straight segments.
A minimum number of nodal points were specified for different conduit spans (e.g., at least two nodal points for overhang conduit spans).
The weight of the conduit, cable, flexible conduits, and conduit fittings (e.g., BCs, LBDs) were included.
Embedded conduits were modeled with a three-way hinge support.
Comanche Peak SSER 16 4-10
Minimum frequencies were imposed in Units 1 and 2 for conduit supports.
- Thus, the supports were modeled as equivalent springs with the spring constant deter-mined from the support frequency and tributary mass.
Minimum frequencies for conduit systems were also imposed in SAG.CP20.
The principle followed in the modeling and analysis was to consider systems having the lower bound system frequency allowed by criteria.
This approach was followed because for fre-quencies on the stiff side of floor response spectra peaks, lower conduit system frequencies result in larger seismic response of the system.
The 14 span configurations were analyzed for all building elevations to deter-mine conduit member' forces or stresses, support reactions in all three direc-tions, seismic displacements, and system fundamental frequency.
Conduit member forces or stresses were used to design verify the adequacy of conduit stress.
Span-allowable lengths were reduced when the stresses exceeded allowable limits.
Support reactions were used to compute support accelerations and then compared with "approximate" (preliminary) design accelerations (design "g").
When the approximate design g values were exceeded by the calculated support g values, the approximate design g values were replaced with the calculated g values.
Design g values were tabulated for each building and elevation.
Con-servatively, the envelope g values from all conduit sizes and span configurations were defined as the final seismic design g values for the given location.
Thus, final seismic design g values were developed and presented in the SAG.CP10 procedures for Unit 1.
In Unit 2, when the support g comparison failed the approximate g was not increased.
Instead, the span allowable was reduced to satisfy the design g comparison.
The design g values for Unit 2 are presented in SAG.CP2.
The staff reviewed the methodology utilized by Ebasco in SAG.CP20.
The model-ing, analytical methods, frequency requirements, and the application of results were evaluated in terms of its technical adequacy and its consideration of issues raised by external sources.
The staff finds that the approach used to qualify the conduit span lengths and configurations adequately considered tne governing conduit configurations, utilized technically sound analytical methods, and developed conservative design limits, and is thus acceptable.
4.1.1.2 Conduit Supports for Train C Less Than or Eaual to 2 Inches in Diameter In conjunction with the Design Basis Consolidation Program (Reference 19),
Impell identified and documented the design criteria for Train C conduit and conduit supports in DBD-C/S-093, "Design Basis Document - Seismic Adequacy of Train C Conduits (Two Inch Diameter and Less)," Revision 1, dated November 4, 1987.
On the basis of these design criteria, Impell developed procedures and guidelines to be implemented in the Train C conduit support design validation effort.
The design criteria and methodology were developed for Train C conduit, in part, to resolve the technical issues raised by the NRC staff's Technical Review Team (TRT).
The design criteria provide for (1) an evaluation of the structural integrity of the conduit and supporting systems and (2) an assessment of the effect of physical interaction with seismic Category I rtructures, systems, and compo-nents.
In addition, the design criteria and methodology for Train C conduit l
Comanche Peak SSER 16 4-11
supports address the issues raised during the CYGNA Independent Assessment Program for Trains A and B conduit supports (Reference 5) as they apply to Train C conduit supports.
These concerns include support self-weight, anchor
(
bolt design, clamp usage, and edge-distance violation.
The staff evaluation of i
the applicability of Trains A and B conduit support issues to Train C is pro-
{
vided in Appendix A to this supplement.
In addition, two issues concerning Hilti Kwik-Bolt safety factors and Train C conduit damping values were. resolved i
through special studies and testing and are addressed below.
The acceptance criteria used by Impell for Hilti Kwik-Bolt concrete expansion anchors in the Train C design validation is based on a safety factor of three to the average ultimate strength for the safe-shutdown earthquake condition.
The manufacturer's recommended safety factor is four.
The justification for a safety factor of three is documented in Impell Report No. 01-0210-1483, "Hilti Kwik-Bolt Concrete Expansion Anchors, Justification of Factor of Safety," July 1987.
The staff evaluation of the adequacy of a safety factor of three follows.
10 CFR Part 50, Appendix A, states in part in General Design Criterion 1, "Structures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed."
RG 1.124, "Service Limits and Loading Combinations for Class 1 Linear-Type Component Supports" (Reference 31), states that:
Component supports are deformation sensitive because large defor-mations in them may significantly change the stress distribution in the support system and its supported elements....Since compo-nent supports are deformation-sensitive load bearing elements, satisfying the service limits of Section III will not automatic-ally ensure their proper function.
Deformation limits, if spect-fied by the Code Design Specification, r.ay be the controlling criterion.
On the other hand, if the function of a component support is not required for a particular plant condition, the stresses or loads resulting from the loading combinations under that plant condition do not need to satisfy the design limits for the plant condition.
IE Bulletin 79-02, "Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts" (Reference 32) states, "(t)he purpose of IE Bulletin No. 79-02 and this revision is to assure the operability of each seismic Category I piping system."
The statements from RG 1.124 (Reference 31) acknowledge the feet that Class 1 component supports (including safety-related pipe supports but not non-safety-related conduit supports) provide an important function of maintaining small deformations to ensure the operability of the supported component.
IE Bulletin 79-02 similarly acknowledges that the safety factor of four (for wedge type anchors) and the baseplate flexibility, both of which are included in the bulletin, are to ensure the operability of the piping system.
Consequently, RG 1.124 and IE Bulletin 79-02 emphasize the need for the design of component supports commensurate with the importance of the safety functions to be per-formed (i.e., operability of the supported component).
Comanche Peak SSER 16 4-12 I
For the design of anchor bolts in Category II conduit supports, the staff re-viewed whether the same degree of safety margin is required to be provided as that provided for safety-related piping supports.
Because the safety function of Category II conduit supports is to ensure only the structural integrity of the conduit system, and is not needed to ensure component operability, the staff finds that the design considerations required for Category II conduit supports should accordingly be established commensurate with the importance of the safety function to be performed (i.e., ensuring structural integrity).
The design considerations and the basis for the safety factor appropriate for Category II conduit supports are discussed in detail in the paragraphs that follow.
The design of concrete anchors is generally governed by the rules of ACI-349, Appendix B.
The American Concrete Institute (ACI) in its Appendix B to the Code Requirements for Nuclear Safety Related Concrete Structures (ACI 349-80)
(Reference 33) states in Section B.7.2, "(f)or expansion anchors that do not meet the requirements of Section B.7.1, the design strength shall be 0.33 times the average test failure load." Thus, the ACI Code accepts a safety factor of three to the average test failure load for concrete expansion anchors.
In Appendix B to NUREG/CR-2137, "Realistic Seismic Design Margins of Pumps, Valves, and Piping" (Reference 34), a simple statistical evaluation is pre-sented which is based on the results of a test program conducted by Teledyne Engineering Services reported in its summary report, "Generic Response to USNRC IE Bulletin 79-02, Base Plate / Concrete Expansion Anchor Bolts," August 30, 1979.
The statistical evaluation of the data given in NUREG/CR-2137 indicates that by using one-fourth of average strength as a design basis, the probability of failure at two times the design load is about 0.023 and less than 0.001 at the design load.
Thus, it can be concluded that at CPSES where a safety factor of three (or 1.33 times the design load) is used for Train C conduit systems, the probability of failure ranges between 0.001 and 0.023.
The staff further reviewed the ultimate strength of drilled-in concrete expan-sion anchor bolts for dynamic and vibratory loadings.
The safety factor of four, as recommended by anchor bolts manufacturers, is generally applicable to static loadings.
The design margin to failure for seismic loadings which are dynamic and vibratory in nature is a function of both load magnitude and the number of cycles.
A report on a study by Bechtel Power Corporation to justify the use of expansion anchor bolts in the Fast Flux Test Facility (Richland, WA) was prepared for the Hanford Engineering Development Laboratory and is entitled, "Drilled-in Expansion Bolts Under Static and Alternating Load" (January 1975).
The objective of this study was to establish the allowable j
design loads (tension, shear, and combined load) for expansion bolts to be 1
installed in various mixes of concrete.
The test loads included static loads and alternating loads which simulated the dynamic earthquake loads.
The expansion bolts included the stud-type wedge anchors manufactured by Hilti Fastening Systems.
The seismic loading was simulated by about 6000 cycles of a i
sine wave which varied from 0 to 0.2S (where S is the static load capacity of the anchor bolt and 0.2S corresponds to a safety factor of five).
The test found that all expansion bolts that were tested successfully withstood 6000 cycles of 0 to 0.25, alternating load as designated for seismic qualification.
The dynamic load capacities of the expansion bolts were found to be the same as j
their corresponding static load capacity.
It was further discovered that at 1
Comanche Peak SSER 16 4-13 1
l
l 6000 to 7800 load cycles, when the dynamic test load sequence was increased to 0.65 (or a safety factor of 1.67), subsequent alternating loading caused appreciable wedge movement (or "walking").
If the bolt did not fail in a brittle mode because of pull-out or in some other premature failure mode (e.g.,
poor installation), the "walking" ceased after a certain number of load cycles.
Extensive dynamic testing of expansion anchor bolts by Hanford Engineering Development Laboratory was also discussed in NUREG/CR-2999, "Final Report -
USNRC Anchor Bolt Study Data Survey and Dynamic Testing," dated December 1982 (Reference 35).
It was found that, when the installation torque is properly applied, residual preload does not significantly affect anchor load displace-ment characteristics until the preload drops to less than 50 percent of the l
full installation preload.
The staff has determined from the ultimate dynamic load capacity and the number of cycles to failure, that a minimum design margin of 1.8 exists when a safety factor of three is used for concrete anchor bolts in installations where support stiffness is not critical.
The number of cycles tested exceeded the minimum number of seismic cycles recommended in Standard Review Plan Section 3.9.2 (10 SSE and 50 OBE) (Reference 23) by approximately a factor of three.
It should be noted that in 3 out of 20 tests the anchors did experience 1/4-inch bolt pullout at a load less than the load corresponding to a safety factor of three.
However, no bolts failed until the safety factor decreased to 1.67.
Thus, the staff finds that the dynamic testing performed by Bechtel and Hanford Engineering Development Laboratory provide similar results.
Considering the j
dynamic testing discussed above, the staff finds that when the wedge-type expansion anchor bolt (e.g., Hilti Kwik-Bolt) is designed to a safety factor of three, the structural integrity of the anchor is maintained, although appre-ciable slippage may occur in some bolt installations.
The staff concludes that a safety factor of three for wedge-type concrete expansion anchor bolts (e.g.
Hilti Kwik-Bolts) when used in Category II (Train C) conduit supports is commensurate eith the importance of the safety function to be performed (i.e.,
ensuring structural integrity) and is, thus, acceptable.
Impell used a damping value of 7 percent in the analysis of Train C conduit systems for the safe-shutdown earthquake (SSE).
The justification for the damping value is documented in Impell Report No. 01-0210-1527, "Justification of Damping Value," May 1988.
The CPSES FSAR (Reference 22) provides a damping value of 7 percent under SSE loadings for bolted steel structures such as conduit systems, which is con-sistent with RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants" (Reference 25).
l l
RG 1.61 delineates damping values to be used in elastic-dynamic seismic anal-ysis of structures, systems and components.
Table 1 of RG 1.61 provides a l
modal damping value, as a percentage of critical damping, of 7 percent for l
bolted steel structures under SSE earthquake loading.
RG 1.61 also states that higher damping values may be used if documented test data are provided to support higher values.
Impell used static and dynamic test data to verify that the Train C conduit and supports are sufficiently similar to bolted structures that use of the 7 percent damping value specified by RG 1.61 is appropriate.
Comanche Peak SSER 16 4-14
Two test programs, undertaken to investigate damping levels on conduit systems, were cited in support of the 7 percent damping factor.
The first test program was performed by ANC0 for Bechtel Power Corporation as documented in a report, "Cable Tray and Conduit Raceway Seismic Test Program," 1053-21.1-4, Volumes 1-3 (Final), dated December 15, 1978.
The test measured damping for the conduit supportad on clamps similar to CPSES Type 5 supports and_ on Unistrut-type supports similar to CPSES Types 4, 7, and 8.
The ANC0 test program included 29 conduit specimens on clamped supports and 12 conduit specimens on Unistrut supports.
The conduit runs were 28 feet long and were supported at three points with 10 feet spacing for most tests.
The rigid steel conduit used for the tests were of 3/4-inch, 2-inch, and 4-inch diameter for the clamp tests and 2-inch and 4-inch diameter for the Unistrut hanger tests.
All tests were conducted with 100 percent cable fill.
One test sequence for the clamp-supported conduit was performed on a 2-inch conduit with 0- and 50 percent cable fill, so that a comparison could be made with the 100 percent cable fill tests.
The Unistrut supports tested were of the single-tiered trapeze type made of two vertical Unistrut-type members and a horizontal Unistrut-type member on which the conduit was clamped.
The trapeze support was similar to CPSES Train C Type 4, 7, and 8. supports.
For the Unistrut tests, ANC0 reported damping of 9 percent at 0.20 g for a braced support, and a damping of 13 percent at 0.25 g for an unbraced support.
For the clamp-supported conduit, damping of no more than 2.5 percent was shown j
for the clamp type most similar to the one-hole clamp (CPSES Type 5 support).
However, differences existed between the clamp configuration and test conditions relative to those of CPSES for Type 5 clamps.
Specifically, the tested clamp did not include the CPSES Type 5 spacer plate between the condait and the attachment surface, which would tend to increase the damping effect.
i Also, the level of cable fill for all tests, with one exception, was 100 percent greater than the CPSES maximum cable fills of 40 percent.
The results of the test performed with a 50 percent cable fill indicated an increase in damping over tests having 100 percent fill level.
However, an uncertainty existed because the 50 percent fill tests were performed with clamps not similar to CPSES Type 5.
Since these tests were not conclusive for CPSES Type 5 supports, further test-ing was conducted.
Specifically, the new tests more closely simulated CPSES Type 5 support hardware, represented more accurately the level and frequency content of input acceleration, and included the amount of cable fill representative of CPSES conditions.
In this second test program, performed by ANC0 in 1986, SSE level input motions were applied to the conduit supported by actual CPSES Train, C Type 5 supports and containing representatite CPSES Train C coaductor fills.
A 2-inch-diameter steel conduit system was constructed on a shake frame.
The conduit run contained a 90-degree horizontal bend with fivo Type 5 supports attached at intervals of 9 feet or less to the shake frame as if the system were ceiling mounted.
Typical Train C conductor fills of 10, 20, 30, and 40 percent based on volume were used.
The conduit dynamic response was measured at three Comanche Peak SSER 16 4-15
locations:
at the bena in the vertical direction and at the midspan of a straight segment in the vertical and transverse directions.
Response time histories of relative displacement and of acceleration were measured at each l
location.
The acceleration time histories at all support locations were measured.
Impell performed a test / analysis comparison (Calculation No. ROTC-37, "Damping Determination, Test Vs. Analysis," September 16, 1986) to assess the level of i
damping.
In the analysis, the test input motions were applied to a finite-element model of the conduit system.
The analysis model used 7 percent damping and considered cable fills of 10 to 20 percent and 40 percent.
Correlation between the test and analysis results was assessed by comparing the responses for each.
Analysis-to-test response ratios for displacement and acceleration were calculated twice, using first the single maximum peak' responses and second the absolute sum of all peaks greater than 20 percent of the maximum responses.
For ratios less than one, the result would indicate that the damping factor used in the analysis is overestimated.
Ratios greater than one indicate the analytical damping factor used was underestimated.
The averages of the 30 data points for each method were 1.006 and 1.140, indi-cating that the use of 7 percent damping overestimated the response of the test configuration.
That is, the test results when compared with typical analytical techniques used for Train C conduit systems indicated a higher level of damping than the 7 percent used by Impell.
An analysis of scatter in the data indicates that 18 of 30 points (60 percent) fall within one standard deviation, and 29 of 30 points (97 percent) fall within two standard deviations.
l The staff's review of the Impell calculation finds that the justification for using a 7 percent damping value is based on a conservative interpretation by Impell of the ANCO dynamic test results for CPSES Type 5 supports, i
On the basis of the results of the tests described above, the staff finds that a damping factor of 7 percent for non-safety-related Train C conduit support systems, when used in conjunction with elastic analysis for evaluating structural integrity under SSE loading, is acceptable for CPSES.
4.1.2 Design Validation j
4.1.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter The Trains A and B conduit and conduit support design validation program was conducted to confirm the design adequacy of the installed conduit systems at CPSES while addressing all the conduit support technical issues.
The design validation process consisted of the following activities:
(1) As-Built Confirmation (As-Builting)
Field engineering walkdowns were performed to obtain all the information on conduit configuration (span length, orientation, conduit size, etc.) and support details (support configuration, orientation, anchorages, clamps, etc.)
necessary to validate the design.
This information is recorded on detailed isometric drawings and support drawing details.
Comanche Peak SSER 16 4-16
1 (2) Generic Design Drawings The original conduit and supports installed at CPSES were based on the generic details specified in TV Electric drawings 2323-5-0910 for Unit. 1 and 2323-S2-0910 for Unit 2.
Ebasco reviewed the entire original drawing packages to deter-mine their compliance to the newly established design criteria and procedures, and to the resolution of the conduit support technical issues.
This review made it necessary to validate the design of every conduit configuration, con-j duit support, and junction box detail presented in these drawings to incorpo-rate the new design criteria and resolve CPRT and external issues.
(3) Installed Conduit Systems Isometric Validation - Conduit isometric drawings developed under the as-built activity were reviewed to confirm that they conform to the requirements speci-fied in drawings 2323-S-0910 for Unit 1 and 2323-S2-0910 for Unit 2.
Addi-i tional analyis or hardware modifications were performed when the criteria could not be satisfied.
Sup) ort Capacity Validation - Generic conduit support details obtained from the as-)uilt effort were reviewed to confirm that they satisfy the configuration requirements and load capacity limits specified in drawings 2323-S-0910 for Unit 1 and 2323-S2-0910 for Unit 2.
Other supports that deviate from the generically qualified supports are validated by performing additional analyses in accordance with Ebasco project criteria documents.
Junction Box / Support Validation - Under this activity, the design of electrical junction boxes and their supports was validated using the details obtained from the as-built effort and comparing them to the requirements specified in draw-ings 2323-S-0910 for Unit 1 and 2323-S2-0910 for Unit 2.
In addition, the total conduit loads acting on the junction boxes were compared with tabulated allowable loads in the same drawing packages.
Any deviations were resolved by additional analyses or hardware modification.
4.1.2.1.1 As-Built Configuration (As-Builting)
Ebasco developed a list of attributes of the as-built configurations required as input to the design validation process.
Ebasco then developed engineering walkdown (as-built) procedures, called field verification methods (FVMs), which incorporated the list of attributes required as input to the design validation process.
The FVMs define engineering walkdown requirements such as measurement and recording tolerances, measurement methods, and as-built drawing preparation.
Ebasco assigned qualified walkdown personnel who were provided with classroom as well as field training on the requirements of FVMs before they proceeded with the engineering walkdown.
j These people performed the engineering walkdowns of conduits and conduit supports to obtain the as-built information required by the FVMs.
During the walkdown, isometric drawings were prepared giving details of the conduit and conduit support configurations.
The following conduit attributes were examined Comanche Peak SSER 16 4-17
by engineering walkdown personnel and were documented on the conduit isometric drawings for Unit 1:
(1) conduit identification (2) routing of conduit (3) location of supports (spans between supports)
(4) identification of conduit fittings (5) identification of seals at conduit wall, floor,' and ceiling penetrations (6) conduit size (7) distances between conduit fittings and supports (8) location of embedments of conduit in concrete (9) junction box physical characteristics (10) flexible conduit length and size (11) air drops (cable length from end of conduit)
(12) support identification (13) fire protection material (Thermo-Lag or Thermoblanket) configuration The isometric drawing was accompanied by detailed as-built drawings of the conduit supports.
For each support, engineering walkdown personnel examined the following elements and documented them on the conduit support drawings:
(1) dimension of support members (2) member thickness (3) orientation (vertical, horizontal, or floor mounted)
(4) Nelson stud diameter (5) bolt diameter, spacing, and type (6) clamp type (7) shim and filler plate sizes (8) edge distance (distance from bolt hole to free ends of structural member)
(9) dimension from clamp edge to free end of conduit support structural member (10) fire protection material (Thermo-Lag or Tnermoblanket) configuration (11) lliiti bolt / Richmond insert diameter, length identifier, and bolt projection (12) base plate dimensions The accuracy of the as-built drawings of the conduits and conduit supports has been verified by TU Electric quality control surveillance personnel on a sample basis, and has been audited by the TU Electric QA Technical Audit Program (TAP) i
- group, i
The walkdown procedure for Unit 2 is different from the procedure for Unit 1 since the conduit systems in Unit 2 are "pre-engineered." That is, the conduit ~
isometric drawings and support selections are made and documented at the time of construction not after construction, as was the case in the design validation of Unit 1 conduit systems.
In Unit 2, the walkdown engineer working with the electrical construction crews prepares the isometric drawing for each conduit system and identifies on that drawing the support location, support types,andafewbasicsupportparametersforgenerictypesupports.
Specific details about supports are only prepared for "modified typical' or "individually engineered" (IN) supports.
The staff audited the as-built program for conouit and conduit supports at the CpSES site on September 8-10, 1987 (Appendix C to this supplement - Event 13).
The objectives of this audit were to:
Comanche Peak SSER 16 4-18
(1) review the technical adequacy of the as-built procedures, including-completeness in identifying all important attributes needed for design verification (2) review the implementation of the as-built procedures, including the information/ document-flow process (3) review representative conduits and supports for agreement with as-built information documented in the walkdown package (4) perform a walkcown of representative conduits and supports to identify any deficiencies Ebasco d2veloped three field verification methods (FVMs) to perform the as-built review:
CPE-EB-FVM-C/S-003 - for Unit 1 conduit instalied in Unit 1 and in an area common to Units 1 and 2 CPE-EB-FVM-C/S-002 - for Unit 2 conduit CPE-EB-FVM-C/S-014 - for Unit 2 conduit installed in Unit 1 and in an area common to Units 1 and 2 (Unit 2X conduit)
Portions of these FVM procedures were reviewed and discussed with Ebasco per-sonnel.
The FVM procedures were reviewed to determine whether the instructions given to the walkdown engineers are correct and whether they provide all the requirements necessary to prepare the required as-built documents (isometric conduit drawings, conduit support drawings, and junction box support drawings).
1 In addition, the various steps, from the identification of the conduit systems to be walked down to the transmittal of data to the Design Verification Group, were reviewed and discussed.
The staff conducted field walkdowns for eight representative conduit systems.
These systems were selected to encompass the various plant buildings, conduit sizes, and train types for both Units 1 and 2.
The staff performed its walkdowns by comparing the documented walkdown packages prepared by Ebasco to che as-installed conduit systems.
In addition to verifying the proper implementation of the procedures and spot checking the as-built documents for accuracy, the walkdown of these eight con-duit lines included a visual inspection for identification of any deficiencies or discrepancies that should have been noted.
On the basis of the staff review of the walkdown procedures, the staff finds that the three FVM procedures are technically sound and provide adequate in-structions for the preparation of as-built documents for those attributes listed in the procedures.
For attributes not included in these procedures, such as weld size / length or bolt-hole size, either the original quality control inspections were relied on or other CPSES programs such as the PCHVP addressed them.
The staff finds the conduit support attributes to be complete, therefore acceptable.
Comanche Peak SSER 16 4-19 1
1
The implementation of the as-built procedures, including the completeness and accuracy of the documentation, was found to be adequate except for minor documentation discrepancies.
A followup audit at the CPSES site on June 13-16, 1988 (Appendix C to this supplement - Event 21), verified that these discrep-ancies had all been satisfactorily resolved.
4.1.2.1.2 Generic Design Drawings TU Electric drawings 2323-5-0910 for Unit 1 and 2323-S2-0910 for Unit 2 contain the acceptable generic designs for conduits, conduit supports, junction boxes and junction box supports.
The design drawings present acceptable conduit con-figurations, maximum span lengths, permissible generic designs for conduit supports and junction boxes / supports, and allowable support capacities.
These generic design drawings were used to validate the installed conduit systems by comparing the as-built information to the designs and requirements presented in the generic drawings.
Thus, the designs presented in the generic drawing packages needed to be validated so that they could be used, in turn, to vali-date installed conduit systems.
The allowable conduit configurations and span lengths are provided on tie "LS" series of drawings contained in the design drawing packages.
These ensu,i that desired minimum frequencies are maintained, reasonable acceleration values can be used, and conduit stress values are less than allowable stress values.
The drawings provide allowable span lengths between conduit supports for a range of conduit configurations, conduit sizes, end conditions, buildings / elevations, and for various conduit fittings / components (such as couplings and flexible cor
'ts).
The drawings also provide equations for calculating tributary we g*-
on supports that are required for validating the design of the I
i su,acett Similarly, the criteria in the design drawing packages for generic supp r ensure that minimum support frequencies are maintained, reasonable acceleration values (less than peak) can be used, and support member stresses are less than allowable values.
The design / requirements on the generic design drawings were validated using criteria presented in Ebasco's specifications SAG.CP10 and SAG.CP2 for Units 1 and 2, respectively.
These documents provide the criteria and procedures to be used in the design and analysis of the conduits and conduit supports.
Criteria for the analysis and design of junction boxes are presented in SAG.CP17 for Unit 1 and SAG.CP12 for Unit 2.
The design criteria and methodology contained in all of these documents are described in Section 4.1 of this supplement.
Ebasco prepared additional project documents (SAG.CP20. SAG.CP25, and SAG.CP29) to provide more detailed procedures and guidelines for use during the design validation effort.
A description of the criteria t.nd methodology contained in these documentr. is also presented in Section 4.1.
The staff audited the criteria and methodology used for validating the design j
of the generic design drawings at Ebasco offices on November 2-5, 1987, and March 30-31, 1988 (Appendix C to this supplement - Events 17 and 19).
The staff's evaluation of the criteria and methodology, based on the3e audits, is provided in Secticn 4.1.1 of this supplement.
Open items were ultimately closed out by the audit at CPSES site on June 13-16, 1988 (Appendix C to thir supplement - Event 21).
Appandix 0 to this supplement provides a description of tnese items, their resolution, and the staff's evaluation.
Comanch-SSER 16 4-20
l l
On the basis of its review of the approach used by Ebasco to design validate j
the generic drawings for conduits, conduit supports, and junction boxes, the l
staff finds that the design drawings adequately incorporate the criteria and l
methodologies that have been found acceptable by the staff (as described in l
Section 4.1.1.1 of this supplement) into a technically sound approach, thereby I
ensur'.E that minimum support frequencies are maintained, adequate acceleration l
val g ce specified, and appropriate stress limits for support members are i
use-Se design validation of generic support drawings is thus acceptable.
l The staff audited the implementation of the 2eneric design drawing validation and the use of the criteria and methodologies by Ebasco (see Appendix C to this supplement - Event 21).
Three sample calculations (SPAN-1125, SUPT-1015-1, and CP-JB-22-7) were selected to verify that the designs shown on the generic design drawings were correctly validated.
Calculation SPAN-1125 validates a single bend conduit configuration with a j
The results of this calculation confirm the adequacy of the conduit configuration presented on drawing LS-la in the generic design i
drawing 2323-5-0910.
In reviewing this calculation, the staff found that the i
model was correctly developed in accordance with the modeling instructions specified in the Ebasco criteria documents.
The conduit system analyzed matched the configuration shown on drawing LS-la contained in drawing package 2323-5-0910.
A response spectra modal analysis was performed using the STRUDL computer program to determine the fundamental frequency and to demonstrate the structural adequacy of the conduit.
The 10-percent modal combination method and damping values of 2 percent and 3 percent for OBE and SS2, respectively, were utilized as required by SAG.CP20.
On this basis, the staff finds the calculation acceptable.
Calculation SUPT-1015-1 provides the design validation of the generic conduit support CSM-18f (shown on drawing CSM-18f contained in design drawing 2323-S-0910).
The five cases shown on the generic design drawing were grouped into two structural models for analysis.
The staff reviewed the models to confirm that they correctly represent the generic design drawing.
The calculations utilized the EZHANG cenputer program to analyze the supports.
The analysis criteria, including dampina values, load combinations, and range of support parameters, were found to be in accordance with SAG.CP10 and the sucport cap-acities were correctly determined in accordance with the criteria methodology described in Section t.1.2 of this supplement.
On this basis, the staff finds the calculation acceptable.
1 Calculation CP-JB-22-7 provides the design validation of a junction box having dimensions of 12"x6"x12" supported by two bolts.
A finite element model with plate elements for the box and beam elements for the attached conduits was reviewed by the staff and was found to adequately represent the junction box.
A modal analysis was performed and a thermal analysis was performed us'ng the STRUDL computer program in accordance with requirements specified in SAG.CP10 r
SAG.CP17.
Thermal loads were added to deadweight ar.d seismic loads in b
Critical portions of the junction bcx, including box plate etress, cor.nection of conduit to junction box, and junction box bolt attachment, were checked in accordance with the criteria in SAG.CP17.
The allow-able conduit weight for this junction boy was calculated to design validate the junction box capacities tabulated on drawing JA-15-H contained in drawing package 2323-5-0910.
The staff found that the calculation followed the criteria and methodology provided in the Ebasco procedures and it thus acceptable.
Comanche Peak SSER 16 4-21
f:
P As a result of the staff review of the three calculations described above, the staff concludes that the adequ ;, *f the calculations provides assurance that 1
the design validation of generic m sign drawings has been performed in accordance with adequate criteria and methodologies, and is, thus, acceptable.
4.1.2.1.3 Installed Conduit Systems Ebasco validated the design of installed conduit systems to determine whether they comply with the requirements of the validated and revised drawings 2323-S-0910 design document.
The design validation includes analyses which either demonstrated that the as-installed conduit and conduit supports complied with the design criteria, or identified necessary modifications to bring.the hardware into compliance with the design criteria.
The isometric packages (isometric and support drawings) prepared in accordance with the field verification procedures (see Section 4.1.2.1.1) were used as input to the design validation effert.
The isometric packages consist of (1) isometric drawing / sketch, (2) redline drawings for supports, (3) inspection reports optional), and (4) component modification cards (CMCs) for welds.
In general, the design validation for conduit systems installed in Unit 1 con-sists of the following steps:
(1) evaluation of conduit spans (2) calculation of conduit loads L and L, and evaluation of clamps L
T (3) evaluation of supports based on as-built conditions and calculations of footprint loads (4) modification, if required The evaluatien of conduit span required the selection of the generic LS draw-i ings in the 2323-S-0910 drawing package that show a configuration similar to the span being evaluated.
Then, a comparison is made between the actual span and the allowable span given in the LS series of drawings.
Detailed guidelines for comparing the spans is provided in SAG.CP25.
The guidelines include items such as the tolerance of plus or minus 3 inches which need not be considered for validating spans and the requirement that for multiple conduit runs of different diameter on common supports, the conduit (s) witi, the most stringent criteria shall govern the span spacing of supports.
As indicated in this section, the comparison of the conduit configuration and spans with the generic design drawings 2323-S-0910 ensures that minimum frequencies are maintained, 2
which results in reasonable acceleration values and ensures that conduit stresses are less than allowable values.
j 4
If during the evaluation of conduit spans, the as-built span exceeds the allow-able value, custom isometric package evaluation is made per SAG.CP25.
This appendix provides guidelines for performing the response spectra modal analysis of conduit and support assemblies.
The criteria and methodology and the staft's evaluation of the RSM analysis procedures are described in Section 4
i 4.1.2.2 of this supplement.
I Comanche Peak SSER 16 4-22
r To validate the conduit clamps and support design, conduit loads L and L II 4
L T
all supports are calculated in accordance with the LS series of drawings con-tained in the generic design drawings 2323-S-0910.
The equations for L and L t
T represent the contributing conduit loads acting at a support.
The equations include support reaction effects due to multi-spans and different end condi-tions.
These conduit loads are then multiplied by a load factor based on the configuration, building, and elevation.
This factor was developed to account for the early use of the complete quadratic combination (CQC) modal method rather than the 10 percent closely spaced modal combination method described in the CPSES FSAR and in RG 1.92, "Combining Modal Responses and Spatial Com-ponents in Seismic Response Analysis" (Reference 24).
Where the response spectrum is analyzed for the conduit systems, such factors are not needed, since SAG.CP20 correctly specifies the use of the 10 percent closely spaced modal combination method.
Clamp adequacy is checked in accordance with SAG.CP10 using the calculated LL and L and the appropriate g values.
The appropriate g values are defined as T
follows:
(1) In the vertical direction (dead load direction), g value equals 1+g max.
(2)
In the other directions, g value equals g max.
4 The g max is the maximum g value of the three component g values (N-S, E-W, and vertical) obtained from the RSM analysis or from the design g value tables specified in SAG.CP10.
The clamp-applied loads of L and L times the appro-L T
priate g values are then compared against the clamp-allowable loads in each direction.
The clamp-allowable loads in the transverse, vertical, and longitudinal directions are presented in tabular form in SAG.CP10 for each clamp attachment type (Unistrut bolt, Nelson stud, and Hilti Kwik-Bolt), for each clamp type, and for each conduit size.
The methodology for developing these allowable clamp loads and the staff's evaluation of them are described in Section 4.1.2.4 of this supplement.
The design validation of conduit supports depends on the support classification i
(i.e., generic, modified, or IN).
When the redline drawing of the support con-forms to the corresponding typical detail in the 2323-S-0910 drawing package, the support is treated as a generic support.
Otherwise, the support is tlassified as either modified or IN support.
A modified support is a support that has some deviation (s) from the typical details in design drawings l
2323-S-0910.
IN support is a support that does not conform to the details in l
the design drawing package.
l l
Generic supports are validated by comparing the calculated support loads LL and
'T with the support load capacity specified on the generic support details in Jrawings 2323-5-0910.
The support capacities are provided in tabular form for each generic support.
The capacities usually are a function of the building in which the support is located, the elevation, and the length of the centilevered Comanche Peak SSER 16 4-23
support member (if applicablo).
If the calculated loads are larger than the support capacity, the isometric drawing is validated in accordance with SAG.CP25.
The design of modified supports with minor deviations from a generic support may be validated (utilizing hand calculations) by comparing them to the generic support.
This approach can be used if all corresponding members and attributes that affect the capacity of the support can be demonstrated to be more conserva-tive than those used for the generic support to meet frequency requirements and acceptance criteria.
When a modified support is significantly different from a generic support, the design of all aspects of the support is required to be verified to meet support requirements described in SAG.CP29.
These require-ments include proper modeling of the support, including baseplate / anchorage flexibility, meeting minimum support frequency, and satisfying member stress allowables, weld allowables, and anchorage requirements.
IN supports by definition do not conform to the generic support details in the design drawing package.
Thus, the IN supports are required to be individually engineered to meet all support requirements specified in SAG.CP29.
The requirements describ d above for modified supports generally describe the requirements for IN supports as well.
To confirm the proper implementation of the design validation critoria and procedures for installed conduit systems, the staff Londucted an audit on June 13-17, 1988 (Appendix C to this supplement - Event 21) at the CPSES site.
Two conduit systems were selected to review the design validation proces. and to confirm the correct implementation of the criteria and procedures.
The staff audited Conduit Isometric Evaluation Calculation Nos. 07405 (Revision 0) s.J 13449 (Revision 0); the audit included associated junction boxes and var-ious types of conduit supports.
Calculation No. 07405 provides the design validation for a 1-1/2-inch-diameter conduit isometric and associated supports and junction boxes located ir. the reactor building between elevations 893'-2" and 913'-6".
The staff reviewed this calculation for adherence to the criteria and procedures specified in the applicable Ebasco procedures and to determine its technical adequacy.
The calculation did follow the design validation sequences as described in Section 4.1.2.1.3 of this supplement.
The actual spans were correctly compared to allowable spans as specified in the LS series of drawings contained in design drawings 2323-S-0910.
This was done successfully for four of the eight spans occurring between supports.
The remaining four span lengths could not be qualified to the LS series of generic drawings.
Thus, a custom isometric package evaluation was performed using the response spectra method of analysis.
The computer model and the STRUDL computer printout were reviewed.
The model did match the isometric drwing prepared during the as-built effort.
The response spectra analysis, which was performed to confirm the conduit stress adequacy and conduit deflection limitation, was performed in accordance with the criteria established in SAG.CP10, SAG,CP20, and SAG.CP25.
Calculation of conduit loads on supports (L and L ) were then reviewed.
The L
T equations given in drawings 2323-5-0910 were correctly applied to determine the Comanche Peak SSER 16 4-24
tributary loads acting on each support.
Then, a comparison of the support loads against allowable clamp capacities presented in SAG.CP10 was reviewed and found to have been performed correctly.
Next, support loads were properly compared against generic support capacities tabulated on the same generic support details in drawings 2323-S-0910.
Since this calculation had some open items relating to (1) inaccessible attri-butes, (2) marked-up isometric drawings to be incorporated, and (3) considera-tion of relative support stiffness distribution for conduit longitudinal load, list of open items was found in front of the calculation.
This list was re-viewed and found to be complete and securate.
These types of items were to be resolved by the FCHVP or at the reconciliation phase which will follow shortly.
A computerized "Generic Open Items Checklist" which tracks open items that could result in modifications was also reviewed and found to contain the list of supports having inaccessible attributes.
The second conduit isometric calculation reviewed by the staff was Calculation No. 13449.
This calculation provides the design validation for a 1-inch-diameter conduit isometric and associated supports and junction box located in the electrical control building near elevation 854'-4".
This calculation was reviewed in the same manner as the previous calculation (No. 07405).
For the conduit validation, a response spectra analysis of the entire isometric configuration was performed to qualify all of the spans.
A review of the com-puter model for the conduit isometric drawing confirmed that it matched the isometric configuration developed during the as-built effort.
In addition, the computer model was prepared in sufficient detail to predict the seismic response of the ::onduit system.
From the results of the computer analysis, conduit stresses and conduit deflec-tions were correctly shown to be less than allowable values.
Seismic accelera-tion response at support locations were also shown to be less than the g values corresponding to the values used in qualifying the supports.
Several support calculations were reviewed and found to adequately demonstrate support and clamp adequacy.
These were done in accordance with SAG.CPIO and SAG.CP25 by comparing the support loads obtained from the response spectra analysis to the allowable support and clamp capacities.
As in the previous isometric calculation reviewed by the staff, this calcula-tion also had a list of open item; which identified two items that will be reconciled to complete the design validation effort.
On the basis of these discussions, the staff finds that the calculations were performed in accordance with the Ebasco criteria documents and procedures and are, thus, acceptable.
4.1.2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter Impell validated the design of Train C conduit and supports by using a multi-level scre eing validation method.
The postulated failure of Train C conduit i
Comanche Peak SSER 16 4-25
systems was evaluated for conformance with Position C.2* of RG 1.29, "Seismic Design Classification" (Reference 9), by assessing the potential impact of Train C conduit on nearby safety-related structures, systems, and components.
The Train C conduit supports were also validated to prevent incapacitating injury to occupants of the control room under the SSE condition.
The multi-level validation method evaluated (1) that no potential interaction exists, (2) whether potential interaction is acceptable, or (3) whether the Train C conduit and support can maintain its structural integrity.
Modifications are required if the Train C conduit support cannot satisfy one of these three criteria.
In order to determine that no potential interaction exists, Impell performed calculations to develop an interaction zone for free-falling Train C conduit and large displacement swaying of Train C conduit.
Impell performed field verifications to identify the potential targets and assess the interaction of the Train C conduit with the targets.
If the safety-related system, structure, or component was not contained in the interaction zone of Train C conduit, then that portion of Train C conduit was validated.
For assessing the acceptability of potential interactions, Impell performed field verifications to identify the potential targets, determined which Train C conduit could interact with these targets, and evaluated the impact of the Train C conduit on the target.
The ability of a seismic Category I system, structure, or component to withstand impact depends on (1) features of the seismic Category I systea, structure, or component, such as size, mass, the material and type of construction, (2) features of the Train C conduit and conduit supports, such as size, mass, material and type of construction, and (3) the drop height or lateral swing distance of the Train C conduit and/or conduit supports to the target.
Procedures for evaluating impacts during source-target interaction were prcvided in the Impell project technical instructions.
Where structural integrity of Train (. conduit supports was required, the as-built design attributes were obtained 0y field verification.
Examples of as-built design attributes obtained are conduit diameter, t.onduit spans between supports, support characteristics, support location, and adjacent support configuration.
The results of these field verifications were used as design input for structural integrity evaluations.
For certain frequently used support types, engineering calculations were performed to obtain capacities before field verification of these supports.
Structural integrity of such supports was then validated by field verification to assure that the as-built attributes were consistent with those attributes used in the engineering calculations.
For other supports, structu al integrity was validated by performing engineering evaluations on a case-by-case basis.
- Position C.2 of RG 1.29 states:
Those portions of structures, systems, or components whose continued function is not required but whose failure could reduce the functioning of any (seismic Category I) plant feature to an unac-ceptable safety level or could result in incapacitating injury to occupants of the control room should be designed art constructed so that the SSE would not cause such failure.
Comanche Peak SSER 16 4-26
The engineering evaluations included the use of a dynamic response spectrum method for seismic analyses.
The dynamic response spectrum method calculated the stresses for each component of the support (using computcr generated loads) and compared the actual stress to cn allowable stress.
In this method the con-duit system was modeled and subjected to deadweight end seismic (SSE) loading.
All modes up to 33 Hz (or the rigid cutoff frequency) were included.
The modal response due to the missing mass excited by modes having frequencies above 33 Hz was corrected.
The dynamic response spectrum method is more refined since the analyzed con-duit, its supports, and all tributary conduits and supports are modeled to yield a more accurate load prediction.
In certain cases, such as when Train C conduit supports were attached to safety-related components, OBE loads that were generated were conservatively taken to be equal to SSE loads.
These loads can be reduced by considering actual OBE spectra.
These loads were transmitted to the appropriate contractor so the safety related component could be evaluated.
Existing seismic Category II restraints (also known as cable restraints) which had been previously designed and installed for other seismic Category II compo-nents were checked to assure that they would sustain the additional incremental loads that would result from postulated failures of Train C systems.
The staff reviewed the adequacy of the Impell walkdown criteria to evaluate the potential interactions and to structurally qualify the as-built condition of the Train C conduit.
The staff audited the field verification of Train C con-duit on August 10-13, 1987, at the CPSES site (see Appendix C to this supple-ment - Event 12).
The scope of the audit included (1) a review of the Impell walkdown procedures, (2) a review of the Train C conduit methodology and approach, and (3) a review and walkdown of a completed room.
The staff reviewed the Impell walkdown procedures (Project Instruction 0210-052-004, "As-Built Walkdown" (Revision 1), and Project Instruction 0210-052-005, "Procedures for Implementing Screen Level 6" (Revision 3)).
The staff found that Impell had performed a plant walkdown to inspect all Train C conduit supports and all associated junction boxes attached to conduit of 2-inch diameter and less, including the reclassified lighting system.
(The entire population for lighting cable was categorized as an unclassified trend in the respective CPRT Quality of Construction Program construction work category.) The staff found that the walkdown procedures were based on a multi-level validation method consisting of several screening criteria.
The staff reviewed the criteria, design methodology, and approach used in the multi-level screening criteria.
The multi-level screening criteria provide acceptance criteria based on parametric studies, tests of generic support types, analysis of representative conduit runs or junction boxes, and criteria for identifying acceptable interaction between Train C conduit or junction boxes with certain safety-related components, i
i In addition, the staff reviewed the implementation of the multi-level validation method in an audit at the CPSES site on December 7-11, 1987 (see Appendix C to this supplement - Event 18).
The staff reviewed selected Impell calculation and l
l i
Comanche Peak SSER 16 4-27 i
m
modification packages and inspected selected Train C supports evaluated in the calculation packages.
A total of 51 calculation and modification packages representing conduit systems from the safeguards, electrical control, auxiliary, fuel load, service water, and containment buildings were selected.
The conduit supports inspected were selected from the calculation and modification packages reviewed by the staff.
Specific calculation packages were selected for review to ensure that each of the screening levels implemented by Impell in the design validation process was represented.
On the basis of its audit, the staff found (1) the design validation program had been implemented satisfactorily and in accordance with the program instructions, (2) supports to date have been validated using the multilevel validation method, and (3) where implementation required the exercise of some judgment in assessing interaction potential, such judgment was sound.
The staff concurs with that judgment.
The staff concludes that the Impell multi-level validation method provided an adequate methodology for evaluating the seismic adequacy of Train C conduit and supports under safe-shutdown earthquake conditions and for ensuring that the guidelines of Position C.2 of RG 1.29 (Reference 9) have been satisfied and are, thus, acceptable.
4.1.3 Hardware Validation The applicant described to the NRC staff a program for hardware validation in letters dated August 20, August 28, September 8, and September 23, 1987 (References 13, 14, 15, and 16, respectively); in the Trains A and B conduit support project status report (Reference 20); and in the Train C conduit support project status report (Reference 21).
The program referred to as the Post-Construction Hardware Validation Program (PCHVP) is one of the major elements of the Corrective Action Program (CAP).
The staff's evalustion of the overall concept of the CAP including the PCHVP was provided in a letter from S. D. Ebneter (NRC) to W. G. Counsil (TV Electric) dated January 22, 1988 (Reference 18).
4,1.3.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter Specifically for Trains A and B conduit supports, the PCHVP was divided into two areas:
(1) preparation of as-built drawings under the as-built / 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 as-built / design validation program, including the field verification methods (FVMs) which were used to obtain as-built informa-tion for design validation and the preparation of as-built drawings, is dis-cussed in Section 4.1.2.1.1 of this supplement.
Comanche Peak SSER 16 4-28
The second area of the PC4VP described above validates the final acceptance attributes for Trains A and B conduit supports.
The final acceptance attri-butes are based on validated installation specifications and are documented in the PCHVP attribute matrix for Trains A and B conduit supports as provided in Table 5-1 of the Trains A and B conduit support project status report (Ref-erence 20).
The attributes contained in the attribute matrix incorporate those recommended corrective actions identified by the CPRT Quality of Construction Program.
The staff finds that the PCHVP and its implementation for Trains A and B conduit supports reasonably ensure that construction-related deviations are identified in the installed hardware to enable appropriate engineering studies and tests to be performed in the development of specific design criteria, guidelines, and procedures for use in the design validation of CPSES Trains A and B conduit supports. The staff also finds that the PCHVP process and attribute matrix provide an acceptable method to ensure that the installed Trains A and B conduit supports are consistent with the design input used in their design validation and are thus acceptable.
At a later date, however, the staff will review in detail the acceptability of the specific attributes to'be reinspected or excluded from the PCHVP attribute matrix.
4.1.3.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter Specifically for Train C conduit supports, Impe11 developed a matrix of final acceptance attributes to be validated.
The final acceptance attributes are presented in Table 5-2 of the Train C conduit and conduit support project status report (Reference 21).
Under the PCHVP, these final acceptance attri-butes are validated oy either physical reinspections or through an engineering evaluation methodology.
The PCHVP has been implemented through a field verification method (FVM) which was developed to provide as-built information into the design validatior pro-cess.
The FVM, "As-Built Field Verification Method for Tra'n C Conduit Program," CPE-IM-FVM-C/S-095, validates all attributes in the final attribute l
matrix.
J The staff finds that the PCHVP process and attribute matrix provide an accept-able method to ensure that the installed Train C conduit supports are con-i sistent with the design input used in their design validation and are thus acceptable.
I 4.1.4 Final Reconciliation The purpose of final reconciliation is to consolidate data analysis, hardware modification, and inspection documentation to ensure that the Trains A, B, and C conduit supports design documentation are consistent with the hardware installation, The staff finds that the final reconciliation of Trains A, B, and C conduit i
supports is adequate and complete because it:
(1) reconciles validated design input with as-built configurations j
l I
Comanche Peak SSER 16 4-29 l
.=
j 4
t i
I (2) incorporates the resolution of third party (CPRT) issues and other' issues I
raised by sources external to the TV Electric project organization (3) includes confirmation of results from design organizations that interact l
(4) resolves open items from NRC's notices of violations and TV Electric's significant deficiency analysis reports Because these four items have been included in the final reconciliation, the staff concludes that the scope of the final reconciliation is sufficient to ensure closure of all design deficiencies and external source issues and to ensure compliance of the Trains A, B, and C conduit supports with validated 1
design documentation and is thus acceptable.
4.1.5 Final Documentation The fifth and final step in the overall CAP process for Trains A, B, and C con-duit supports is the transmittal of CAP results (e.g., design validation pack-agas) to the permanent records facilities.
The results are processed according to Engineering and Construction Engineering (ECE) Procedure ECE 2.13 and trans-i mittedaccordingtotherequirementsofthe"ComanchePeakRecordsManagement f
Program Manual.
Because the design basis and analyses of record for the CPSES plant are established under the CAP, the staff finds that the final documenta-tion 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 t
Trains A, B, and C conduit supports with the design basis will be controlled i
j during plant operation, and are thus acceptable.
4.2 Third-Party Actions I
4.2.1 CPRT Third-Party Review (TENERA, L.P.)
4.2.1.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter 3
The CPRT third party review of the Trains A and B conduit support activities was conducted by TENERA, L.P. (previously known as TERA Corporation) to ensure verification of the resolution of issues, to confirm the adequacy of design criteria, and to provide an overview of the conduit support design verification 1
1 activities.
The review as described in CPRT Program Plan DSAP VIII (Revision j
- 3) 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 project activities and corrective actions l
The CPRT Program Plan describes the third party area of review related to the I
idantification, review, and tracking of external source issues.
The external source issue review included not only issues related to conduit supports but i
also issues related to piping, pipe supports, cable tray hangers, mechanical 1
a i
Comanche Peak SSER 16 4-30 i
l systems and components, electrical systems, instrumentation and control, and civil / structural disciplines.
l As stated in the foreword to Revision 4 of the CPRT Program Plan (Reference 17), TO Electric's commitment to the CAP, with its comprehensive design validation 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 was terminated.
The CPRT third party review has established applicable criteria based on the CPSES Final Safety Analysis Report (FSAR) (Reference 22) and licensing commit-ments and compared both Ebasco's procedures and supporting documentation with those criteria.
The design criteria include FSAR commitments, applicable NRC regulatory guides, and referenced industry codes and standards.
The CPRT third party oversight of the CAP design validation activities for Trains A and B conduit supports included (1) a review of the as-built procedures, (2) a review of the design validation procedures, (3) a review of the special studies, and (4) a review of the test programs performed by Ebasco.
The CPRT third party activities also included a review of Ebasco's procedures, special studies, and test program results as they related to the resolution of each cc duit support issue raised by sources external to the TV Electric project.
As such, the external source issue reviews were performed as an integrated part of third party review of the Ebasco procedures, special studies, and test program results.
The staff inspected the third party activities at the offices of TENERA, L.P.
to evaluate the activities associated with the CPRT third party review.
The CPRT activities associated with Trains A and B conduit supports were inspected between October 28 and November 1, 1985, at Bethesda, MD (Appendix C to this supplement - Event 2), as documented in Inspection Report 50-445/85-17, 50-446/85-14 (Reference 36) and from July 7 to July 10, 1986 at Berkeley, CA, as documented in Inspection Report 50-445/86-19, 50-446/86-16 (Reference 37).
In addition, the staff audited the CPRT third party activities at the TENERA offices at the CPSES site (Appendix C to this supplement - Event 15).
The staff has reviewed and evaluated the CPRT third party involvement in the identification, review, and tracking of issues.
In its review of the peocess 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 updating of the issue evaluation.
This process provided a reasonable method for ensuring that all identified external source issues were properly tracked until they were resolved.
The external source issues were identified by a CPRT third party review of 364 source documents containing issues of concern.
The documents included Atomic Safety and Licensing Board (ASLB) hearing transcripts, submittals to the ASLB by the various parties, NRC staff meeting transcripts, safety evaluation reports, inspection reports, and CYGNA letters and reports.
The CPRT third party review of the source documents identified individual issues related to Trains A and B conduit supports.
A discrepancy / issue resolu-tion report (DIR) used to track each issue to closure was assigned to each issue.
TENERA consolidated the DIRs into 29 issue categories and each issue Comanche Peak SSER 16 4-31
category is evaluated by the staff in Appendix A to this supplement.
On the basis of its review of the scope of the external source issues, including all issues identified by CYGNA, the staff concludes that the scope is ;omplete and acceptable.
The staff reviewed the process used by the CPRT third party to verify design criteria and standards used by Ebasco.
The CPRT third party process involved a review of all FSAR commitments and relevant industry codes and standards (e.g.,
those of the American National Standards Institute (ANSI) and American Insti-tute of Steel Construction (AISC)) in accordance with CPRT DAP procedure 1, "Preparation and Review of Criteria Lists," to develop a design criteria list.
DAP-1 describes the preparation of design criteria lists and requires all cri-teria and commitments used in the CPSES design to be sequentially numbered surmrized, and all source documents to be identified.
The design criteria list was used to develop a checklist for reviewing Ebasco's design criteria and procedures.
The staff finds that the process provides a systematic method for ensuring that all relevant design criteria, standards, and licensing commit-ments were identified, documented, and addressed in Ebasco'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 Trains A and B conduit supports as documented in a CPRT Design Adequacy Program report entitled, "Discipline Specific Results Report:
Civil / Structural - Trains A and B Conduit and Supports," DAP-RR-C/S-002, Revision 1, November 4, 1987 (Reference 38) (herein-after referred to as the Trains A and B conduit support results report).
The staff finds that the Trains A and B conduit support results report is a well written and well-organized document.
The sections in the main text are technically straightforward and concise, and the attachments prove a practical and useful aid for tracking the sources of the issues and their resolutions in project and third party documents.
Overall, the Trains A and B conduit support results report provides an adequate description of the findings resulting from the TENERA oversight of the CPSES Trains A and B conduit support design.
The staff reviewed the CPRT third party (TENERA) activities related to TENERA's review of the Ebasco special studies and design procedures.
The TENERA review of the Ebasco documents resulted in either an engineering evaluation or a review checklist.
There are a total of 55 review checklists and 16 engineering evaluations which document TENERA's efforts in its review of the Trains A and B conduit support program.
The staff selected and reviewed seven engineering evaluations that summarized TENERA's evaluation of the five main activities in i
the Ebasco program.
The activities included (1) as-built drawing package preparation, (2) support capacity validation, (3) junction box capacity validation, (4) span-allowable studies, and (5) isometric validation.
In addi-tion, the staff reviewed two review checklists that evaluated the two major Ebasco design criteria documents for Unit 1 (SAG.CP10) and Unit 2 (SAG.CP2).
Through the staff's review of the TENERA engineering evaluations and review checklists, the staff gained confidence in the depth and comprehensiveness of the TENERA review and its technical understanding of the conduit support design issues.
Overall, the staff found that the CPRT third party had a well-defined program with controlled procedures for performing and documenting its design review.
The CPRT review checklists and engineering evaluations provided a clear and auditable trail.
Comanche Peek SSER 16 4-32
On the basis of its reviews, the staff finds that the CPRT third party engineer-ing evaluations and review checklists provided a systematic method to ensure the adequacy of the Ebasco design validation activities and design documents in regard to satisfying applicable code and standard requiremer,ts and licensing commitments.
The staff concludes that the CPRT third party activities related to Trains A and B conduit support design provided an adequate program to ensure that all external source issues are identified, that the Ebasco criteria and procedures used for the resolution of external source issues are technically adequate, and that the Ebasco design criteria and procedures satisfy FSAR commitments, applicable codes and standards requirements, and NRC regulatory guides.
4.2.1.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter The CPRT third-party review of the Train C conduit support activities was performed by TENERA, L.P. under the CPRT Program Plan's Issue-Specific Action Plan (ISAP) I.c, "Train C Conduits and Supports." The objective of ISAP I.c was to address the actions specified by the NRC's Technical Review Team by demonstrating that Train C conduit is in compliance with the seismic require-ments defined in RG 1.29 (Reference 9) and CPSES FSAR (Reference 22).
The third party reviewed the procedures and methodology developed by the project for performing the activities associated with the Train C design validation under the CAP.
The scope of that effort included the following activities:
(1) external source issues identification (2) design criteria / commitments identification (3) walkdown procedures review (4) support qualification procedures review (5) special studies review (6) test programs review (7) issue resolution review The details of the scope, review methodology, and results of the DAP effort for Train C conduit and supports are documented in the CPRT Results Report ISAP I.c, "Train C Conduit and Supports," Revision 1, dated October 28, 1987 (Ref-erence 39) (hereinafter referred to as the "Train C conduit results report").
The primary issue identified by the DAP in its review of external source docu-ments for the civil / structural discipline which was related to Train C conduit was the NRC's Technical Review Team finding that Train C conduit less than or equal to 2 inches in diameter was not seismically designed or evaluated for potential interaction with safety-related equipment.
The concerns related to this issue resulted in the TU Electric CAP workscope for conduit supports (Train C conduit less than or equal to 2 inches in diameter) discussed in Section 4.1.2.2 of this supplement.
In addition, the DAP identified two other issues concerning the NRC staff audits of the Train C seismic qualification program:
(1) justification for a factor of safety of three for Hilti Kwik-Bolts used in Train C conduit supports and (2) justification for a 7 percent damping value used in the seismic analy-(
sis of Train C conduit.
These two issues are discussed in Section 4.1.1.2 of l
this supplement.
l Comanche Peak SSER 16 4-33 l
The DAP also reviewed the external source issues identified for conduit Trains A and B to determine its applicability to Train C.
Four issues were identified as being applicable to Train C conduit:
(1) violation of AISC edge-distance requirements for oversized bolt holes (2) omission of support self-weight (3) prying and applied moments for anchor bolts (4) reaming of bolt holes in conduit clamps The staff evaluations of the above four issues are provided in Appendix A to this supplement in Sections 5.2, 7.1, 10.1, and 18.1, respectively.
The OAP identified and reviewed the design criteria and commitments that govern the design of Train C conduit supports for CPSES.
These criteria established the acceptance criteria for the review of project activities for Train C conduit design validation.
The OAP concluded that the CPSES criteria, together with the extraction of detailed criteria from the committed codes and standards, provide a completa, :onsistent, and adequate set of M ign criteria for conduit supports.
The DAP reviewed the procedures used by Impell for the walkdown program for Train C conduit and supports.
This review was performed to provide reasonable assurance that the procedures gave adequate instructions for field qualifica-tion or for obtaining accurate and sufficient design attribute information for' qualification by analysis.
The OAP concluded that the walkdown procedures are adequate provided their implementation is verified by the TU Electric QA Tech-nical Audit Program (TAP).
The TAP audit of the walkdowns conducted by Impell are discussed in Section 4.2.2.2 of this supplement.
In addition, the staff audit of the implementation of the Train C walkdown procedures is provided in Section 4.1.1.2 of this supplement.
The DAP reviewed the Train C support qualification procedures and found the procedures for analysis using individual support as-built data (Screen Level 5) were adequate, the criteria and instructions for rework options were accept-able, and the overall program methodology for the Train C qualification was adequate.
The DAP review of the Impell special studies and various test programs found that these studies and programs adequately supported the Train C qualification criteria.
The applicability of the special studies and test programs to the technical issues of conduit supports is further discussed in Appendix A to this supplement.
j The DAP reviewed the resolution of the external source issues discussed above.
The DAP evaluations of the Trains A and B external source issues relevant to l
Train C are discussed in Appendix A to this supplement in Sections 5.2, 7.1, 10,1, and 18.1, respectively.
The staff audited the CPRT third party activities at the offices of Impell andt at the CPSES site (Appendix C to this supplement - Event 16).
The purpose of the audit war to assess the overall adequacy of the CPRT third party activities associated with its review of the Train C conduit design validation.
The staff i
audit included (1) a review of the completeness of the DAP activities and (2) a review of the Train C conduit results report.
Comanche Peak SSER 16 4-34
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In its audit, the staff found that the basis for documenting the third party review is contained in CPRT Civil, Structural, Mechanical (CSM) Work Instruc-tion CSM-5, Revision 0.
The memo method, as described in CSM-5, was used to document the reviews in all but two cases.
For two reviews, checklists were used.
Therefore, the memoranda formed the documented basis of the engineerbg i
evaluation performed bv DAP.
During the course of the third party review, i
discrepancy / issue resolution reports (DIRs) and requests for information (RFIs)
I were issued.
The DAP has closed out all DIRs and RFIs associated with Train C r
conduit.
Overall, the staff found that the third party review had been per-formed in a thorough manner by well qualified personnel.
The third party review of the seismic qualification program for Train C conduit included reviews of walkdown and seismic qualification procedures, special studies, tests, and overall program methodology.
The staff found that there was adequate depth and breadth to the third-party review of these activities.
On the basis of its reviews, the staff finds that the DAP memoranda and check-lists provide a systematic method to ensure the adequacy of the Impell design validation activities for Train C conduit supports.
The staff concludes that the CPRT third party activities related to Train C conduit support design pro-l vided an adequate program to ensure that all external source issues are identi-fied, that the Impell criteria used for the resolution of external source 3
issues were technically adequate, and that the Impell design criteria and pro-1 cedures satisfied FSAR commitments,' applicable code and standard requirements, l
and NRC regulatory guides, and are thus acceptable.
i i
4.2.2 TV Electric Technical Audit Program
^
The TV Electric Technical Audit Program (TAP) is described in a letter from W. G. Counsil to the NRC dated September 8, 1987 (Referenca 40).
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 I
i Action Program and (2) provide oversight of project responses to CPRT l
recommendations.
4.2.2.1 Conduit Supports for Trains A and B, and Train C Larger Than 2 Inches in Diameter For Trains A and B conduit supports, the TAP audits of the CAP activities are i
designed to evaluate the effectiveness of the design validation process and the j
technical adequacy of the validated design product and supporting documenta-tion.
These audits are coordinated with other TV Electric audit activities and i
with the engineering functional evaluation (EFE) (Reference 40).
(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 a part of the ISAP audit program.
The TAP audit methodology used for the CAP and ISAP audits are described in TV Electric's Nuclear Engineering and Operations (NEO) Quality Assurance Department Procedure NQA 3.07-1.01, "Technical Audit Program" (Attachment 3 to Reference 40).
The audit methodologies include both a vertical and a horizontal review of the design validation process.
A vertical review would involve a review of the Trains A and B conduit support designs contained within a selected package.
A horizontal review would involve a I
review of a resolution of an external source issue common to a number of Trains A and B conduit support packages.
Comanche Peak SSER 16 4-35
The IAP audits of the CAP design validation activities include the following nine elements:
(1) availability and adequacy of procedures, instructions, and guidance documents (2) development of design-basis documents and reconciliation with licensing commitments (3) reflection of generic technical issues in design validation packages and, where appropriate, incorporation of resolutions into applicable design manuals, procedures, and/or criteria documents (4) validation of CPSES design documentation (5) resolution of CPRT third party discrepancy / issue reports (6) as-built considerations in the design validation process (7) identification, preparation, and implementation of design modifications and changes required as a result of the design validation effort (8) implementation of the Post-Construction Hardware Validation Program (9) final reconciliation of CPSES systems, structures, and components with the final approved design For Trains A and 8 conduit supports, the staff reviewed selected TAP audit reports covering the first seven elements listed above.
The TAP audits for elements 8 and 9 (above) were not yet available to the staff.
The staff also reviewed the transmittal of the DAP commitments to the TAP as documented in an interoffice memorandum from P. Wilson (CPRT) to G. Westhoff (fAP) dated May 5, 1988.
In the staff's review of the TAP audit reports on CAP activities (Appendix C to this supplement - Event 21), the staff finds that under the TV Electric TAP theimplementationoftechnicalanddesigncontrolrequirementsforthedesIgn-validation of Trains A and B conduit support in CPSES Unit 1 and in areas common to Units 1 and 2 is being effectively audited.
In addition, the staff finds that under the TAP, appropriate actions have been taken to resolve dis-crepancies previously identified during the CPRT audits of the conduit support design validation activitics.
On the basis of its review of the TAP activities, the staff finds the TAP provided an effective level of technical oversight of the CPSES Trains A and B conduit support design validation that is comparable to the level provided previously by the CPRT third party oversight and is thus, acceptable.
4.2.2.2 Conduit Supports for Train C Less Than or Equal to 2 Inches in Diameter For Train C, the staff reviewed the scope and extent of implementation of the audit program.
To date, the TAP has audited six of the nine elements.
The TAP audits have not covered the implementation of the resolution to generic tech-nical issues, PCHVP, and final design reconciliation.
In the six elements Comanche Peak SSER 16 4-36
audited, the TAP has found that the Impell procedures related to enginewing evaluations and design modifications as well as the Train C seismic qualir'ica-tion methodology and multi-level screening criteria were generally adequate.
Individual support calculations were reviewed and,,except for minor issues, were found adequate.
The TAP also reviewed the closure of the CPRT Design Adequacy Program's discrepancy / issue resolution reports (DIRs) and concluded that the Impell program is capable of resolving these issues.
The TAP conducted audit walkdowns to evaluate how well the procedure had been implemented during engineering field walkdowns performed by Impell.
The TAP concluded that the design validation process properly considers as-built information.
In addition, the TAP audit of design modification calculations including flow of field information were found to be generally satisfactory.
In its review of the TAP audit reports on CAP activities (Appendix C to this supplement - Event 20), the staff finds that under the TV Electric TAP, tho' implementation of technical and design control requirements for the design validation of Train C conduit supports in CPSES Unit 1 and for areas common to Units 1 and 2 is being effectively audited.
In addition, the staff finds that under the TAP, appropriate actions have been taken to provide oversight of the CPRT discrepancies previously identified during the CPRT review of the Train C conduit and supports (ISAP I.c).
On the basis of its review of the TAP activities, the staff finds the TAP provides an effective level of technical oversight of the CPSES Train C conduit support design validation and is thus, acceptable.
4.2.3 CYGNA Energy Services The conduit support design issues identified by CYGNA as a result of its Independent Assessment Program (IAP) (Phases 1-4) (Reference 5) 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 TU Electric CAP design validation, the CYGNA conduit support issues have been effectively addressed.
Ebasco addressed the CYGNA conduit support issues as part of the resolution of external source issues in Appendix A to the Trains A and B conduit supports project status report (Reference 20) and the staff evaluated the conduit support issues in Appendix A to this supplement.
The CYGNA findings related to other design areas - civil / structural, piping, cable tray hangers, mechanical and electrical systems, instrumentation and control, and design control - have been or will be addressed by the staff in safety evalua-tions for those areas.
CYGNA is continuing its design reviews under the formal protocol (Reference 41) established during the IAP for closure cf the conduit support issues raised by l
CYGNA.
The status of the CYGNA reviews are documented in review issue lists (RIls) for each design discipline in their scope.
For conduit supports, all the review issues have been closed (Reference 42).
l 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 conduit i
support design deficiencies are appropriate and acceptable.
CYGNA's Independent Assessment Program for CPSES did not include Train C conduit and supports in its scope.
l Comanche Peak SSER 16 4-37
5 PREVENTIVE ACTIONS In assessing the adequacy of the preventive actions taken by the applicant, Texas Utilities Electric Company (TV Electric), with respect to the program-matic and quality assurance aspects of the Comanche Peak Steam Electric Station (CPSES) conduit support issues, it is important to understand the underlying causes of the conduit support issues that resulted in the types of design deficiencies identified by independent design reviews.
In this section, the staff discusses the underlying causes of the conduit issues and addresses the appropriateness of the preventive actions taken by the applicant to preclude their recurrence.
Implementation of Design Control The staff reviewed the types of conduit support technical issues identified by CYGNA Energy Services (CYGNA) in its Independent Assessment Program (IAP) and categorized these issues into distinct programmatic areas associated with the quality assurance criteria of 10 CFR Part 50, Appendix B.
As a result of this review, it becomes evident that the conduit support issues arose primarily from the design process used by Gibbs & Hill, Incorporated (Gibbs & Hill).
The primary cause can be attributed to the fact that Gibbs & Hill failed to control the design of conduit supports.
More specifically, Criterion III of 10 CFR Part 50, Appendix B requires that measures be established to ensure that regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instruc-tions, the staff find; that several analysis methods used by Gibbs & Hill in the design of conduit supports did not effectively translate design commitments into design guidelines.
Examples of this programmatic deficiency are evident in the CYGNA conduit issues such as the assumption of the operating-basis earth-quake (OBE) as a governing load case for design, the dynamic amplification factor used for equivalent static method, and the method used to combine dead-weight loads and seismic loads.
These design methods used by Gibbs & Hill in conduit support design were also found by the staff to have been used in simi-lar design areas for which Gibbs & Hill was responsible, including design of j
cable tray hangers.
In addition, the staff found that the lack of control of design implementation by Gibbs & Hill raised several issues of conduit support, including bolt-hole edge-distance violations, torsion in Unistrut members, FSAR load combinations, improper use of catalog components, longitudinal loads on transverse supports, use of CA-type supports in LS spans, Nelson studs, span increase for fire protected spans, rigidity of CA-type supports, enveloping configurations for design, and systems concept.
Criterion III of 10 CFR Part 50, Appendix B further requires that design control measures provide for verifying the adequacy of the design including field design changes.
The staff finds that several conduit support issues arose fron a lack l
of review or insufficient justification for design changes, including field l
design changes, allowed by Gibbs & Hill for conduit supports.
Evidence of Comanche Peak SSER 16 5-1
r t
these deficiencies is manifested in the CYGNA conduit support issues associated with Hilti Kwik-Bolt substitutions, substitution of smaller conduit 'on CA-type supports, increases in allowable span lengths, substitution of next' heavier structural member, clamp usage, and conduit fire protection calculations, i
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Criterion III of 10 CFR Part 50, Appendix D further requires that measures be t
established for the control of design interfaces and for coordination among l
participating design organizations.
The remaining conduit support issues iden-t tified by CYGNA, including as-built walkdown discrepancies and construction aspects which could affect design assumptions, can be attributed to poor coordi-nation between the design and construction organizations.
Another complication arose because the constructor (Brown & Root) was required to follow a complex series of steps from a voluminous set of standard conduit support details in order to obtain a support configuration for installation.
The resulting conduit support design was not required to be' documented for each individual support as long as the drawings and steps were followed.
However, the staff finds that the drawings permitted excessive latitude for design variations which were not bounded by the supporting engineering calculations.
This complication further 4
i added to the lack of as-built information available for an adequate as-built i
review by Gibbs & Hill of the design changes and for an effective quality con-i trol inspection of the installed conduit supports.
The root cause determination for Train C conduit design was discussed in the CPRT ISAP I.c Results Report (Reference 39).
The staff reviewed the CPRT's root cause determination and concurs in its findings.
The CPRT states:
1 l!
The central issue identified by the NRC TRT regarding Train C conduit and supports was whether such conduit installations i
conformed with Regulatory Guide 1.29.
As discussed in Sec-l tion 3.0 (of the ISAP 1.c Results Report), the Project has assumed in its original design evaluation that conduit 2 inches and less in diameter was inherently capable of with-standing seismic loads such that adverse interactions with safety-related items would not occur.
Calculations that were not a part of the design basis had been generated in support of this assumption.
In view of the fact that observations of the performance of similar hardware during actual earthquakes support this assumption, it was common practice within the nuclear industry during the time frame of these CPSES design activi-ties to make these assumptions.
In the current time frame, designers typically document the bases for such assumptions.
This was not formally done by the Project although, as stated above, uncontrolled calculations had been generated.
Whenever assumptions of this type are made, it is important 1
to assure that designs fall within the bounds of applicabil-j ity.
For example, data developed by the Project during the initial phase of the ISAP investigation suggests that the i
support of single conduit runs was generally acceptable.
However, during the same initial ISAP investigation, the Comanche Peak SSER 16 5-2 l
4 w-
-.-n--.
-c-. -,,
Project was not able to establish that a few supports on which multiple small diameter runs had been hung would not fail under seismic conditions.
Thus, the "extrapolation" of the experience base for single conduit runs represented a weakness in the logic supporting the Project's conclusion on the seismic adequacy of Train C conduit 2 inches and less in diameter.
It is concluded by the third party that the root cause of the Train C conduit problem is that the Project failed to recon-cile key design assumptions and to recognize the evolution of industry practice and regulatory requirements to support these assumptions with formal calculations.
Staff Evaluation of Preventive Actions In the preceding discussion, the underlying cause for the conduit support issues appears to be a failure to implement design control.
A common thread in the types of issues identified in Trains A, B, and C conduit support designs is the lack of documented calculations to justify the variations on the standard con-duit support designs permitted by the drawings.
From another perspective, the use of generic support drawings permitting field changes resulted in an uncer-tain configuration of individual conduit supports.
Accordingly, a complete documentation of the conduit support installed conditions would be a necessary element for a proper corrective action.
On the basis of its review as discussed in Section 4.1.2 of this supplement, the staff finds that the Ebasco and Impell as-built walkdowns for conduit supports provide assurance that adequate as-built drawings have been developed of the installed conduit systems at CPSES.
The staff found acceptable the design validation activities used by Ebasco and Impell which incorporate the as-built information and design criteria into procedures used for a complete design validation of conduit supports.
Thus, a reasonable basis exists to ensure that the conduit systems at CPSES are adequately designed to remain functional under the design-basis loading conditions.
On the basis of its review of the corrective actions associated with the CAP, the staff finds that the comprehensiveness of the design validation activities performed by Ebasco and Impell provide sufficient confidence to the staff that all design deficiencies in conduit systems at CPSES which might have resulted from the failures in the implementation of the initial design control program have been corrected.
Furthermore, the development of as-built drawings for conduit systems, the establishment of design validation procedures and accept-ance criteria, and the changes to the process used to control field design changes provide a reasonable basis to preclude the types of design deficiencies previously identified.
The procedural changes requiring the documentation of each installed conduit support design, including a review of field design changes by Ebasco, provide an adequate means to preclude the types of problems which previously arose in the design-construction interface.
Consequently, the staff finds that adequate measures have been established to ensure that conduit supports are adequately design validated under the CAP, thus correcting the previous failures that might have occurred in design control and satisfying the applicable portion of Criterion III of 10 CFR Part 50, Appendix B.
Comanche Peak SSER 16 5-3
2 F
i 5
On the basis of its review of the CAP activities related to the corrective and i
preventive actions taken to control design and the design-construction rela-tionship, the staff concludes that the TU Electric CAP for conduit supports adequately corrects the underlying causes of the past design problems to prevent their recurrence and, thus, satisfies the applicable portion of Cri-terion XVI of 10 CFR Part 50, Appendix B.
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j Comanche Peak SSER 16 5-4
6 CONCLUSIONS On the basis of its review of the Comanche Peak Response Team (CPRT) Program Plan (Revision 4) and the Texas Utilities Electric Company (TU Electric) Cor-rective Action Program (CAP) as discussed in Section 4 of this supplement, the staff concludes for the design validation of conduit supports at Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 that the specified design is ac-ceptable 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 findings.
(1) The criteria used in the analysis, design, and construction of all conduit supports important to safety to account for anticipated loadings and pos-tulated conditions that may be imposed upon the conduit supports during their service lifetime are in conformance with established criteria, codes, standards, and specifications acceptable to the NRC staff.
(2) The use of these criteria as defined by applicable codes, standards, and specifications; the loads and loading combinations; the design and analysis procedures testing programs; an;d the hardware reinspection requirements providethe ac reasonable assurance that, in the event of earthquakes and various postu-lated accidents affecting the conduit supports, these components will withstand the specified design conditions without impairment of structural integrity or the performance of required safety functions.
The staff also_ concludes that for the resolution of identified and potential design deficiencies in the conduit supports at CPSES Units 1 and 2, the TV Electric CAP for conduit supports and the CPRT Program Plan (Revision 4) collectively establish effective means to identify all design deficiencies, provide comprehensive corrective actions for their resolution, and ensure proper implementation of the corrective actions.
These conclusions are based on the following findings.
(1) The applicant's conduit support design validation activities performed by Ebasco and Impoll and the CPRT third party reviews performed by TENERA, L.P. provide a comprehensive program for identifying and resolving the technical concerns raised by CYGNA Energy Services (CYGNA), the NRC staff, and other external sources related to the design adequacy of conduit sup-ports at CPSES.
The staff concludes that the overall program reasonably ensures that all deficiencies in the design of conduit supports are identi-fied and corrected.
The staff further concludes that the effectiveness of the program implementation ensures that those issues will be acceptably resolved upon completion of the program.
(2) The applicant's conduit support hardware validation activities provide assurance that construction deviations in the associated hardware are corrected and, thus, will not adversely affect the ability of conduit supports to perform their functions.
Comanche Peak SSER 16 6-1
(3) The scope and depth of the independent review by CYGNA provide additional assurance of the satisfactory resolution of deficiencies in the design of conduit supports at CPSES.
Additionally, satisfactory findings by the CPRT third party in its review of the conduit support design criteria pro-vide assurance that the design of the conduit supports satisfies licensing commitments and applicable code requirements.
(4) The TV Electric Technical Audit Program provides assurance that the execution of the design validation by Ebasco Services Incorporated (Ebasco) and the Impell Corporation (Impell) is technically adequate and that the implementation of the resolution of the conduit supports external source issues is appropriate and complete.
On the basis of its review of the design and interface controls associated with the TV Electric CAP (as discussed in Section 5 of this supplement), the staff concludes that the corrective actions are acceptable and satisfy the applicable requirements of 10 CFR Part 50, Appendix B, Criteria III and XVI.
This con-clusion is based on the following findings.
(1) 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 translated into specifications, design drawings, and procedures by estab-lishing design-basis documents and implementing a complete design vali-dation for conduit supports ireportant to safety.
The design validation provides proper control of the design interface between the conduit support groups and provides an adequate review of installed field designs and design changes.
(2) The applicant has satisfied the requirements of 10 CFR Part 50, Appendix B, Criterion XVI by esublishing a program to correct design deficiencies and to preclude repetition of the underlying causes of the problems associated with the design of conduit supports at the CPSES.
I Comanche Peak SSER 16 6-2
7 REFERENCES 1.
"Independent Assessment Program for Comanche Peak Steam Electric Station, Final Report, TR-83090-01 (Draf t) Volumes 1 and 2, Oocket Nos.
50-445/446, November 5, 1982.
2.
U.S. Nuclear Regulatory Commission, Atom!c Safety and Licensing Board Memorandum and Order (Quality Assurance for Design), December 28, 1983, LBP-83-81, 18 NRC 1410 (1983).
3.
Errata and revised pages to "Independent Assessment 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 (USNRC),
Subject:
Status of IAP Conclusions, Docket Nos. 50-445/446, January 25, 1985.
5.
Letter from N. H. Williams (CYGNA) to J. Bcck (TUGCO),
Subject:
Review Issues List - Independent Assessment Program All Phases, Docket Nos.
50-445/446, April 4, 1985.
6.
U.S. Nuclear Regulatory Commission, "Comanche Peak Special Review Team Report," Docket Nc-50-445/446, transmitted in a letter from D. G.
Eisenhut (USNRC) to M. D. Spence (TUGCO) dated July 13, 1984.
7.
Letter from D. G. Eisenhut (USNRC) to M. D. Spence (TUGCO),
Subject:
Comanche Peak Review, Docket Nos. 50-445/446, September 18, 1984.
8.
U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2,"
(SER) NUREG-0797, July 1981 and Supplements 1 through 4 and 6 through 14.
9.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.29, "Seismic Design Classification."
10.
Comanche Peak Response Tearn, "Program Plan and Issue-Specific Action Plans," Revision 0, October 8, 1984, Docket Nos. 50-445/446, transmitted in a letter from M. D. Spence (TUGCO) to 0. Eisenhut (USNRC) dated October 8, 1984.
11.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
CPSES Corrective Action Program, Docket Nes. 50-445/446, January 29, 1987.
12.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Response to Additional Information in Conjunction With Program Plan Update, Docket Nos. 50-445/446, June 25, 1987.
t 13.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Comanche Peak Programs, Docket Nos. 50-445/446, August 20, 1987.
Comanche Peak SSER 16 7-1 l
14.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Corrective Action Program Description and Flow Diagrams, Docket Nos. 50-445/446, August 28, 1987.
15.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Post Construction Hardware Validation Program Engineering Evaluation Methodology, Docket Nos. 50-445/446, September 8, 1987.
16.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Post Construction Hardware Validation Program Attribute Matrix, Docket Nos.
50-445/446, September 23, 1987.
17.
"Comanche Peak Response Team Program Plan and Issue-Specific Action f
Plans," Revision 4, June 18, 1987, Docket Nos. 50-445/446, transmitted in j
a letter from W. G. Counsil (TV Electric) to USNRC dated June 25, 1987.
18.
Letter from S. D, Ebneter (USNRC) to W. G. Counsil (TV Electric), subject:
CPSES Licensing and Corrective Action Programs, Docket Nos. 50-445/446, January 22, 1988.
19.
"CPSES Design Basis Consolidation Program Plan," Docket Nos. 50-445/446, j
December 19, 1986, transmitted in a letter from W. G. Counsil (TU i
Electric) to USNRC dated December 22, 1986.
20, TVElectric,"CPSESUnit1andCommonCorreci.iveActionProgram-Project Status Report Conduit Supports Trains 4 and B, and Train C Larger Than 2 Inch Diameter," Revision 0, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 18, 1987.
i 21.
TU Electric, "CPSES Unit 1 and Common Corrective Action Program - Project Status Report Conduit Supports Train C 2 Inch Diameter and Less," Revision 0, Docket Vs. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 11, 1987.
22.
"Comanche Peak Steam Electric Station - Final Safety Analysis Report,"
Docket Nos. 50-445/446, up to and including Amendment 71.
23.
U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review 4
of Safety Analysis Reports for Nuclear Power Plants - LWR Edition," USNRC Report NUREG-0800, Revision 1, July 1981.
l 24.
U.S.NuclearRegulatoryCommission,RegulatoryGuide1.92,"Combining Modal Responses and Spatial Components in Seismic Response Analysis.
25.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61, "Damping Values for Seismic Design of Nuclear Power Plants."
AISC,tute of Steel Construction."~ Manual of Steel Construction, Seventn Edition, 19 26.
Insti
- Available through public technical libraries and at the NRC Library, 7920 Norfolk Avenue, Bethesda, MD, 1
Comenche Peak SSER 16 7-2
P I
AISI, "S ecification for the Design of Cold-Formed Steel Structural 27.
Members,p' American Iron and Steel Institute (1980).
28.
ANSI /AWS D1.1-79, "Structural Welding Code - Steel," American National i
Standards Institute /American Welding Society."
- 29. ACI 318-63, "Building Code Requirement for Reinforced Concrete," American Concrete Institute.*
30.
ACI 318-71, "Building Code Requirements for Reinforced Concrete," American Concrete Institute.*
31.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.124, "Service Limits and Loading Combinations for Class 1 Linear-Type Component Supports."
32.
U.S.-Nuclear Regulatory Commission, "IE Bulletin 79-02, "Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts," March 5, 1979 including Revision No. 1 (August 20, 1979).
33.
ACI 349-80, "Code Requirements for Nu: lear Safety Related Concrete Structures," American Concrete Institute."
34.
E. C. Rodabaugh, Battelle Columbus Laboratories, "Realistic Seismic Design Margins of Pumps, Valves, and Piping," USNRC Report NUREG/CR-2137, June 1981.
i 35.
M. R. Lindquist, Hanford Engineering Development Laboratory, "Final Report, USNRC Anchor Bolt Study Data Survey and Dynamic Testing," USNRC Report NUREG/CR-2999 December 1982.
l 36.
U.S. Nuclear Regulatory Commission, Inspection Report No. 50-445/85-17; 50-446/85-14, January 21, 1986.
J 37.
U.S. Nuclear Regulatory Commission, Inspection Report No. 50-445/86-19; 50-446/86-16, November 4, 1986.
38.
Comanche Peak Response Team, "Discipline Specific Results Report:
Clvil/
Structural - Trains A and B Conduit and Supports," DAP-RR-CS-002, Revision i
1, Docket Nos. 50-445/446, November 4, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 18, 1987.
39.
Comanche Peak Response Team, Results Report ISAP I.c, "Train C Conduit and Supports," Revision 1, Docket Nos. 50-445/446, October 28, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 9, 1987.
40.
Letter from W. G. Counsil (TV Electric) to USNRC,
Subject:
Technical Audit Program and Engineering Functional Evaluation, Docket Nos.
i 50-445/446, September 8, 1987.
- Available through public technical libraries and at the NRC Library, 7920 Norfolk Avenue, Bethesda, MD.
Comanche Peak SSER 16 7-3 i
~.
41.
Letter from D. G. Eisenhut (USNRC) to L. L. Kammerzell (CYGNA) and M. D.
Spence (TUGCO),
Subject:
Independent Assessment Program (IAP) Performed by CYGNA, Docket Nos. 50-445, May 31, 1984.
I 42.
Letter from N. H. Williams (CYGNA) to W. G. Counsil (TV Electric), ic r
Subject:
Conduit Support Review Issues, Comanche Peak Steam-Electr Station, Independent Assessment Program - All Phases, Docket Nos.
50-445/446, June 15, 1988, t
I i
1 1
Y i
I h
I i
1 l
i I
- f 4
i l
l Comanche Peak SSER 16 7-4
APPENDIX A RESOLUTION OF TECHNICAL ISSUES FOR CONDUIT SUPPORTS The conduit support technical issues" consist of those external source issues raised primarily by CYGNA Energy Services in conjunction with its Independent Assessment Program for Comanche Peak Steam Electric Station (CPSES) (Reference A1) that could potentially affect more than one specific conduit support.
The 1
Comanche Peak Response Team (CPRT) third party organization (TENERA, L.P.) was responsible for identifying, reviewing, and tracking the resolutions of the external source issues as part of the CPRT program plan's Design Adequacy
(
Program (DAP).
Ebasco Services Incorporated (Ebasco) had the responsibility for developing the technical resolutions of the external source issues for Trains A and B, and Train C larger than 2 inches in diameter; Impell Corpora-tien (Impell) had the responsibility for Train C less than or equal to 2 inches in diameter as part of the Texas Utilities Electric Co. (TV Electric) Correc-tive Action Program (CAP) for validating conduit and conduit support design.
The resolution methodologies for the conduit support technical issues were initially discussed in a IU Electric report entitled, "Evaluation and Resolu-tion of Generic Technical Issues for Conduits and Conduit Supports," dated March 30, 1987 (Reference A2), and subsequently have been documented in Appen-dix A to the "CPSES Unit 1 and Common Corrective Action Program - Project Status Re Diameter"port - Cont!uit Supports Trains A and B, and Train C Larger Than 2-Inch (Reference A3) (hereinafter referred to as the "conduit Trains A and B pro 1ect status report").
Impell's evaluation of the applicability of the condult (Train A and B) issues to Train C was provided in its "Generic Techni-cal Issues Report - Evaluation and Resolution of CYGNA Train A and B Issues as Applicable to Train C Conduit Supports," Impell Report No. 01-0210-1523, dated October 22, 1986 (Reference A4).
Ebasco and Impell incorporated the method for implementing the technical resolutions in their design validation procedures identified herein.
The CPRT's third party (TENERA, L.P.) evaluations of the Enasco and Impell resolution methodologies are summarized in the CPRT's "Discipline Specific Results Report:
Civil / Structural - Tra:ns A and B Conduit and Supports,"
DAP-RR-C/S-002, Revision 1, dated November 4,1987 (hereinafter referred to as the "conduit Trains A and B results report") (Reference A5) and in the CPRT Results Report ISAP (issue-specific action plan) I.c, "Train C Conduit and Supports," Revision 1, dated October 28, 1987 (hereinafter referred to as the "conduit Train C results report") (Reference A6).
The CPRT evaluations are documented in supporting engineerir.g evaluations and checklists identified herein.
"In the staff's terminology, a conduit support technical issue (e.g., anchor bolts) may consist of several subissues (e.g., prying factors. substitution of Richmond inserts).
Comanche Peak SSER 16 1
Appendix A
l i
1 The staff's review of the conduit support technical issues and their resolution i
consisted of a review of Appendix A to the conduit Trains A and B project status report, a selective review of portions of the Ebasco design validation i
procedures and special studies, a review of the CPRT conduit Trains A and B and i
Train C results reports, and a selective review of the DAP engineeriPO evalua-tions and checklists.
In addition, the staff conducted several audits and inspections at the Ebasco, Impell, and TENERA -L.P. offices (Appendix C to this supplement).
The staff evaluated each technical issue in this appendix with regard to the Ebasco/Impell resolution of the issue and the applicable CPRT third party review and evaluation of the issue.
In addition, the status of the CYGNA review for each issue is provided herein.
l All discrepancy / issue resolution reports (DIRs) generated by the CPRT in its review of 364 various source documents related to conduit support issues that were raised by external sources are addressed herein.
The 29 conduit support technical issues evaluated in this appendix correspond to the CYGNA review 1
issues for conduit supports which have been closed out per CYGNA's June 15, 1988 letter (Reference A7).. Closure of the CYGNA review issues and the bases 4
for closure will be documented by CYGNA in review issues lists.
For conduit supports, the staff will review the CYGNA review issues list when it is avail-able to ensure that the bases for closure are adequate.
Contingent upon the l
1 acceptability of CYGNA's bases for closure the staff finds the conduit 1
supporttechnicalissuestobesatisfactorIlyresolved.
These issues and all e
suaissues addressed under each technical issue are discussed in the follow-ing sections of this appendix:
l 1 GOVERNING LOAD CASE FOR DESIGN d
1.1 Operating-Basis-Earthquake (OBE) and Safe-Shutdtwt. Earthquake (SSE)
Load Cases 2 DYNAMIC AMPLIFICATION FACTOR (DAF)
[
l i
2.1 DAF for Conduit Systems i
3 COMBINATION OF DEADWEIGHT AND SEISMIC RESPONSE i
i L
l 3.1 Load Combination Method l
4 MEASUREMENT OF EMBEDMENT FROM TOP 0F TOPPING l
4.1 Design Considerations for Concrete Topping i
I l
5 BOLT-HOLE TOLERANCE AND EDGE-DISTANCE VIOLATION 5.1 Bolt-Hole Tolerance i
i 5.2 r,.cDistance Violation 6 FSAR LOAD COMBINATION f
j 6.1 Loads and Load Cambinations for Conduit Support Designs r
l j
Comanche Peak SSER 16 2
Appendix A i
l
i i
7 SUPPORT SELF-WEIGHT 7.1 Self-Wcight Design Considerations for Conduit Supports 8 TORSION IN UNISTRUT MEMBERS 8.1 Torsion in Unistrut Members in Original Design 9 IMPROPER USE OF CATALOG COMP 0NEfvTS 9.1 AISC-Derived Allowables 9.2 Components Used in Ways Not Intended by Vendors 10 ANCHOR BOLTS j
10.1 Prying Factors 10.2 CST-17, Type 17 Supports j
10.3 CA-2a Supports 10.4 Substitution of Richmond Inserts 11 LONGITUDINAL LOADS ON TRANSVERSE SUPPORTS i
11.1 Design of Transverse Conduit Supports for Longitudinal Loads 12 HILTI KWIK-BOLT SUBSTITUTION 12.1 Substitution of Conduit Support Anchorages 13 SUBSTITUTION OF SMALLER CONDUITS ON CA-TYPE SUPPORTS 13.1 Substitution of Smaller Conduit 14 USE OF CA-TYPE SUPPORTS IN LS SPANS 14.1 Methodology for CA-Type Supports in LS Spans 15 STRESSES IN CABLE TRAYS RESULTING FROM ATTACHED CONDUIT SUPPORTS j
i 15.1 additional Loads on Cable Trays Resulting From Conduit Attachment 15.2 use of Correct Seismic Accelerations 16 INCREASES IN ALLOWABLE SPAN LENGTHS 16.1 Effect of Span Length Increase on Conduit Stress 17 SUBSTITUTION OF NEXT HEAVIER STRUCTURAL MEMBER 17.1 Effect of Structural Membr Substitution 18 CLAMP USAGE l
18.1 Clamp Modifications i
18.2 Modification of C708-S Clamps 18.3 Clamp Distortion I
Comanche Peak GSER 16 3
Appendix A
19 DOCUMENTATION DEVIATIONS BETWEEN INSPECTION REPORTS, COMP 0NENT MODIFICATION CARDS, AND INDIVIDUALLY ENGINEERED FIRE-PROTECTED DRAWINGS 19.1 Documentation Deviations 19.2 Conduit Configuration Deviations 20 NELSON STUDS 20.1 Design Considerations for Nelson Studs 21 CONDUIT FIRE-PROTECTION CALCULATIONS 21.1 Thermo-Lag Configuration 21.2 CA-la Supports 21.3 CA-2a Supports 21.4 IN-FP Calculations 22 SPAN INCREASE FOR FIRE-PROTECTED SPANS 22.1 Allowable Stress Values 22.2 Stress Evaluation 23 GROUTED PENETRATIONS 23.1 Design Considerations for Grouted Penetrations 24 RIGIDITY OF CA-TYPE SUPPORTS 24.1 Design Considerations of CA-Type Supports 25 ENVELOPING CONFIGURATIONS FOR DESIGN 25.1 Use of Bounding Support Configurations 26 DESIGN DRAWING DISCREPANCIES 26.1 Discrepancies Between Generic Drawings and Analysis 27 WALKDOWN DISCREPANCIES 27.1 Clamp Installation 27.2 Anchor Bolt Installation 27.3 Installation of Structural Steel 27.4 Installation of Unistrut 27.5 Conduit / Pipe Interference 27.6 Conduit Placennt 28 SYSTEMS CONCEPT 28.1 Design Interaction Between Conduit and Supports 29 CUMULATIVE EFFECT OF REVIEW ISSUES 29.1 Cumulative Effect Comanche Peak SSER 16 4
Appendix A
.- ~..
1 GOVERNING LOAD CASE FOR DESIGN Concerns were raised regarding the selection of the operating-basis earthquake (OBE) as the governing seismic load case.
The CPRT third party (TENERA, L.P.),
in conjunction with the Design Adequacy Program (DAP), identified two related concerns from its review of various source documents.
In its conduit Trains A and B results report (Reference A5), TENERA combined these into one primary issue.
The relevant project doct.ments and the corresponding DAP review documents for this issue are listed below.
Project Document
- OAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/S-311 SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311
')
1 1.1 Operating-Basis-Earthquake and Safe-Shutdown-Earthquake Load Cases The background of this issue is provided in Section 3.2.7.1 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the project status report for conduit supports (Subappendix A1, Section 2.0) (Reference.J).
The DAP evaluation is summarized in Section 3.2.7.1 of the results report.
In the initial design of conduit supports, Gibbs & Hill assumed that the gov-erning soirmic load case for all support components (e.g., members, welds, and anchorages) was the operating-basis earthquake (0BE).
The basis for this l
assumption was the 60 percent increase in OBE allowables permitted by the CPSES l
Final Safety Analysis Report (FSAR) for the design of structural steel compo-nents under the safe shutdown earthquake (SSE).
Concerns were raised regarding l
the use of the OBE as the governing load case since the 60-percent increase in j
(
allowables under the SSE is not valid for certain support components such as 4
l expansion anchors or base plates.
I Ebasco resolved this issue by validating the design of conduit and junction box supports for the effects of 0BE and SSE loads, using the appropriate allowable
- All relevant project and CPRT review documents are listed in Appendix B of this supplement.
i Comanche Peak SSER 16 5
Appendix A
limits for each load case.
TENERA's review of Ebasco criteria documents (SAG.CP2, SAG.CP12, SAG.CP10, and SAG.CP17) confirmed that all supports are required to be design validated for the OBE and SSE load cases, using appro-
.priate allowable limits.
Train C supports were evaluated for SSE loads only consistent with the guide-lines of Position C.2 of Regulatory Guide 1.29, "Seismic Design Classification" (Reference A8).
Appropriate SSE stress allowables for structural steel, welds, anchorages, and catalog items were used to ensure structural integrity.
OBE considerations are required only for fatigue evaluation.
Usage factors for cumulative fatigue resulting from OBE and SSE load cycles were determined and compared to the available fatigue life of the components.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff reviewed the Ebasco criteria documents and concludes that the inclu-sion of bcth OBE and SSE load cases in the Ebasco design validation of conduit supports and junction box supports provided an adequate basis to resolve the concerns identified with this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
1.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with the design analysis using only OBE loadings have been adequately resolved.
The conduit support technical issue concerning the governing load case for design, therefore, is closed for CPSES.
Comanche Peak SSER 16 6
Appendix A
2 DYNAMIC AMPLIFICATION FACTOR'(DAF)
CYGNA questioned the use of a dynamic ainplification factor of -1.0 for the design of conduit supports-As part of the Design Adequacy Program (DAP),-the CPRT-third party (TENERA, L.P.) identified three related concerns from.its review of various source documents and combined these into one primary ~ issue.
The relevant project documents and the~ corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco) i l
L SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/S-311 SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311 SAG.CP20 DAP-CLC-C/S-604 DAP-E-C/S-313
)
Dook SPAN-1116 DAP-CLC-C/S-831.
Book SPAN-1133 DAP-CLC-C/S-837 Sook SPAN-1170 DAP-CLC-C/S-830
)
Book #36 DAP-CLC-C/S-825 Book #41 DAP-CLC-C/S-816 Book #61 DAP-CLC-C/S-820 Book #69 DAP-CLC-C/S-812 2.1 Dynamic Amplication Factor for Conduit Systems The background of this issue is provided in Section 3.2.7.2 of the conduit Trains A and B_results report (Referenca A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappendix A2, "All relevant projer.t and CPRT review documents are listed in Appendix B of this supplement, j
Comanche Peak SSER 16 7
Appendix A
- - ~.
Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.2 of the results report.
In the Gibbs & Hill design of conduit / supports using the equivalent static method for seismic loads, a DAF of 1.0 times the peak acceleration value of the governing design spectrum was used.
Since the CPSES FSAR required a DAF of 1.5 unless justification is provided otherwise, concerns were raised regarding the validity of the DAF of 1.0.
Ebasco resolved this issue by using one of the following three methods to account for dynamic amplification:
(1) Use a DAF of 1.5 times the peak spectral acceleration independent of the conduit system frequency.
(2) If the conduit system frequency is less than or equal to the frequency at the spectrum's peak, the equivalent static seismic response is determined by multiplying the peak ordinate of the design spectrum by a DAF of 1.5.
If the conduit system frequency is greater than the frequency at the spec-trum's peak, the equivalent static seismic response is determined by mul-tiplying the design spectrum ordinate at that frequency by.a DAF of 1.25.
Ebasco generally confirmed this DAF by using response spectrum analyses that envelope the combination of conduit configurations and span lengths permitted by generic drawings 2323-S-0910.
Where certain span combina-tions resulted in a DAF higher than 1.25, the design accelerations have been increased to reflect the results of the response spectrum analyses.
(3) Determine the conduit system seismic response using the response spectrum method of analysis.
The design of electrical junction boxes was validated using a DAF of 1.5 times the peak spectral acceleration or by using a response spectrum method of i
analysis.
l TENERA's review of Ebasco's design criteria (SAG.CP2, SAG.CP10, SAG.CP12, SAG.CP17, and SAG.CP20) confirmed that adequate requirements and analysis guidelineswereprovidedtoresolvethisissuebyusingthemethodologyde-scribed above.
In addition, TENERA's review of Ebasco s generic calculations (Books SPAN-1116, SPAN-1131, SPAN-l'.70, #36, #41, #61, and #69) confirmed that the DAFs used in the equivalent static method of analysis have been justified by the performance of enveloping response spectrum analyses.
Impell did not use the Gibbs & Hill calculations for Train C conduit supports as the basis for justifying the use of a DAF less than 1.5.
Rather, Impell justified the use of a lower DAF in certain situations.
A DAF of 1.0 was used if the fundamental system frequency is greater than 33 Hz or the rigid cut-off frequency of the appropriate floor response spectrum.
A DAF of 1.25 was used if (1) the fundamental system frequency is less than or equal to 33 Hz or to the rigid cut-off frequency, (2) the conduit run is straight (no elbows or offsets), and (3) the conduit does not behave like a cantilever.
A DAF of 1.5 was used for all other cases.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
Comanche Peak SSER 16 8
Appendix A
The staff concludes that the inclusion of an appropriate DAF in the Ebasco and Impell design validation procedures for conduit supports and generic calcula-tions that justifies the factors provides an adequate basis for resolving the concerns identified in this issue,'and are acceptable.
The CYGNA review of this issue and of the-CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
2.2 Conclusion l
l On the basis of the above' evaluations, the staff concludes that the concerns associated with DAFs have been adequately resolved.
The conduit support tech-nical itsue concerning DAFs, therefore, is closed for CPSES.
l l
Comanche Peak SSER 16 9
Appendix A
l 3 COMBINATION OF DEADWEIGHT AND SEISMIC RESPONSE In its Independent Assessment Program, CYGNA raised a concern regardi..g the method used by Gibbs & Hill to combine deadweight and seismic loads.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/5-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-H9 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/S-311 SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311 SAG.CP29 DAP-CLC-C/S-602 DAP-E-C/S-307 CP-SG-03 DAP-E-C/S-307 3.1 Load Combination Method The backgeound of this issue is provided in Section 3.2.7.3 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A3, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.3 of the results report.
In the Gibbs & Hill design calculations, deadweight and seismic loads were improperly combined.
Because of the dead load, a 1.0 g acceleration was first l
added to the vertical seismic acceleration; then the sum was combined with the l
two horizontal seismic acceleration components using the square-root-of-the-sum-l of-the-squares (SRSS) method.
Ebasco resolved this issue by requiring that the dead load response be added to the SRSS combination of the three orthogonal seismic components, considering the positive and the negative sign of the seismic resultant.
TENERA's review of the project documents (SAG.CP2, SAG.CP10, SAG.CP12, SAG.CP17, CP-SG-03, and SAG.CP29) confirmed that the deadweight load is required to be added to the SRSS combination of responses to the three orthogor.a1 seismic components.
- All relevant project and CPRT review documents are listed in Appendix B of this supplement.
Comanche Peak SSER 16 10 Appendix A
The absolute summation method was used to. combine deadweight and seismic loads for Train C.
TENERA's review of the applicability of this issue to Train C found that the issue is not relevant because of differences in analysis methods.
The staff concludes that the load combination methods used in the design validation of conduit supports are consistent with the guidelines of NUREG-0484, "Methodology for Combining Dynan.ic Responses," Revision 1 (Reference A9).
The inclusion of the load combination methods in the conduit support design valida-tion procedures provides an adequate basis for resolving the concerns identi-fied in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all.CYGNA conduit support issues as documented in Reference A7.
- 3. 2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with the combination of deadweight and seismic loads have been adequately resolved.
The conduit support technical issue concerning the combi-nation of deadweight and seismic response, therefore, is closed for CPSES.
l f
1 i
Comanche Peak SSER 16 11 Appendix A l
l l
4 MEASUREMENT OF EMBEDMENT FROM TOP 0F TOPPING The use of a 2-inch architectural topping on concrete floors at CPSES has raised some concerns regarding the design adequacy of concrete expansion anchor bolts.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 (TV Electric)
CPE-EB-FVM-C/S-014 DAP-E-C/S-301 CPE-EB-FVM-C/S-033 DAP-E-C/S-301 4.1 Design Considerations for Concrete Topping The background of this issue is provided in Section 3.2.7.4 of the conduit Trains A and B results report (Reference AS).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappendix A4, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.4 of the results report.
Note 5A on the Gibbs & Hill drawings 2323-S-0910 (sheet G-4a) stated that a 2-inch concrete topping could be considered in determining anchor bolt e:nbed-ment for certain supports at lower building elevations.
Since the integrity of the concrete topping was not known and the particular calculations have not considered the effects of the reduced anchor bolt embedments, the design adequacy of the affected supports was questionable.
Ebasco addressed the concern'regarding the measurement of embedment from the top of the architectural topping in the following manner:
(1) Drawings 2323-S-0910 sere revised to specify an additional 2-inch embed-ment length requirement for anchor bolts located in areas with 2-inch architectural topping.
(2) Floor-mounted supports in areas with 2-inch architectural topping were identified and design validated using the as-built embedment length reduced by the 2 inches of topping.
t
- All relevant project and CPRT review documents are listed in Appendix B of this supplement.
l l
l Comanche Peak SSER 16 12 Appendix A i
(3) Anchor bolts that are embedded only in the architectural topping as well as those that do not eet the anchor he't v.crptance criteria are being replaced.
The above methodology conservatively neglects the added anchor load capacity that would be contributed by the 2-inch architectural topping.
TENERA's review of project document SAG.CP10 confirmed that a requirement was specified to exclude the 2-inch architectural topping in determining the anchor bolt embedment length.
In addition, TENERA's review of walkdown procedures CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033 confirmed that adequate instructions were given to identify and determine the embedment of the anchor bolts.
For Train C supports located on the floor, toppings were identified through as-built walkdowns and a review of structural drawings.
The additional 2-inch architectural topping to the embedment length was similarly discounted.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the assumption used in the conduit support design validation procedures to neglect the strength of the 2-inch architectural topping is conservative and provides an adequate basis to resolve the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
4.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with the strength of the 2-inch concrete topping have been adequately resolved.
The conduit support technical issue concerning the inclusion of the architectural topping, therefore, is closed for CPSES.
Comanche Peak SSER 16 13 Appendix A
5 BOLT-H0LE TOLERANCE AND EDGE-DISTANCE VIOLATION.
Several concerns have been raised regarding the bolt-hole tolerances and' edge
' distances Gibbs & Hill used in its designs of conduit supports.
TENERA, in conjunction with the Design Adequacy Pr.ogram (DAP), identified three'related concerns from various source documents.
In its conduit Trains A and B results report, TENERA categorized these into (1) bolt-hole tolerance and (2) edge-distance violation.
The relevant project documents and the corresponding DAP review documents.for this issue are listed below.
Project Document
- DAP Review Document *-
(Ebasco)
SAG.CP29 DAP-CLC-C/S-602 DAP-E-C/S-307 CP-SG-03 OAP-E-C/S-307 Book SUPT-0246 DAP-CLC-C/5-823 DAP-E-C/S-309 Book SUPT-0253 DAP-E-C/S-309 Book #156 DAP-E-C/S-309 Book #158 DAP-E-C/S-309 Paper on effects of DAP-E-C/S-309 oversized bolt holes (Test Laboratory)
CCL Report No. A-699-85 DAP-E-C/S-308 CCL Report No. A-702-86 DAP-E-C/S-308 (TU Electric)
CPE-EB-FVM-C/S-014 DAP-E-C/S-301 CPE-EB-FVM-C/S-033 DAP-E-C/S-301 5.1 Bolt-Hole Tolerance The background of this issue is provided in Section 3.2.7.5 of the conduit Trains A and B results report (Reference AS).
Ebasco's resolution methodology
- All reievant project and CPRT review documents are listed in Appendix B of this supplement.
Comanch6 Peak SSER 16 14 Appendix A v...._.,
._-_._.-m.,
_,, _ -- -....,~_- _.,,, _,
is presented in the conduit Trains A and B project status report (Subappen-dix A5, Section 2.0A) (Reference A3).
The DAP evaluation is surnarized in Section 3.2.7.5 of the results report.
The concern raised was that drawings 2323-S-0910 showed bolt-hole tolerances in excess of 1/16 inch for conduit supports.
The American Institute of Steel Construction's (AISC's) Manual of Steel Construction (Reference A10) allows bolt-hole diameters to be 1/16 inch larger than the nominal bolt diameter.
Therefore, those connections having bolt holes exceeding 1/16-inch tolerance should be considered to be oversized and should be treated as such in bearing connection calculations.
Ebasco's methodology to address this concern depends on the type of connection.
Ebasco requested a determination from the AISC for steel-to-concrete (base plate) connections; in a letter from AISC to L. D. Nace (TV Electric), dated August 29, 1986, AISC stated that its specification requirements for bolt-hole tolerance do not apply to base plates.
However, Ebasco has generically considered the effect of oversized bolt holes on these connections in the TU Electric Correc-tive Action Program for cable tray hangers.
The cable tray hanger study for oversized bolt holes was extended to address the oversized bolt-hole issue for conduit supports.
Additionally, Ebasco's engineering study (Book SUPT-0253) demonstrates that these concrete connections are acceptable.
The study analyzed all critical conduit supports having two anchors with a shear interaction ratio greater than 0.4.
The shear force component acting along the common axis of the two anchors was redistributed to the more critical of the two anchors.
Using the new resultant shear force and existing tension on the anchor, the inter-action ratio was calculated using a 5/3 exponent in the tension-shear inter-action equation as specified in DBD-CS-015, "The Qualification of Embednmnts in Concrete." The results demonstrated that for all supports, the interaction ratios were less than 1.0.
On this basis, the studies conclude that the effects of oversized bolt holes are not significant and can be ignored in the design validation of base angles and base plates for conduit supports.
There are two categories for steel-to-steel bolted connections:
clamp-to-I support connections and connections between structural members.
The clamp-to-support connections were qualified by tests (CCL [ Corporate Consulting and Development Company, Ltd.) Report Nos. A-699-85 and A-702-86) that included i
oversized bolt Mies as specified in drawings 2323-S-0910.
The clamp capacities utilized in the conduit support design validation were based on the results of these tests.
For bolted connections in structural steel, which are not numer-ous at CPSES, engineering studies (Book SUPT-0253 and Ebasco paper on effects of bolt hole oversize) have bean performed for critical connections and the con-nections have been found to be adequate.
The effect of oversized bolt holes j
in critical connections of individually designed supports is resolved by weld-
)
ing the connected structural members.
The DAP reviewed Ebasco's special study (Book SUPT-0253) and concluded that the effects of oversided bolt holes in steel-to-steel connections have been I
appropriately considered.
The DAP reviewed Ebasco's special studies for steel-to-concrete connections (Book SUPT-0253, Ebasco paper on effects of bolt hole oversize, Book #156) and concurred with the findings that the effects of l
oversized bolt holes can be ignored in validating the design of base angles and base plates for conduit supports.
)
Comanche Peak SSER 16 15 Appendix A 4
For Train C, the effects of oversized bolt holes have been generically con-sidered in the cable tray hanger design verification through analytical work and interpretations of available test data.
It has been determined that over-sized bolt holes have an insignificant effect on component capacities and may actually contribute to decreased dynamic response.
The staff concludes that the acceptability of Ebasco's special studies and CCL's tests as found by the DAP review, which demonstrate that there is no adverse effect from oversized bolt holes in conduit supports at CPSES, provides an ade-quate basis to resolve the concerns raised in this issue and is acceptable.
The staff review and evaluation of the conduit test programs are discussed in Sec-tion 4.1.1.1 of this supplement.
5.2 Edge-Distance Violation The background of this issue is provided in Section 3.2.7.5 of the conduit Trains A and B results report (Reference AS).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix AS, Section 2.08) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.5 of the results report.
The concern was that some Gibbs & Hill designs did not provide the minimum edge distance required in the AISC specification for oversized bolt holes.
To address this concern, Ebasco performed special studies (Book SUPT-0246 and 158) to evaluate the effects of edge-distance violations.
The results of these engineering studies showed that the violatior.s of minimum edge distances, to the extent permitted by the design document, did not lower the conduit support capacity.
Conduit clamps were tested to establish allowable capacities for use in design validation (CCL Report Nos. A-699-85 and A-702-86).
The tests were developed to consider the as-built conditions, including edge-distance violations.
TENERA's review of walkdown procedures CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033 confirmed that adequate instructions have been specified to record the data needed to determine the edge distance.
The DAP review of technical guide-line SAG.CP29 showed that adequate instructions were given to perform a stress cvaluation of the edge-distance violation, TENERA's review of Book SUPT-0246 confirmed that the violation of minimum edge distance for steel-to-steel and steel-to-concrete connections does not reduce the capacity of conduit supports.
The DAP review of the CCL tests for clamp connections indicated that the effects of reduced edge distances have been adequately addressed by establishing clamp capacities on the basis of those tests.
The available edge distances for Train C have been generically justified by evaluating plate stresses for bearing-type connections.
The CPRT third party review of Impell's special study confirmed that an adequate margin of safety exists for the stresses in the relevant Train C supports with edge-distance violations.
Comanche Peak SSER 16 16 Appendix A
e The staff concludes that the acceptability-of Ebasco's special studies, which demonstrate the adequacy of the steel-to-steel and steel-to-concrete connections-with-the reduced edge distances, and the adequacy of the CCL tests, which demon-strate the adequacy cf clamps with reduced edge distances, provide an adequate basis for resolving the concerns identified in this issue and are acceptable.
'The CYGNA review of this issue and of the CAP resolution has'resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
5.3 Conclusion On the basis of the above evaluations, the staff concludes that the concerns associated with bolt-hole tolerance and edge-distance violations have been adequately resolved.
The conduit support technical issue concerning bolt-hole tolerance and edge-distance violation, therefore, is closed for CPSES.
Comanche Peak SSER 16 17 Appendix A
e 6 FSAR LOAD COMBINATION Concerns were raised with regard to the load combinations used in the Gibbs &
Hill design of conduits and conduit supports.
TENERA, in conjunction with the Design Adequacy Program (DAP), identified three related concerns from various
~
source documents.
In its conduit Trains A and B results report (Reference A5),
TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding DAP review documents for, this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/5-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/5-311 SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311 SAG.CP21 DAP-E-C/S-305 SAG.CP22 DAP-E-C/S-305 SAG.CP25 DAP-E-C/S-310 DAP-E-C/S-314 CP-SG-02 DAP-E-C/S-314 '
Book THER-1760 DAP-E-C/S-305 Book THER-1761 DAP-E-C/S-305 Book THER-1901 DAP-CLC-C/S-819 DAP-E-C/S-305 Book THER-1961 DAP-E-C/S-305 Book THER-1981 DAP-E-C/S-305 Book #81 DAP-CLC-C/S-804 DAP-E-C/S-305
- All relevant project and CPRT review documents are listed in Appendix B of this supplement.
Comanche Peak SSER 16 18 Appendix A 0
Project Document
- DAP Review Document
- Book #82 OAP-E-C/S-305 Book #84 DAP-CLC-C/S-805 DAP-E-C/S-305 Book #85 DAP-E-C/S-305 l
l Book #86 OAP-E-C/S-305 Book #87 DAP-CLC-C/S-822 DAP-E-C/S-305 l
Book #91 DAP-E-C/S-305 Book #92 DAP-CLC-C/S-839 OAP-E-C/S-305 DAP-E-C/S-311 Book #94 DAP-CLC-C/S-821-DAP-E-C/S-305 Book #111 DAP-CLC-C/S-810 DAP-E-C/S-311 6.1 Loads and Load Combinations for Conduit Support Design The background of this issue is provided in Section 3.2.7.6 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report-(Subappen-dix A6, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.6 of the results report.
CYGNA identified a concern that all applicable FSAR loads were not considered in the Gibbs & Hill design of conduit and conduit supports.
Loads resulting from normal operating and accident temperatures as well as loads from jet impingement, pipe whip, internally generated-missiles, and tornado effects had not been explicity considered.
In addition, design accelerations had been used that did not envelope the applicable seismic response spectra for the contain-nent building and internal structure.
In the TV Electric Corrective Action Program (CAP), the concern relating to the use of all FSAR applicable loads was addressed in the following manner:
The Systems Interaction Program under the TU Electric CAP mechanical. systems workscope is responsible for identifying those safety related conduit systems that are subjected to loads resulting from jet impingement, pipe whip, and
- All relevant project and CPRT review documents are listed in Appendix B of this supplement.
Comanche Peak SSER 16 19 Appendix A j
missiles (including tornado effects).
Ebasco had the responsibility for miti-gating the effects of these loads on the conduit systems.
This has been accom-plished'by relocating or shielding conduit and conduit supports from pipe-whip, jet impingement, and internally generated missiles.
No safety-related conduits or conduit supports are affected by tornado or tornado generated missiles.
The staff evaluation of the Systems Interaction Program will be addressed in con-junction with the staff's review of the CAP design validation for mechanical systems.
To address the effect of thermal loads on conduit systems, Ebasco performed a generic study as described in SAG.CP21 to evaluate conduits, conduit supports, and junction boxes under normal temperature and accident temperature loads.
The study showed that the concrete anchors that were found to bo the critical components are not loaded beyond their allowables for normal operating thermal condition and remain within their ultimate deflection capabilities for the accident thermal condition with an adequate factor of safety.
Since design "g" values for support capacity validation have been developed per building and elevation, there is no need to envelope the spectra for the entire building.
For conduit systems supported by both the containment building shell and internal structure, response spectra that envelope the containment building shell and the internal structure were used for the seismic analysis.
TENERA's reviews of the Ebasco criteria and guidelines (SAG.CP2, SAG.CP10, SAG.CP12, SAG.CP17, SAG.CP21, and SAG.CP2?) confirmed that appropriate loads and load combinations were specified and adequate guidelines were provided to evaluate the effects of these loads.
TENERA's reviews of the generic studies (Books THER-1760, THER-1761, THER-1901, THER-1961, THER-1981, #81, #82, #84,
- 85, #86, #87, #91, #94, and #111) verified that conduits and supports were properly analyzed for operating thermal loads.
The DAP review of the generic study (Book #92) for the accident thermal load case confirmed that the concrete expansion anchors used for most of the generic support types and junction boxes have an adequate minimum safety margin against ultimate displacement.
The DAP further reviewed the Ebasco's technical guidelines (SAG.CP25 and CP-SG-02) and confirmed that adequate guidelines exist for identifying case-by-case exceptions and performing an appropriate thermal expansion analysis.
The CPSES FSAR requires an evaluation of non-safety-related (Train C) conduits only for the SSE load.
Impell has met this FSAR requirement.
Also, where the conduit systems are attached to the containment and the internal structure, ImpolI has enveloped containment and internal structure spectra for evaluation of Train C conduit.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of j
the overall seismic qualification program.
The staff concludes that the inclusion of appropriate load combinations in the conduit support design validation procedures and the documentation of special studies that justify the effect of loadings on a generic basis provide an adequate basis for resolving the concerns identified in this issue, and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
Comanche Peak SSER 16 20 Appendix A
6.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns.
related to FSAR load. combination have been adequately resolved.
The conduit-support technical issue concerning FSAR load combination, therefore, is closed for CPSES.
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Comanche Peak SSER 16 21 Appandix A
7 SUPPORT SELF-WEIGHT 1
Since support self-weights were not uniformly considered by Gibbs & Hill in the 1
design of conduit supports, concerns were raised with the adequacy of the support components.
TENERA, in conjunction with the Design Adequacy Program (DAP), identified two related concerns from various source documents.
In its conduit Trains A and B results report (Reference AS), TENERA combined these concerns into one primary issue.
The relevant project documents and the corresponding DAP review documents for this issue are listed below:
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 OAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/S-311 SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311 7.1 Self-weight Design Considerations for Conduit Support The background of this issue is provided in Section 3.2.7.7 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and 2 project status report (Subappen-dix A7, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.7 of the results report.
4 In the initial design of conduit supports, the weight of the support members and components was not consistently evaluated in the design analyses. The concern was that neglecting some or all of the support self-weight could cause
~
support loads to be underestimated.
Ebasco addressed this concern by requiring that the self-weight of supports be evaluated in the conduit support design validation.
TENERA's review of project criteria (SAG.CP2, SAG.CP10, SAG.CP12, and SAG.CP17) confirmed the inclusion of the requirement to consider support self-weight in the design validation effort.
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
4 i
Comanche Peak SSER 16 22 Appendix A 3:-
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Support weight is explicitly considered in Impell calculations for Train C conduit supports.
The only Gibbs & Hill calculations used to substantiate Impell criteria are for Type 6 supports and they have been reviewed to identify any such impact on the screening criteria.
Impell is performing additional analyses to confirm the Type 6 support screening criteria and to eliminate any dependence on the Gibbs & Hill calculations.
The third party review of Impell's evaluation confirmed that inclusion of support self-weight does not affect the results of the Gibbs & Hill calculations for Type 6 supports.
Hence, the in-clusion of self-weight of Type 6 supports has no effect on the Type 6 support screening criteria.
The staff concludes that the inclusion of the requirement to evaluate the effect of conduit support weight in the design validation analyses provides an adequate basis to resolve the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
- 7. 2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns relating to the conduit support self-weight have been adequately resolved.
The conduit support technical issue concerning support self weight, therefore, is closed for CPSES.
l Comanche Peak SSER 16 23 Appendix A
8 TORSION IN UNISTRUT MEMBERS Several ccncerns were raised regarding torsional loading of Unistrut members.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified three related issues from its review of various source documents.
In its conduit Trains A and B results report (Reference A5),
TENERA categorized these into the single area of concern:
torsion of Unistrut members in the original design.
The relevant project documents and the corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
THE-C/S-CA-CA-la DAP-E-C/S-304 THE-C/S-CA-CA-2b DAP-E-C/S-304 THE-C/S-CA-JA-1 DAP-E-C/S-304 (Test Laboratory)
CCL Report No. A-678-85 DAP-E-C/S-304 8.1 Torsion in Unistrut Members in Original Design The background of this issue is provided in Section 3.2.7.8 of the conduit I
Trains A and B resnits report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Subappan-dix A8, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.8 of the results report.
Gibbs & Hill did not consider torsional loading of Unistrut members in the i
initial conduit support design.
The Unistrut manufacturer does not qualify the use of Unistrut shapes for torsional loading.
Because analysis of asymmetric Unistrut sections was difficult, Gibbs & Hill ir.itiated a test program to qualify Unistrut supports.
CYGNA raised questions regarding the configurations used in the tests, the applied loadings, and the test procedures.
This issue applies only to Unit 1 and areas common to Units 1 and 2 since Unistrut supports were not used in Unit 2.
To resolve this issue, Ebasco reviewed the test results against the CYGNA ques-tions.
Only those supports included in the tests that adequately represented the support configurations at CPSES or were not affected by inadequate testing were used.
Calculations were performed to reduce the test data to results that could be used in the design validation of the supports.
Any Unistrut supports that had a signific:nt reduction in capacity were replaced.
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 24 Appendix A
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Tne above methodology resulted in the replacement of all Unistrut supports except the CA-1, CA-2, CA-8, JA-1, JA-2, and JA-3 series.
These support types all consist of sections that are directly attached to concrete.
The DAP review of the Corporate Consulting and Development Company's (CCL's)
Unistrut test program (CCL Report No. A-678-85) and Ebasco's support capacity calculations (calculations THE-C/S-CA-CA-la, TNE-C/S-CA-CA-2b, and TNE-C/S-CA-JA-1) confirmed that conservative capacities are being used for those Unistrut configurations that are not being replaced.
Impell has not applied the test data for Trains A and B to the Train C conduit supports qualification; rather, Impell has undertaken an independent test pro-gram for Train C conduit.
The test performed by CCL is documented in CCL Repcet No. A-720-86, "Test Report for Static Testing of Train C Beam Clamps and Unistrut Hangers for CPSES," July 10, 1986.
TENERA's review of the CCL test report as documented in a memorandum from J. Groncki to C. Mortgat, "Static Testing of Train C Beam Clamps and Unistrut Hangers," Review No. 33504-01, dated January 22, 1987, concluded that the test program was adequately performed and that the test data were justified for use at CPSES for those support appli-cations currently used.
The staff concludes that the development of a test program to establish the impact of torsional loading in Unistrut members and the replacement of these support configurations where a significant reduction in capacity was'found provide an adequate basis to resolve the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
8.2 Conclusion On the basis of the above evaluation, the staff concludes that the con: erns associated with torsional loading in Unistrut members have been adequately resolved.
The conduit support technical issue concerning the torsion of Unistrut members, therefore, is closed for CPSES.
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Comanche Peak SSER 16 25 Appendix A
.g 9 IMPROPER USE OF CATALOG COMPONENTS In its Independent-Assessment Program, CYGNA raised concerns relating to the use of_ catalog components in the Gibbs & Hill design of conduit supports.
In conjunction with the. Design Adequacy Program.'(DAP), the CPRT third party.
(TENERA, L.P.) identified three concerns from its review of various source documents.
In its conduit Trains A and B results report (Reference A5), TENERA categorized these into (1) American Institute of Steel Construction (AISC)-..
derived allowables and (2) components used in ways not intended by the vendors.
The relevant project documents and the correspcnding DAP review documents for-this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 04P-E-C/S-307
?
TNE-C/S-CA-CA-la DAP-E-C/S-304 TNE-C/S-CA-CA-2b OAP-E-C/S-304 TNE-C/S-CA-JA-1 DAP-E-C/S-304 (Test Laboratory)
CCL A-678-85 DAP-E-C/5-304 1
CCL A-699-85 DAP-E-C/5-308 CCL A-702-86 DAP-E-C/S-308 9.1 AISC-Derived Allowables The background of this issue is provided in Section 3.2.7.9 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A9, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.9 of the results report.
1
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
t Comanche Peak SSER 16 26 Appendix A
'The primary concern was that in the Gibbs & Hill design of conduit supports, the AISC specification (Reference A10), rather than the American Iron and Steel Institute (AISI) code (Reference All), was used-for the design of thin-walled structural members such as Unistrut' members.
The concern was'that the AISC requirements are sometimes less restrictive than AISI requirements for the Unistrut members.
Ebasco has addressed this concern by utilizing the proper design code corre-sponding to the support component type.
Thus, the AISC specification-(Refer-ence A10) was used for structural steel shapes and the AISI code (Reference All) for Unistrut sections.
TENERA's review of the criteria documents (SAG.CP2 and SAG.CP10) has confirmed that the proper design codes were specified for the design of conduit supports.
The Impell Project Instructions for Train C define allowables to be used for cold-formed structural members.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the inclusion of appropriate cades and standards in the design criteria provides an adequate basis to resolve the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
9.2 Components Used in Ways Not Intended by Vendors The background of this issue is provided in Section 3.2.7.9 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A9, Section 2.0) (Reference A3).
The DAP evaluatiun is summarized in Section 3.2.7.9 of the results report.
CYGNA raisea a concern regarding the use of catalog components such as Unistrut brackets and plate connectors and Superstrut and Unistrut clamps in ways that were not intended by the vendors.
Thus, the components were subjected to load conditions for which there were no published allowable capacitieL Ebasco addressed this issue by either utilizing the catalog component in the manner intended by the vendors or in a manner validated as acceptable by tests.
If allowable values for catalog components are not cepplied by the manufacturer or established by tests, then the catalog component was replaced with a quali-fied component.
In the case of Nelson studs used in connections other than with clamps, the allowable values were developed in accordance with the AISC specification (Ref-I erence A10).
The staff evaluation of the use of Nelson studs is provided in
]
Section 20.1 of this appendix.
The CPRT third party review of the CCL Unistrut test program (CCL A-678-85) and l
Ebasco support capacity calculations for the CA-type and JA-type Unistrut Comanche Peak SSER 16 27 Appendix A
supports (TNE-C/S-CA-CA-la, TNE-C/S-CA-CA-2b, and THE-C/S-CA-JA-1) has con-firmed that conservative capacities are being used for those Unistrut supports which were tested and are used at CPSES.
All Unistrut supports that were not qualified by tests will be replaced (also see Section 8.1 of this appendix).
In addition, TENERA reviewed the static and cyclic tests of conduit clamps and confirmed that the tests were representative of as-built conditions and are adequate for developing design allowable capacities.
i Impell walkdown procedures for Train C specify the various support configura-tions that can be qualified by walkdowns.
Use of components in non-standard ways will be removed or screened out for further evaluation or modification.
The staff concludes that the use of catalog components in a manner intended by the vendors or in a manner validated by appropriate supplemental tests, provides an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGRA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
9.3 Conclusion On the basis of the above evaluations, the staff concludes that the concerns associated with the AISC-derived allowables and the use of catalog components in ways not intended by vendors have been adequately resolved.
The conduit support technical issue concerning improper use of catalog components, there-fore, is closed for CPSES.
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l Comanche Peak SSER 16 28 Appendix A 1
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i 10 ANCHOR BOLTS A number of concerns ware raised regarding ~the Gibbs & Hill design of anchor i
bolts in conduit supports.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified six related concerns from its review of various source documents.
In its conduit Trains A and B results report (Reference A5), TENERA categorized these into the following four areas.
of concern listed below.
i (1) prying factors (2) CST-17 Type 17 supports (3) CA-2a supports (4) substitution of' Richmond inserts
~
The relevant project documents and the corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
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(Ebasco)
SAG.CP2 DAP-CLC-C/S-607-DAP-E-C/S-305 DAP-E-C/S-307 SAG.CPIO DAP-CLC-C/S-609 DAP-E-C/S-305 i
DAP-E-C/S-307 SAG.CP12 DAP-CLC-C/S-605 DAP-E-C/S-311 l
SAG.CP17 DAP-CLC-C/S-606 DAP-E-C/S-311 i
SAG.CP29 DAP-CLC-C/S-602 l
l DAP-E-C/S-307 z
CP-SG-03 DAP-E-C/S-307 l
Calculation Book #60 DAP-CLC-C/S-807 l
DAP-E-C/S-307 l
THE-C/S-CA-CA-la DAP-E-C/S-304 TNE-C/S-CA-CA-2b DAP-E-C/S-304 (Test Laboratory)
CCL Report No. A-678-85 OAP-E-C/S-304
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 29 Appendix A
Project Document
- DAP Feview Document *
(TV Electric)
CPE-EB-FVM-C/S-002 DAP-E-C/S-302 CPE-EB-FVM-C/5-014 DAP-E-C/S-301 CPE-EB-FVM-C/5-033 DAP-E-C/5-301 10.1 Prying Factors The background of this issue is provided in Section 3.2.7.10 of the conduit Trains A and B results report (Reference A5).
The Ebasco resnlutior, methodology is presented in the conduit Trains A and B project status report (Subappen-dix A10, Section 2.0) (Reference A3)..The DAP evaluation is summarizea in Section 3.2.7.10 of the results report, "Specific Results Report for Train A &
B Conduit and Supports" (DAP-RR-C/S-001, Rev.1).
Ebasco's resolution methodol-ogy is presented in the conduit Trains A and B project status report (Subappen-dix A10, Section 2.0A).
The DAP evaluation is summarized in Section 3.2.7.10 of the results report.
The concern raised by CYGNA in its Independent Assessment Program regarding prying factors was that fo" anchor bolt tension, prying factors were not treated consistently and, where used, they were not technically justified.
Sometimes the prying factors were neglected or a 1.5 prying factor was used without justification.
At other times, the AISC Manual (Reference A10) was used to justify a prying factor of 1.0 even though the AISC Manual is intenried for structural steel connections.
Ebasco addressed these concerns by developing prying factors for various generic sizes of conduit support base plates and base angles using finite element analyses that considered the stiffness of the base plate / angle, anchor bolt, and concrete.
These prying factors were specified in the design
_ If criteria documents for use in the conduit support design validation effort.
the base plate / angle design failed using these prying factors or when the generic sizes of the base plate / angle did not match the specific support bd ng investigated, then an individual analysis was performed.
TENERA's review of the Ebasco criterie and guidines (SAG.CP2, SAG.CP10, J:
SAG.CP12, and SAG.CP29) confirmed that prying fav
- s have been specified for l
generic cases and that acceptable methods are spesified for evaluation of prying factors for other types of base plates / angles.
For Unit 2, the DAP review of the Ebasco special study for conduit support anchorage (Book #60) confirmed that an acceptable approach was used to establish prying factors.
Those results have been incorporated in Unit 2 guidelines (CP-SG-03).
Prying factors applicable to Train C supports have been developed in a special Impell calculation file.
TENERA's review ci Impell's special study found that prying of anchor bolts in Train C conduit supports has been satisfactorily addressed.
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- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
1 Comanche Peak SSER 16 30 Appendix A
V The staff concludes that the use of appropriate prying factors 11 the design validation of anchor bolts in conduit support base plates and base angles as justified by the Ebasco studies provides an adequate basis for resolving the concerns identified in this issue, and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documanted in Reference A7.
10.2 CST-17, Type 17 Supports The background of this issue is provided in Section 3.2.7.10 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presc7ted in the conduit Trains A and B project status report (Subappen-dix A10, Section 2.0) (Reference A3).
The DAP evaluation is sucmarized in Section 3.2.7.10 of the results report.
In its Independent Assessment Orogram, CYGNA identified a concern, related specifical b to cantilever conduit supports (CST-17, Type 17), that the design of the concrete connections did not consider the additional moments induced by eccentric shear loads.
This type of support was used in Unit 1 only.
Ebasco addressed this concern by either replacing or eliminating the CST-17, Type 17 supports.
The replacement or elimination of these supports was confirmed by TENERA under the DAP effort.
Conduit support CST-17, Type 17 does not exist in Train C conduits.
- However, Train C support types that experience similar moment loading on the anchor bolts were evaluated for such moment loading.
The CPRT third party review of Impell's special studies indicates that moment loading of anchor bolts has been satisfactorily addressed.
The staff concludes that the replacement or elimination of transverse cantilever supports (CST-17, Type 17) provides an adequate basis to resolve the concerns identified in this issua and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as docmented in Reference A7.
10.3 CA-2a Supports The background of this issue is provided in Section 3.2.7.10 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A10, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.10 of the results report.
The initial design of certain conduit supports consisting of Unistrut members attached directly to concrete with outriggers (CA-2a supports) asstmed that the Hilti Kwik-Bolts in the outriggers do not carry any load.
However, some loads may be imposed on these anchors as a result of conduit loads and prestressing of the support because of the structural configuration of the support compo-i nents.
In addition, the design drawing waived anchor separation violations between the Hilti anchors in the outriggers and other enchors because of the assumption made abcVe.
l Comanche Peak SSER 16 31 Appendix A
i Ebasco addressed these concerns by establishing allowable capacities of the CA-2a supports through tests, Ebasco revised its design drawings so that the use of outriggers in CA-2a supports is not permitted.
The possibility of anchor bolt spacing violations has been considered in the calculations that determine the allowable values for the CA-type supports.
The validation of other supports adjacent to CA-2a-type supports, to address the potential spac-ing violations, is performed as part of the Post Construction Hardware Valida-tion Program (PCHVP).
TENERA's review of the CCL Unistrut test program (CCL Report No. A-678-85) and calculations (TNE-C/S-CA-CA-la and THE-C/S-CA-CA-2b) confirmed that Ebasco developed support capacities with an adequate margin of safety for these supports.
Train C proximity violations for Hilti Kwik-Bolts were considered by checking minimum spacing between anchor bolts during the walkdown process.
The staff concludes that the establishment of allowable ca;e '. ties for CA-2a conduit supports and the evaluation of anchor bolt spacino olations provide an adequ&te basis for resolving the concerns identified i-ais issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
10.4 Substitution of Richmond Inserts The background of this issue is provided in Section 3.2.7.10 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status repurt (Subappen-dix A10, Section 2.0) (Reference A3).
The DAP evaluatior. is summarized in Section 3.2.7.10 of the results report.
In the original design document drawings 2323-S-0910, the substitution of Rich-mond inserts for Hilti Kwik-Bolts was allowed.
However, this might result in i
lower bolt / insert capacities than in the original design.
Ebasco addressed this concern by revising drawings 2323-S-0910 so that the sub-stitution of Richmond inserts for Hilti Kwik-Bolts is not permitted and by requiring the evaluation of spacing violations between Hilti Kwik-Bolts and Richmond inserts.
In addition, the installed supports that were affected by the Richmond insert substitution were evaluated for spacing violations that may have occurred.
TENERAt s review of Ebasco's design criteria (SAG.CP2 and SAG.CP10) and walk-down procedures (CPE-EB-FVM-C/5-002, CPE-EB-FVM-C/S-014, and CPE-EB-FVM-C/S-033) has ccnfirmed that criteria for evaluation of Richmond inserts is in place (based on specification 2323-SS-30) and that adequate instructions have been l
given to identify Richmond insert substitutions.
For Train C, Impell qualified conduit supports using the as-built configuration.
Any replacement of bolts has been identified in the walkdowns, i
Comanche Peak SSER 16 32 Appendix A
4 The staff concludes that the deletion of the option to substitute Richmond inserts for Hilti Kwik-Bolts and the design validation of installed supports r
for appropriate spacing requirements provide an adequate-basis for resolving the concerns identified in this issue and is acceptable.
l The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
10.5 Conclusion On the basis of the above evaluations, the sts/f-concludes that the concerns associated with the design of anchor bolts used in conduit supports have been adequately resolved.
The conduit support technical issue concerning anchor bolts, therefore, is closed for CPSES.
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i Comanche Peak SSER 16 33 Appendix A
11 LONGITUDINAL LOADS ON TRANSVERSE SUPPORTS Concerns were raised that the original design did not consider longitudinal loads on the transverse conduit supports.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (OAP), identified two related con-cerns from its review of various source documents.
In its conduit Trains A and B results report (Reference f5), TENERA combined these into one primary issue.
The relevant project documents and the corresponding DAP review documents for.
this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 OAP-E-C/S-307 11.1 Design of Transverse Conduit Supports for Longitudinal Loads The background of this issue is provided in Section 3.2.7.11 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix All, Section 2.0) (Reference A3).
The OAP evaluation is summarized in Section 3.2.7.11 of the results report.
Because certain transverse supports were found to have substantial stiffness in the conduit longitudinal direction, concerns were raised that the initial Gibbs
& Hill design did not consider longitudinal loads on the transverse supports.
There was no technical justification provided for neglecting the longitudinal loads in the design of transverse support.
Ebasco addressed this issue by validating the designs of all generic supports as multidirectional supports.
In addition, design modifications have been developed to replace or modify transverse conduit supports to be multidirectional-type supports.
TENERA's review of design criteria SAG.CP2 and SAG.CPIO confirmed that the design of all conduit supports is required to be validated for all three load directions.
For Train C, longitudinal loads are included in development of the screening criteria and the qualification of supports.
Transverse supports are design verified for longitudinal loads.
Torsion in longitudinal support beam members arising from load eccentricities &re included in the evaluation whenever such
- All relevant project and CPRT review dccuments are listed in Appendix B to this supplement.
Comanche Peak SSER 16 34 Appendix A
load eccentricities occur.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy of the overall seismic qualification program.
}
The staff concludes that the design validation of all conduit supports as multidirectional (3-way) supports provides an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
l Conclusion On the basis of the above evaluation, the staff concludes that the concerns regarding the effect of longitudinal loads on transverse supports have been adequately addressed.
The conduit support technical issue concerning longi-tudinal loads on transverse supports, therefore, is closed for CPSES.
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Comanche Peak SSER 16 35 Appendix A
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12 HILTI KWIK-BOLT SUBSTITUTION The substitution of Hilti concrete expansion anchors with those of a larger size, which was permitted in the original Gibbs & Hill drawings 2323-S-0910, has raised some concerns.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified two related concerns from its review of various source documents and combined them into one primary issue.
TherelevantprojectdocumentsandthecorrespondingDAPreviewdocumentsfor this issue are listed below.
Project Document
- OAP Review Document *
(Ebasco)
SAG.CP25 DAP-E-C/S-310 DAP-E-C/S-340 Book #145 DAP-CLC-C/S-806 (TV Electric)
CPE-EB-FVM-C/S-002 DAP-E-C/S-302 CPE-EB-FVM-C/5-014 DAP-E-C/S-301 CPE EB-FVM-C/5-033 DAP-E-C/S-301 12.1 Substitution of Conduit Support Anchorages J
The background of this issue is provided in Section 3.2.7.12 of the conduit Trains A and B results report (Reference A5). The Ebasco resolution methodol-ogy is presented in the conduit Trains A and B project status report (Subappen-dix A12, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.12 of the results report.
The initial Gibbs & Hill design drawings 2323-5-0910 permitted substitution of Hilti Kwik-Bolts and Super Kwik-Bolts with bolts of a larger size.
A concern was raised that with a larger bolt, the capacity of the anchorages may be reduced because the bolt spacing may be smaller than that required.
Obasco 6ddressed this concern by validating the design of all conduit supports tased on the as-built information containing anchorage spacing details.
In tddition, for Unit 1, drawings 2323-5-0910 have been revised to no longer per-nit the sinstitution of Hilt.i Kwik-Bolts or Super Kwik-Bolts with bolts of a larger size.
TENERA's review of the walkdown procedures (CPE-EB-FVM-C/S-002, CPE-EB-FVM-C/S-014, and f,PE-EB-FVM-C/S-033) confirmed that adequate instructions were provided to identify the Hilti anchor substitution.
The DAP reviewed the Ebasco special study (Book #145) and confirmed that for Unit 2 certain substitutions have been IAll relevant project and CPRT review documents are listed in Appendix B to
~
this supplement.
Comanche Peak SSER 16 36 Appendix A
~.
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justified on a generic basis; however, other cases would require individual justification.
A review by DAP of design criteria SAG.CP10 and SAG.CP2 con-firmed that acceptable guidelines were provided for the evaluation of substi-tutions that require individual justification.
hpell qualified the supports for Train C using the as-built configuration.
i Any anchor bolt modification utilizing larger bolt substitutions were identified iq the walkdowns and their capacities calculated accordingly.
TENERA's review e/ the applicability of this issue to Train C found that the issue is impli-citly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the as-built walkdown to identify the bolt and spacing details and the design validation of the anchorages using the actual bolt sizes provide an adequate basis to resolve the concerns identified in this issue and are acceptable.
.t The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
12.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns related to Hilti Kwik-Bolt substitutions have been adequately resolved.
The t
i conduit support technical issue concerning Hilti Kwik-Bolt substitution, there-fore, is closed for CPSES.
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l Comanche Peak SSER 16 37 Appendix A
13 SUBSTITUTION OF SMALLER CONDUITS'0N CA-TYPE SUPPORTS The substitution of smaller conduits on conduit supports consisting of Unistrut sections attached directly to concrete (CA-type supports) has raised concerns that the total loads imparted on the supports could exceed those of the large-diameter conduits.
The relevant project documents and the corresponding Design Adequacy Program (OAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 i
DAP-E-C/S-307 Book SUPT-1301 DAP-CLC-C/S-833 DAP-E-C/S-307 (TV Electric)
CPE-EB-FVM-C/S-014 DAP-E-C/S-301 CPE-EB-FVM-C/S-033 DAP-E-C/S-301 13.1 Substitution of Smaller Conduit The background of this issue is provided in Section 3.2.7.13 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology l
is presented in the conduit Trains A and B project status report (Subappen-dix A13, Section 2.0) (Reference A3).
The OAP evaluation is summarized in Section 3.2.7.13 of the results report in the original support drcwings, the substitution of small-diameter conduits i
for larger conduits was permitted on certain CA-type supports.
The supports containing large-diameter conduits were designed for zero period accelerations (assuming rigid system response); supports containing small-diameter conduits were designed for peak-spectrum accelerations (assuming flexible system response). With the substitution of small-diameter conduits, the equivalent seismic load of the small-diameter conduits could exceed those of the large-l diameter conduite.
This issue applies to Unit 1 and areas common to Units 1 and 2 only because there are no CA-type supports in Unit 2.
i Ebasco addressed this issue by using only one set of seismic design accelera-tions regardless of conduit sizes.
- All relevant project and CPRT review documents are listed in Appendix 8 to
{
this supplement.
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Comanche Peak SSER 16 38 Appendix'A l
y
.y-,
- - +. -
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TENERA's review of design criterion SAG.CP10 confirmed that Ebasco specified one set of seismic accelerations for the design validation of fabricated con-duit supports.
The DAP review of walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that adequate instructions were provided to identify the conduits to address this issue.
TENERA's review of the Ebasco l
calculation (BookSUPT-1301)demonstratedthatEbascoproperlyimplemented the resolution methodology described above.
Impell qualified the supports for-Train C using the as-built configuration.
Any substitutions are identified in the walkdowns and qualified using the as-built configurations.
TENERA's review of the applicability of this issue to
~
Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the use of an appropriate seismic analysis method for the design validation of as-built conduit systems provides an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documerAed in Reference A7.
13.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns 4
associated with substitution of smaller conduit have been adequately resolved.
The conduit support technical issue concerning substitution of smaller conduits on CA-Type supports, therefore, is closed for CPSES.
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I Comanche Peak SSER 16 39 Appendix A
I 14 USE OF CA-TYPE SUPPORTS IN LS SPANS The use of conduit supports consisting of Unistrut sections attached directly to concrete (CA-type support) in transverse spans up to 12 feet long or longitudinal spans up to 24 feet long (LS spans) has raised concerns that the actual seismic accelerations could exceed the support design loads.
The CPRT l
third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified two related concerns from its review of various source docu-i ments.
In its conduit Trains A and B results report (Reference A5), TENERA combined these into one primary issue.
The relevant project documents and the corresponding DAP review documents are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP25 DAP-E-C/S-314 DAP-E-C/S-310 (TV Electric)
CPE-EE-FVM-C/S-033 DAP-E-C/S-301 14.1 Methodology for CA-Type supports in LS Spans The background of this issue is provided in Section 3.2.7.14 of the conduit Trains A and B results report (Reference AS).
Ebasco's resolution methodology
)
is presented in the conduit Trains A and B project status report (Subappen-i dix A14, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.14 of the results report.
For CA-type supports supporting large-diameter conduits, the seismic design loads were calculated using zero period acceleration (ZPA) based on the assumption of rigid response for spans limited to 6 feet in length (LA spans).
Since the conduits are field run, a CA-type support may be installed adjacent to multidirectional supports.
The span between the two supports was con-sidered to be an LA-span (rigid response) since the span length did not exceed that specified by the design of the CA-type support.
However, the rigidity of the span was found to be an erroneous assumption because of the flexibility of the multidirectional support and the effect of the flexible spans on the other side of the multidirectional support.
Thus, the seismic accelerations for the flexible span on the CA-type support could exceed the l
zero period acceleration used for design.
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
i Comanche Peak SSER 16 40 Appendix A
Ebasco has addressed this issue by eliminating the rigid (LA) spans from draw-ings 2323-S-0910 and specifying in its design validation criteria that rigid conduit spans (LA) cannot be used; all spans are to be design validated as flexible (LS) spans.
The design of CA-type supports was validated using only the one set of seismic accelerations that envelope all conduit sizes.
TENERA's review of design criteria (SAG.CP10), confirmed that Ebasco is usir.g only one set of seismic accelerations that envelope all conduit sizes.
The walkdcwn procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) and technical guideline (SAG.CP25) also were reviewed by the DAP. - The DAP concluded that appropriate procedures were developed to gather the required as-built informa-tion and that adequate guidelines were in place to evaluate the as-built data in accordance with the resolution methodology described above.
3 Span allowable values are defined by Impell for the Train C work.
For cases in which frequencies of the conduit support spans are not calculated, spectral peak accelerations in combination with the appropriate dynamic amplification factor are conservatively used to develop these span allowable values.
Alternatively, actual support stiffnesses ara used to calculate the frequencies of the conduit support spans and the corresponding inertial loading.
Support qualification is based on as-built walkdowns.
The staff concludes that the use of an appropriate seismic analysis method for the design validation of as-built conduit systems provides an adequate basis for resolving the concerns identified in this issue and is acceptable.
Tne CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
14.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with this issue have been adequately resolved.
The conduit support technical issue concerning the use of CA-type supports in LS spans, therefore, is closed for CPSES.
Comanche Peak SSER 16 41 Appendix A
15 STRESSES IN CABLE TRAYS RESULTING FROM ATTACHED CONDUIT SUPPORTS The initial Gibbs & Hill designs allowed conduit stubs to be clamped to cable tray-rails.
Concerns were raised regarding the effects on analysis and design.
of conduit attachments to cable trays.
Two areas of concern relating to this issue are (1) the additional loads on cable trays resulting from conduit attach-(
ments and (2) the use of correct seismic accelerations considering the flexi-bility of cable trays.
t The relevant project document and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 l
15.1 Additional Loads on Cable Trays Resulting From Conduit Attachment The background of this issue is provided in Section 3.2.7.15 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A15, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.15 of the results report.
[
This concern deals with the additional loads on cable trays resulting from con-l duit attachments.
An example of this is conduit support detail, C50-16, con-j tained in the original Gibbs & Hill drawings 2323-S-0910.
If cable trays are designed to the full capacity of the tray, then the addition of CSD-16 to the tray would increase the loads above the capacity of the cable tray.
Thus, all j
cable tray spans with conduit attachments should be individually checked for j
total loads.
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Ebasco addressed this concern by evaluating the effects of conduit attachments to cable trays in the cable tray and cable tray Langer design validation under the Corrective Action Program.
The staff evalur. tion of this issue is addressed in conjunction with its review of the CAP works: ope for cable tray and cable j
tray hangers.
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Trays with attached Train C conduit supports are individually qualified with due consideration of the added conduit weights.
Walkdowns will screen out any 1
conduit supports attached to cable trays.
The qualification of these conduit supports will account for the effect of cable tray flexibility.
TENERA's i
review of the anplicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
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- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
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i Comancha Peak SSER 16 42 Appendix A I
..m.,_
,,. _ _ ~ _, _ _.
15.2 Use of Correct Seismic Accelerations The background of this issue is provided in Section 3.2.7.15 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and 8 project status report (Subappen-dix A15, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.15 of the results report.
This concern deals with the selection by Gibbs & Hill of the appropriate seismic acceleration for the CSD-16 support.
If a rigid conduit were attached to the cable trays then the zero period acceleration (ZPA) would be used to determine the equivalent static seismic loads on the CSD-16 support.
This approach would not be appropriate if the conduit support were attached to a flexible tray span because of the potential amplification of input acceleration at the resonance frequency.
Ebasco addressed this concern by specifying in its design validation criteria that rigid conduit attached to cable trays are required to be design validated using 1.5 times peak spectral acceleration.
The DAP review of Ebasco's criteria (SAG.CP10) confirmed that this requirement is included.
Impell project instructions for Train C conduit supports require the consider-ation of added tray flexibility to evaluate conduit supports attached to cable trays.
Appropriate dynamic amplifcation factors are used in evaluating support loads.
TENERA's review of the applicability of this issue to Train C found s
l that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the use of an appropriate seismic analysis method for the design validation of as-built conduit systems provides an adequate basis
{
for resolving the concerns identified in this issue and is acceptable.
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The CYGNA review of this issue and of the CAP resolution has resulted in closure j
of all CYGNA conduit support issues as documented in Reference A7.
15.3 Conclus(on 4
l On the basis of the above evaluations, the staff concludes that the concerns associated with stresses to cable trays from the attached conduit supports have been adequately resolved.
The conduit support technical issue concerning conduit attachment to cable trays, therefore, is closed for CPSES.
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Comanche Peak SSER 16 43 Appendix A i
1.
t 16 INCREASES IN ALLOWABLE SPAN LENGTHS A concern was raised that when certain span lengths were increased based on I
refined spectra, the adequacy of the longer conduits was not demonstrated.
The relevant project documents and the corresponding Design Adequacy Program (OAP) review documents for this issue are listed below.
p Project Document
- DAP Review Document *
(Ebasco) i SAG.CP10 DAP-CLC-C/S-609 OAP-E-C/S-305 0AP-E-C/S-307 SAG.CP20 DAP-CLC-C/S-604 DAP-E-C/S-313
]
16.1 Effect of Span Length Increase on Conduit Stress i
The background of this issue is provided in Section 3.2.7.16 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A16, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.16 of the results report.
Gibbs & Hill drawings 2323-S-0910 were revised to increasa LA span lengths 1
(conduit spans designed to be rigid) by the ratio of the refined to the i
unrefined spectra.
Calculations performed by Gibbs & Hill demonstrated that the increased spans remain rigid.
This approach is appropriate for support i
designs because the support loads are proportional to span lengths.
- However, i
since conduit bending stresses are proportional to the square of the span length, an snalysis to calculate the conduit stress also is required.
2 Ebasco addressed this issue by eliminating the use of LA spans and requiring i
that all conduit spans be evaluated as LS spans (flexible spans). Design validation criteria for evaluating conduit stresses are specified in Ebasco
)
documents SAG.CP10 and SAG.CP20.
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The DAP review confirmed that the criteria and procedures specified in Ebasco's documents are appropriate for validating the design of conduit spans.
Refined spectra were used for Train C evaluation.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly j
captured by the adequacy review of the overall seismic qualification program.
l The staff concludes that the use of an appropriate seismic analysis method for j
the design validation of as-built conduit systems provides an adequate basis for resolving the concerns identified in this issue and is acceptable.-
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- All reltvant project and CPRT review documents are listed in Appendir. B to this supplement.
Comanche Peak SSER 16 44 Appendix A
~-
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The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
16.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns related to stresses in conduits with increased span lengths have been adequately resolved.
The conduit support technical issue concerning increases in allowable span lengths, therefore, is closed for CPSES.
Comanche Peak SSER 16 45 Appendix A
17 SUBSTITUTION OF NEXT HEAVIER STRUCTURAL MEMBER l
Concerns were raised regarding the adequacy of conduit supports when a support structural member was substituted by the next heavier size member as permittud in the original Gibbs & Hill construction drawings.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identi-fled two related concerns from the various source documents and combined these into one primary issue.
I The relevant project documents and the corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP25 DAP-E-C/S-310 DAP-E-C/S-314 Book SPAN-1189 DAP-E-C/S-307 DAP-E-C/S-313 DAP-E-C/S-314 i
Book SUPT-0247 DAP-E-C/S-307 (TV Electric)
CPE-EB-FVM-C/S-014 DAP-E-C/S-301
[
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CPE-EB-FVM-C/S-033 DAP-E-C/S-301
~
17.1 Effect of Structural Member Substitution l
The background of this issue is provided in Section 3.2.1.17 of the conduit l
Trains A and B results report (Reference A5).
Ebasco's resolution methodology l
is presented in the conduit Trains A and B project status report (Subappen-dix A17, Gection 2.0) (Reference A3).
The DAP evaluation is summarized in i
Section 3.2.7.17 of the results report.
i The original Gibbs & Hill drawings 2323-5-0910 permitted the substitution of 3
a a conduit support structural member by the next heavier structural member to that shown on the particular drawing.
Since support self-weight was not j
properly considered in some oesigns (see Section 7.1 of this appendix), certain
?
components of the support could have been overstressed, i
Ebasco addressed this concern by requiring as-built walkdowns for all conduit 1
supports to identify and document the structural members used. The as-built i
l information includes the member sizes for all open structurr.1 shapes such as angles, channels, and I-beams.
For tube steel, since the installed thickness could not readily be determined, a special study was performed to evaluate the l
- All relevant project and CPRT review documents are listed in Appendix B to l
this supplement.
i j-Comanche Peak SSER 16 46 Appendix A
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l effect of substitution of the next heavier tube steel.
The study covered generic cantilever-type supports; other supports (modified and individually 1
engineered [IN]), which utilized tube steel members, were evaluated using the.
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weight of the next heavier member.
TENERA's review of walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that the procedures correctly specify that the required infor-l mation be obtained and recorded to permit the evaluation of supports where the next heavier member has been substituted.
TENERA's review of the special studies (Book Nos. SPAN-1189 and SUPT-0247) confirmed that the effects of the next heavier tube steel substitution have been adequately addressed.
TENERA's i
review of SAG.CP25 verified that the, appropriate criteria are specified to consider the effects of the substitution of next heavier structural member in the design validation of conduit supports.
)
Impell qualified Train C supports, including proper consideration of self-weight effects, using the as-built configuration.
Any substitutions were identified in the walkdowns and were qualified using the as-built configurations.
l TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the implementation of the conduit support as-built I
verification program and the requirement to consider the effects of substitu-l tion of the next heavier member in the design validation provide an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
I 17.2 Conclusion il On the basis of the above evaluation, the staff concludes that the concerns j
associated with the substitution of the next heavier structural member have been adequately resolved.
The conduit support technical issue, therefore, is J
closed for CPSES.
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i Comanche Peak SSER 16 47 Appendix A 1
t 18 CLAMP USAGE A number of concerns were raised with respect to conduit clamp usage.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified three related concerns from its review of various source documents.
In its conduit Trains A and B results report (Reference A5), TENERA categorized these into the three areas listed below.
(1) clamp modifications (2) modification of C703-5 clamps (3) clamp distottion The relevant pro 1ect documents and the corresponding DAP review documents for this issue are listed below.
Project Document" 0APReviewDocumeg" (Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 OAP-E-C/S-305 DAP-E-C/S-307 Book SPAN-1200 DAP-E-C/S-308 Position paper on DAP-E-C/S-309 1
quality of construction of conduits and conduit supports (Test Laboratory)
CCL Report No. A-699-85 DAP-E-C/S-308 i
CCL Report No. A-702-86 DAP-E-C/S-308 (TV Electric)
CPE-EB-FVM-C/S-002 DAP-E-C/S-302 1
CPE-EB-FVM-C/S-014 DAP-E-C/S-301 CPE-EB-FVM-C/S-033 OAP-E-C/S-301
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 48 Appendix A
i 18.1 Clamp Moditications The background of this issue is provided in Section 3.2.7.18 of the conduit
{
Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A18 Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.18 of the results report, This concern deals with Unistrut P2558 clamps that were teamed during con-struction to accommodate larger bolts.
As a result, the minimum edge-distance requirements could have been violated and the washers for certain Hilti Kwik-Bolts would not fit properly on the clamp.
Ebasco addressed this concern using allowables for the clamps based on a conduit clamp testing program performed by CCL (CCL Report Nos. A-699-85 and A-702-86).
The test program considered the effects of oversized holes; reduced edge distances; modified, omitted, or distorted washer 3; and distorted clamps.
Ebasco reviewed the results of these tests and incorporated those results into its design criteria.
TENERA's review of the CCL test program confirmed that the tests were repre-i 4
sentative of the as-built conditions.
In addition TENERA confirmed that the l
test results have been properly interpreted in Ebasco's special study (Book f
No. SPAN-1200) and that the results of the test program have been appropriately t
incorporated in the design validation criteria (SAG.CP2 and SAG.CP10).
For Train C, CPRT third party review of the CCL test program found that the clamp test allowable values have been properly developed and have an appropriate j
factor of safety.
j The staff concludes that the development of a conduit clamp test program to j
consider the effect of edge-distance viclations as a result of oversized bolt holes in the clamps and the use of the clamp test data in the design validation of conduit supports provide an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure i
of all CYGNA conduit support issues as documented in Reference A7.
18.2 Modification of C708-S Clamps The background of this issue is provided in Section 3.2.7.18 of the conduit l
Trains A and B results report (Reference A5).
Ebasco's resolution methodology I
is presented in the conduit Trains A and B project status report (Subappen-j dix A18, Section 2.0) (Reference A3).
The DAP evaluation is summarized in l
Section 3.2.7.18 of the results report.
C708-S clamps for conduits were modified by cutting off the end portion of the clamp ears.
This modification, which removes two of the four bolt holes from j
the clamp, was not justified.
Ebasco addressed this concern using the CCL test program.
The test program
)
considered the modifications allowed by the Gibbs & Hill drawings 2323-5-0910.
Ebasco reviewed tne results from the test and incorporated those results into j
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its design criteria.
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Comanche Peak SSER 16 49 Appendix A I
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As discussed above in Section 18.1, TENERA's review of the CCL test program (CCL Report Nos. A-699-85 and A-702-86) and special study (Book SPAN-1200) confirmed that Ebasco properly addressed the concern related to the modification i
of the C708-S clamp.
j Impe11 qualified Train C supports using the as-built configuration.
Any support deficiencies were identified in the walkdowns and evaluated on a j
case-by-case basis.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of i
4 the overall seismic qualification program.
The staff concludes that the development of a test program, which included I
modified clamp ears and the use of the clamp test data for design validation of conduit supports, provides an adequate basis for resolving the concerns identi-
]
fled in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure i
of all CYGNA conduit support issues as documented in Reference A7.
\\
18.3 Clamp Distortion The background of this issue is provided in Section 3.2.7.18 of the conduit l
j Trains A and B results report (Reference AS).
Ebasco's resolution methodology i
4-is presented in the conduit Trains A and B project status report (Subappen-i dix A18, Section 2.0) (Reference A3).
The DAP evaluation is summarized in s
]
Section 3.2.7.18 of the results report.
This concern relates to the identification of clamp distortion by CYGNA for the 1
four specific conduit supports (C12G03528-8, C12G002935-4, Cl?G03126-18, and C12G02851-6).
j Ebasco addressed this concern using the CCL test program (CCL A-699-85 and A-702-86), which considered clamp distortion for all conduit clamps.
The test i
program provided data for potential clamp distortions beyond design tolerances j
except for clamps anchored with 1/4-inch anchor bolts.
For the 1/4-inch anchor bolts, the test program showed that a reduction in anchor bolt spacing beyond l
the design tolerance resulted in loss of support capability in the longitudinal direction.
Ebasco is inspecting the clamps with 1/4-inch anchor bolts as part l
of the Post-Construction Hardware Validation Program (PCHVP) to ensure that l
they meet the required tolerance or are modified.
l With the exception of the clamps with 1/4-inch anchors, TENERA's review con-t i
firmed the adequacy of the CCL test program and validity of the resulting j
clamp allowables developed by Ebasco.
The DAP review of the walkdown procedures (CPE-EB-FVM-C/S-002, CPE-EB-FVM-C/S-014, and CPE-EB-FVM-C/S-033) confirmed that l
appropriate procedures are in place to identify clamp information necessary for design validation.
The DAP also confirmed Ebasco's commitment (position paper i
i on quality of construction) to inspect the 1/4-inch bolt clamps as part of the l
PCHVP and found the program will adequately address the issue of distortion for l
these clamps.
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This issue is specific to Trains A and B hardware.
No action was required for Train C.
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Comanche Peak SSER 16 50 Appendix A
^
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The staff concludes that the development of a test program to establish clamp allowable loads for distorted clamps, the use of the clamp test data in the design validation of conduit supports, and the implementation of the PCHVP to correct clamps with 1/4-inch anchor bolts provide an adequate basis for resolving the concerns identified in this issue and are acceptable.
The CYGNA review of tnis issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
18.4 Conclusion On the basis of the e.bove discussion, the staff concludes that the concerns related to clamp modifications and clamp distortions have been adequately resolved.
The conduit support, technical issue concerning clamp usage, there-fore, is closed for CPSES.
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1 Comanche Peak SSER 16 51 Appendix A l'l 1
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i 19 DOCUMENTATION DEVIATIONS BETWEEN INSPECTION REPORTS, COMPONENT MODIFICATION CAROS, AND INDIVIOUALLY ENGINEERED FII'E-PROTECTED ORAWINGS e
Concerns were raised regarding documentation and conduit configuration devla-tions.
The CPRT third party (TENERA, LP.), in conjunction with the Design i
Adequacy Program (DAP), identified two related concerns from its review of various source documents.
In its conduit Trains A and B results report (Ref-4 1
erence A5), TENERA cctegorized these into (1) documentation deviations and (2) conduit configuration deviations.
r The relevant project documents and the corresponding DAP review documents for j
this issue are listed below, i
Project Document
- OAP Review Document *
(Ebasco)
SAG.CP25 DAP-E-C/S-310 DAP-E-C/S-314 Position paper on DAP-E-C/S-309 quality of construction of conduits and conduit supports (TV Electric) i i
CPE-EB-FVM-C/S-014 DAP-E-C/S-301 l
CPE-EB-FVM-C/S-033 DAP-E-C/S-301 19.1 Documentation Deviations The background of this issue is provided in Section 3.2.7.19 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolutten methodology is presented in the conduit Trains A and B project status report (Subappen-dix A19, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.19 of the results report.
f In the initial design and construction effort for each conduit system, an inspection was performed by quality control and documented by a conduit line i
inspection report (IR).
These irs did not always reflect the information contained in component modification cards (CMCs) and individually engineered fire protected (IN-FP) conduit and support drawings.
l The type of documentation deviations identified included (1) differences in i
support designation type between irs and CMCs, (2) differences in revision l
number of supports between irs and CMCs, (3) omission of applicable CMCs and/or their revision number on irs, and (4) inconsistency in support documentation between IR and IN-FP conduit support drawings.
l
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 52 Appendix A
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l Ebasco addressed this concern by performing an engineering walkdown to develop j
as-built drawings of the conduits and their supports.
The walkdown included i
fire protected lines covered with Thermo-Lag.
The design of each conduit run and support was then validated for conformance with revised drawings 2323-5-0910 and Ebasco criteria documents SAG.CP10, SAG.CP17, and SAG.CP25.
To address the specific documentation deviations identified by CYGNA, which resulted in this issue, Ebasco investigated each of the documentation devia -
i tions.
As reported by TENERA in its conduit Trains A and B results report, l
the DAP found that there was no safety significance to any of the identified deviations.
7 TENERA's review of the walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that adequate procedures have been specified for the prepar-ation of as-built drawings.
TENERA's review of the Ebasco position paper on quality of construction confirmed that adequate documentation exists to quan-tify the attributes necessary to perform the design validation.
This issue does not apply to the Train C conduit program since as-built support drawings did not exist originally.
The Train C conduit support quali-fication is based on as-built configurations obtained by Impell.
The staff concludes that the development of conduit support as-built drawings in the Ebasco walkdowns and the complete design validation of as-built conduit I
systems provide an adequate basis for resolving the concerns identified in this l
issue and are acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
i 19.2 Conduit Configuration Deviations The background of this issue is provided in Section 3.2.7.19 of the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology i
is presented in the conduit Trains A and B project status report (Subappen-l dix A19, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.19 of the results report.
Deviations were identified between the final irs and installed configurations l
l for two conduit lines.
Apparently, the latest irs did not reflect the l
as-installed conditions.
In one case the IR lists four supports; the actual i
conduit run contains only three.
A support that was removed and another support that was remarked was not reflected in an updated IR.
In another l
case, a support that was installed in the field was not listed in the IR.
Ebasco addressed this concern in the same manner as it did for the documentation deviations (see Section 19.1 above).
In addition, there was no safety signifi-cance to any of the identified deviations.
)
i This issue does not apply to the Train C conduit program since as-built support drawings did not exist originally.
The Train C conduit suppurt quali-i fication is based on as-built configurations obtained by Impell.
)
l Comanche Peak SSER 16 53 Appendix A
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Thus, the staff finds that the program established to obtain as-built informa-4 tion and the design validation effort of conduits and supports provide an i
adequate basis to resolve the concerns related to configuration deviations,"
and are acceptable.
2 2
i The CYGNA review of this issue and of the CAP resolution has resulted in closure i
of all CYGNA conduit support issues as documented in Reference A7.
19.3 Conclusion On the basis of the above evaluations, the staff concludes that the concerns associated with documentation and configuration deviations have been adequately resolved.
The conduit support technical issue cor.cerning documentation deviations between irs, CMCs,.and IN-FP drawings, thereforo, is closed for CPSES.
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j Comanche Peak SSER 16 54 Appendix A
20 NELSON STUDS A number of concerns were raised relating to the design and analysis-of Nelson stud connections in conduit supports.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review document for this issue are listed below.
Project Document
- OAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 i.
SAG.CPIO DAP-CLC-C/S-609 OAP-E-C/S-305 DAP-E-C/5-307 l
Book #44 DAP-CLC-C/S-811 DAP-E-C/S-307 (Test Laboratory)
CCL Report No. A-699-85 DAP-E-C/S-308 CCL Report No. A-702-86 DAP-E-C/S-308 20.1 Design Consideration for Nelson Studs i
~
The background of this issue is provided in Section 3.2.7.20 of the conduit i
Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A20, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.20 of the results report.
In the initial conduit support design calculations, Gibbs & Hill did not cht-k that the Nelson studs conformed to the vendor specifications and allowable i
values.
Subsequently, Gibbs & Hill performed calculations to demonstrate the i
adequacy of the installed Nelson stud configurationc,.
These calculations raised concerns that the calculations did not account for the flexibility of the clamp and shim plate, relaxation of the preload, and the moment caused by l
the eccentric load application.
In addition, the stress analysis performed l
for the shim plate was not appropriate.
1 l
Ebasco addressed the above concerns in the following manner:
For conduit clamp connections that utilize Nelson studs, allowable capacities were deter-mined by CCL tests (CCL Report Nos. A-699-85 and A-702-86).
For Nelson studs that are not used in the clamp connections, allowable loads are determined by i
- All relevant project and CPRT review documents are listed in Appendix B to this supplement, i
l Comanche Peak SSER 16 55 Appendix A
I treating the studs as threaded fasteners in accordance with the AISC specifi-a 4
cation (Reference A10).
The Neh,on stud vendor concurred in this approach.
i The adequacy of the shim plate, weld, and structural member were reanalyzed.
TENERA's review of the CCL clamp tests confirmed that the concerns described above have been adequately addressed for Nelson studs used in clamp connec-tions.
In addition, TENERA confirmed that Ebasco's analysis (Book #44) was performed to demonstrate the structural adequacy of the shim plate, weld, and i
4 structural member.
The use of the AISC specification for the design of Nelson i
studs in other than clamp connections was found to be acceptable.
The DAP review of Ebasco's design criteria (SAG.CP2 and SAG.CP10) confirmed that appro-i priate Nelson stud pre-tension forces and a ductility ratio are specified for evaluation of cenduit connection details.
[
To date, Train C conduit supports in Unit I with Nelson stud application have not been identified.
Nelson studs cre expected to exist in Train C conduit j
supports for Unit 2.
A method of evaluation will be developed based on a survey i
of the various support configurations with Nelson stud application.
TENERA's I
review of the applicability of this issue to Train C found that the issue is l
implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the development of a test program to establish Nelson l
stud capacities when used in clamp connections and the use of appropriate criteria for the design of Nelson studs as approved by the vendor provide ar.
a adequate basis for resolving the concerns identified in this issue and are j
)
acceptable.
i The CYGNA review of this issue and of the CAP resolution has resulted in ;1osure i
of all CYGNA conduit support issues as documented in Reference A7.
i r
20.2 Conclusion On the basis of the above evaluation, the staff concludes that Ebasco's testiag i
program, analysis methods, and use of the AISC specification adequately resolve the concerns raised by this issue.
The conduit support technical issue concerning Nelson studs, therefore, is closed for CPSES.
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i Comanche Peak SSER 16 56 Appendix A
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21 CONDUIT FIRE-PROTECTION CALCULATIONS Some concerns were raised regarding calculations performed by Gibbs & Hill for conduits and supports with fire protection insulation (Thermo-Lag).
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified four related concerns from its review of various source docu-ments.
In its conduit Trains A and B results report (Reference AS), TENERA i
categorized these into the four areas listed below.
l (1) Thermo-Lag configuration (2) CA-la supports (3) CA-2a supports l
(4) IN-FP calculations i
TherelevantprojectdocumentsandthecorrespondingDAPreviewdocumentsfor this issue are listed below.
l Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 OAP-E C/S-305 j
DAP-E-C/S-307 SAG-CP25 DAP-E-C/S-310 OAP-E-C/S-314 l
(TV Electric)
CPE-EB-FVM-C/S-033 DAP-E-C/S-301 j
21.1 Thermo-Lag Configuration i
The background of this issue is provided in Section 3.2.7.21 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology i
is presented in the conduit Trains A and B project status report (Subappen-oix A21, Section 2.0) (Reference A3).
The DAP evaluation is summarized in l
Section 3.2.7.21 of the results report.
i The fire protection calculations performed by Gibbs & Hill considered a round configuration of Thermo-Lag material around the conduits.
Thus, the weight of the Thermo-Lag material on the spans was based on this configuration.
- CYGNA, in conjunction with its Independent Assessment Program, determined chat square configurations also existed in the field.
Ehasco addressed this concern by performing a walkdown of all conduit systems, including the fire protection lines, to obtain as-built information.
The design of conduits and supports was validated on the basis of the as-built configurations and conditions obtained from the walkdowns.
I
- All relevant project. and CPRT review documents are listed in Appendix B to this supplement, t
Comanche Peak SSER 16 57 Appendix A
)
TENERA's review confirmed that the watkdown procedure (CPE-EB-FVM-C/S-033) provides appropriate instructions to obtain the as-built information needed to address this issue.
In addition, the review of design criteria (SAG.CP10 and SAG.CP25) confirmed that edequate procedures are in place to quantify inaccessi-ble attributes and to validate the design of fire protected conduit and conduit supports.
The as-built walkdowns will identify the presence of any fire protection mate-rial for Train C conduit systems.
The additional weight will be considered for support evaluation.
TENERA's review of the applicability of this issue to Train C found that the issue is iriplicitly captured by the adequacy review of the overall seisu : qualification program.
The staff concludes that the as-built walkdown effort documenting the type of Thermo-Lag used on conduit and the design validation of as-built conduit systems provide an adequate basis to resolve the concerns relating to differences between the as-built conditions and the calculations for the design of the fire protected conduit systems and are acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
21.2 CA-la Supports The backgrourd o'T this issue is provided in Section 3.2.7.21 ef the conduit Trains A and B results report (Reference A5).
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A21, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.21 of the results report.
Tables in the previous Texas Utilities Generating Company (TUGCO) Instruction CP-EI-4.0-4.9 specified the capacities for use in determining the adequacy of CA-la supports with fire protect'on.
However, the tables did nct specify that the capacities given are limited to the support configurations used in the calculations that developed the capacities.
Ebasco addressed this concern by superseding Engineering Instruction CP-EI-4.0-4.9 with drawings 2323-5-0910 and the associated technical guidelines (SAG.CP25).
The capacities of CA-la. supports have been revised and validated.
See Sections 8.1 and 8.2 of this appendix for the specific method used to validate CA-type supports and for the staff's evaluation of the Ebasco resolution methodology.
1 21.3 CA-2a Supports The background of this issue is provided in Section 3.2.7 21 of the conduit Trains A and B results report (Reference A5).
Ebasta's resoluu on methodology is presented in the conduit Trains A and B project status report (Subappen-dix AP., Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.21 of the results report.
Comanche Peak SSER 16 58 Apoendix A
Capacities for CA-2a supports also were specified in the previous TUGC0 Instruction CP-EI-4.0-4.9.
The calculaHons that developed there capacities stated that the CA-la capacities should be used for CA-2a supports, since CA-2a supports are sim1'.n to and stronger than CA-la supports.
However, the tabulated capacitic the CA-2a supports appear to be in error when compared to the CA-la capaciL Ebasco has addressed th' ncern by superseding Engineering Instruction CP-EI-4.0-4.9 with drai
, 2323-S-0910 and the associated technical guidelines (SAG.CP25).
The caoacities of the CA-2a supports have been revised and validated.
See Sections 8.1 and 8.2 of this appendix for the specific method used to validate CA-type supports and for the staff's evaluation of the Ebasco resolu-tion methodology.
21.4 IN-FP Calculations The background of this issue is provided in Section 3.2.7.21 of the conduit Trains A and B re alts report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A21, Section 2.0) (Reference A.3).
The DAP evaluation is summarized in Section 3.2.7.21 of the results report.
CYGNA identified specific concerns during its review of IN-FP calculations.
The orientation of supports was not given on IN-FP drawings, but the calcula-tions assumed a configuration for the analysis.
Some of the IN-FP calculations did not include the affects of CMCs.
Support capacities used for the qualifi-cation of fire protected supports were taken from current revisions of the support drawings, but
',e supports were originally installed and inspected to earlier revisions of the drawings.
1 Ebasco's resolution methodology and the staff's evaluation for the subject concerns are described above in Section 21.1 #cr the Thermo-Lag configuration.
TENERA's review of the applicability of this issue to T'.'ain C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
i 21.5 Conclusion On the basis of the abcve evaluations, the staff concludes that the cuncerns associated with calculations for conduit with fire protection material have been adequately resolved.
The conduit support technical issue concerning con-duit fire protection calculations, therefore, is closed for CPSES.
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l Comanche Peak SSER 16 59 Appendix A u
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22 SPAN INCREASE FOR FIRE-PROTECTED SPANS The original Gibbs & Hill analysis and design of conduit spans.for fire-protected runs have raised some concerns.
In its conduit Trains A and B results report (Reference AS), TENERA categorized these into two areas:
(1) allowable stress values and (2) stre:,s evaluation.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Proje_ct Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 l
DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 D4P-E-C/S-307 Book SPAN-1199 DAP-E-C/S-313 l
22.1 Allowable Stress Values The background of this issue is provided in sect.on 3.2.7.22 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B pro,iect status report (Subappen-dix A22, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.22 of the results report.
f CYGNA raised specific concerns in conjunction with its Independent Assessment l
Program. During its review of the design calculations relating to allowable stress values, CYGNA found that vendor test data were used to obtain the yield stress for conduits.
To obtain an allowable stress for a particular conduit size, Gibbs & Hill used the lowest tested yield stress for each conduit size or an imposed minimum yield stress value of 33 kei.
No justification was l
provided for the imposed minimum yield stress value.
CYGNA further found that it was not appropriate to specify different allowable stresses for each conduit size.
Furthermore, documentation could not be provided to justify the appli-cability of the vendor test data to the conduits installed at USES.
Ebasco a(dressed these concerns by utilizi' yield stress of 25,000 psi for ell conduit sizes.
As stated in the conrii rains A and 8 project status report, this yield stress value is the low m' :e for any commerically available steel used for conduits.
TENERA's review of Ebasco's design criteria (SAG.CP2 and SAG.CP10) confirmed that the 25,000 psi value of yield strats specified to determine allowable stress values for the conduits was appropriato "All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 60 Appendix A i
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The above concerns are specific to Trains o and B conduit work.
Conduit stre s qualification is not required for Train C conc'uit.
The staff concludes :. hat the use of the lowest yield stress value (or any commercially available steel used for conduit in the conduit design validation provides an adequate basis for resolving the concerns identified iri this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
22.2 Stress Evaluations The background of this issue is provided in Section 3.2.7.22 of the conduit Trains A and B results report (Reference A5).-
The Ebasco resolution methodology is presented in the conduit Trains A and B project status report (Sut ppen-dix A22, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.'/.22 of the results report.
In the method used by Gibbs & Hill for the calculation of conduit stress, a dynamic amplification factor (DAF) of 1.0 was used without justification.
TheconcernregardingtheDAFusedforconduitsystemsandtaestaff's evaluation of Ebasco s resolution methodology for the DAF issue is discussed in Section 2.1 of this appendix.
22.3 Conclusion On the basis of the above evaluations, the staff concludes that the concerns of allowable stress values and dynamic amplification factor have been adequately resolved.
The conduit support technical issue concerning span increase for fire protected spans, therefore, is closed for CPSES.
Comanche Peak SSER 16 61 Appendix A
23 GROUTED PENETRATIONS Concerns were raised regarding design assumptions used by Gibbs & Hili for grouted conduit penetrations in walls and floors.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *'
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 1
DAP-E-C/S-305 DAP-E-C/S-307 Book #151 (Unit 2)
DAP-CLC-C/S-840 DAP-E-C/S-305 q
1 23.1 Design Considerations for Grouted Penetrations The background of this issue is provided in Section 3.2.7.23 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-
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dix A23, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.23 of the results report.
j In the initial design of grouted conduit penetrati
, Gibbs & Hill assumed that longitudinal conduit supports were not requireo if there were no bends in the conduit run.
The grouted conduit penetrations were assumed to carry the entire longitudinal load for straight conduit runs.
Also, all grouted conduit penetrations were assumed to be multidirectional supports.
Calculations were not perforried to demonstrate the adequacy of the penetration to carry the required leads.
In addition, the effects of the relative stiffnesses of adjacent supports and conduit configuration were not considered.
Ebascu addressed the above concerns by requiring that penetrations be evaluated to ensure their ability to withstand the applied loads.
The grouted penetra-tions are designed as multidirectional supports.
In performing the calcula-tions that verify the penetration adequacy, the conduit is assumed to be fixed at the penetration.
For the longitudinal direction, allowable bond stresses between the conduit and concrete walls and slabs are provided in design vali-dation criteria (SAG.CP2 and SAG.CP10) on the basis of the American Concrete Institute (ACI) code.
If the slab or wall thickness is found to be inadequate, the design validation procedures require that the embedment not be considered as a multiple directian support.
In addition, a special study (Calculation "All relevant project and CPRT review documents are listad in Appendix B to this supplement.
Comanche Peak SSER 16 62 Appendix A
Book #151) was performed to address the capacity and support stiffness concern related to the grouted penetrations.
TENERA's review of design criteria (SAG.CP2 anJ SAG.*P10) confirmed that appro-priate requirements were specified to evaluate the acequacy of the grouted conduit penetration:.
In addition, TENERA's review of the special study (Calculation Book #151) verified that the capacity and stiffness effects of grouted penetrations have been adequately addressed.
Grouted penetrations for Train C were evaluated when used as a support for a Train C conduit run.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification pecgram.
The staff concludes that the use of appropriate criteria for evaluating grouted conduit penetrations and the establishment of the capacity and stiffness effects of the penetrations provide an adequate basic for resolving the concerns ider.tified in this issue and are acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
23.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with grouted penetrations have been adequately resolved.
The con-duit support technical issue concerning grouted penetrations, therefore, is closed for CPSES.
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i Comanche Peak SSER 16 63 Appendix A
24 RIGIDITY OF CA-TYPE SUPPORTS In its Independent Assessment Program, CYGNA raised concerns regarding the initial design calculations by Gibbs & Hill for CA-type supports related to the rigidity of the support.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 Book SUPT-1301 DAP-CLC-C/S-833 DAP-E-C/S-307 THE-C/S-CA-CA-la DAP-E-C/S-304 TNE-C/S-CA-CA-2b DAP-E-C/S-304 24.1 Rigidity of CA-Type Supports, The background of this issue is provided in Section 3.2.7.24 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A24, Section 2.0) (Reference A3).
The DAP evaluation is summarized in l
Section 3.2.7.24 of the results report.
To justify the use of zero period acceleration (ZPA) values in the design of CA-type supports, only the rigidity of the conduit spans was demonstrated.
The design calculations for the CD-type supports assumed that the supports were rigid.
To utilize ZPA values for design, the system (conduit and supports) must be shown to be dynamically rigid (generally having a frequency greater than 33 Hz for seismic loads).
Ebasco addressed the above concerns by requiring in its design validetion criteria (SAG.CP10) that all supports meet minimum frequencies specified therein unless a conduit / support system analysis is performed for the particular configuration.
CA-type supports are no longer required to be rigid i
but need to meet the specified frequency to permit the use of tabulated design l
g values.
Frequency calculations for the CA-type supports are containeo in calculations TNE-C/S-CA-CA-la and 2b.
The DAP review of design criteria (SAG.CP10) confirmed that the requirement to calculate minimum support frequencies is appropriately specified.
TENERA's review of calculations (TNE-C/S-CA-CA-la and THE-C/S-CA-CA-2b) for CA-type
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 64 Appendix A
Unistrut supports as well as the calculation (Book SUPT-1301) for CA-type supports fabricated from structural shapes confirmed that Ebasco is calculating support frequencies to ensure they meet the minimum frequency requirements.
Support stiffnesses are included in determining frequencies for Train C conduit systems. TENERA's review of the applicability of this issue to Train C found that the issue is. implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the requirements for supports meet specified minimum-frequencies and that the conduit system frequency to consider both conduit and support stiffnesses that is used for determining design acceleration values provide an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
24.2 Conclusion On the basis of the above evaluation, the staff concludes that the concern related to support flexibility has been adequately resolved.
The' conduit support technical issue concerning rigidity of CA-type. supports, therefore, is closed for CPSES.
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Comanche Peak SSER 16 65 Appendix A
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25 ENVELOPING CONFIGURATIONS FOR DESIGN In its Independent Assessment Program, CYGNA raised concerns that generic de--
sign calculations performed by Gibbs & Hill did not bound all conduit support configurations.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identified two related concerns from its review of various source documents.
In its conduit Trains A and B results report i
l (Reference A5), TENERA combined these into one primary issue.
l The relevant project documents and the corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
SAG.CP2 DAP-CLC-C/S-607 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP10 DAP-CLC-C/S-609 DAP-E-C/S-305 DAP-E-C/S-307 SAG.CP29 DAP-CLC-C/S-602 DAP-E-C/S-307 CP-SG-03 DAP-E-C/S-307 Book SUPT-1010 DAP-CLC-C/S-834 DAP-E-C/S-307 Book SUPT-1020 DAP-CLC-C/S-836 DAP-E-C/S-307 I
Book SUPT-1024 DAP-CLC-C/S-815 DAP-E-C/S-307 Book SUPT-1050 DAP-CLC-C/S-814 i
DAP-E-C/S-307 Book SUPT-1226 DAP-CLC-C/S-835 DAP-E-C/S-307 Book SUPT-1301 DAP-CLC-C/S-833 DAP-E-C/S-307 Book #10 DAP-CLC-C/S-828 DAP-E-C/S-307
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 66 Appendix A
I Project Document
- DAP Review Document
- Book #11 DAP-CLC-C/S-790 DAP-E-C/S-307 Sook #13 DAP-CLC-C/S-801 DAP-E-C/S-307 Book #23 DAP-CLC-C/S-800 DAP-E-C/S-307 Book #27 DAP-CLC-C/S-791 DAP-E-C/5-307 Book #30 DAP-CLC-C/S-803 DAP-E-C/S-307 Bo'ok #44 DAP-CLC-C/S-811 OAP-E-C/S-307 Book #48 DAP-CLC-C/S-792 DAP-E-C/S-307 Book #55 OAP-CLC-C/S-827 DAP-E-C/S-307 Book #57 OAP-CLC-C/S-828 DAP-E-C/S-307 Book #133 DAP-CLC-C/S-824 OAP-E-C/S-307 25.1 Use of Bounding Support Configurations The background of this issue is provided in Section 3.2.7.25 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status.xport (Subappen-a dix A25, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.25 of the results report.
Because generic supports have numerous design parameters and tolerances for installation, the design must account for these variations by evaluating the worst-case configuration permitted by the generic support drawing.
CYGNA identified several cases in Stich the most critical support configuration was not evaluated.
Furthermore, 1.ha analytical models that were used to check I
the assumed critical component also were used to check other components whose forces were not maximized in the selected design model.
In addition, Gibbs &
i Hill design calculations did not consider maximum load eccentricities, l
installation tolerances, ccmponent substitutions, or any other applicable variations.
Call relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 67 Appendix A i
Ebasco addressed these concerns by validating the designs of all generic con-duit supports, considering the most critical support configurations allowed by the revised drawings 2323-S-0910.
TENERA's review of Ebasco's criteria documents (SAG.CP2, SAG.CP10, SAG.CP29, and CP-SG-03) confirmed that adequate instructions have been specified to con-sider the variois design parameters and tolerances.
These requirements ensure that the worst-case configurations are validatrd for the generic supports.
TENERA's reviews of the generic calculations l'sted above confirmed that the Ebasco criteria were implemented correctly.
These generic calculations did consider the critical support configuration,.naximum load eccentricities, and installation tolerances.
Evaluations for Train C conduit systems are based on as-built walkdowns.
Qualification by walkdown is performed by ensuring that the support meets all the limitations provided in the project instructions.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that consideration of construction tolerances and the most critical support configurations in the design validation of generic conduit support designs provides an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
25.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns associated with critical support configurations have been adequately resolved.
The conduit support technical issue concerning enveloping configurations for design, therefore, is closed for CPSES.
Comanche Peak SSER 16 68 Appendix A es
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'l 26 DESIGN DRAWING DISCREPANCIES In its Independent Assessment Program, CYGNA raised several concerns when the design drawings and the corresponding design calculations for generic supports were compared.
The re' levant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
Book SUPT-1010 DAP-CLC-C/S-834 DAP-E-C/S-307 Book SUPT-1020 DAP-CLC-C/S-836 DAP-E-C/S-307 Book SUPT-1024 DAP-CLC-C/S-815 DAP-E-C/S-307 Book SUPT-1050 DAP-CLC-C/S-814 DAP-E-C/S-307 Book SUPT-1226 DAP-CLC-C/S-835 DAP-E-C/S-307 Book SUPT-1301 DAP-CLC-C/S-833 DAP-E-C/S-307 Book #10 DAP-CLC-C/S-828 DAP-E-C/S-307:
Book #11 DAP-CLC-C/S-790 DAP-E-C/S-307 Book #13 DAP-CLC-C/S-801 DAP-E-C/S-307 Book #23 DAP-CLC-C/S-800 DAP-E-C/S-307 Book #27 DAP-CLC-C/S-791 l
DAP-E-C/S-307 l
Book #30 DAP-CLC-C/S-803 DAP-E-C/S-307
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 69 Appendix A
Project Document
- DAP Review Document
- Book #44 DAP-CLC-C/S-811 DAP-E-C/S-307 Book #48 DAP-CLC-C/S-792 DAP-E-C/S-307 Book #55 DAP-CLC-C/S-827 DAP-E-C/S-307 Book #57 DAP-CLC-C/S-828 DAP-E-C/S-307 Book #133
.DAP-CLC-C/S-824 DAP-E-C/S-307 26.1 Discrepancies Between Generic Drawings and Analysis The background of this issue is provided in Section 3.2.7.26 uf the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A26, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.26 of the results report.
A number of discrepancies were noted between the generic conduit support drawings and the assumptions and models used in the Gibbs & Hill support cal-i culations.
Some of the discrepancies or inconsistencies noted in the design drawings included (1) base plate size missing, (2) clamp types not provided, (3) edge distance for the clamp bolts not specified, and (4) notes on draw-ings conflicting.
Ebasco addressed these concerns by performing an engineering walkdown for all of the conduits and supports to obtain the attributes required for design validation.
These attributes included support configuration, member identi-fication and size, dimensions, anchor bolt type and size, mounting surface, clamp type, and stud / bolt size.
Conduit and conduit support drawings were revised to reflect the as-built configurations obtained from the walkdowns.
The designs of the generic conduits and supports were validated utilizing the as-built data in drawings 2323-S-0910.
The designs of all modified and indi-vidually engineered (IN) supports were validated on the basis of as-built information, and new drawings were prepared for these supports.
l TENERA compared the generic calculations listed above with the generic cor.duit support drawings.
The drawings were found to be consistent with the designs l
calculations.
In addition, it was confirmed that the specific design drawing l
discrepancies raised by CYGNA for the specific supports have been addressed.
Since Impell's Train C conduit program is based on using the as-built config-urations, this issue is not applicable.
TENERA's review of the applicability
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 70 Appendix A
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1 1
of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that incorporating the as-built data into revised. conduit i
support drawings and the developing design calculations for generic conduit supports based.on those as-built drawings provide an adequate basis to resolve j
the concerns identified in this issue and are acceptable.
4 The CYGNA review of this. issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as-documented in Reference A7, i
26.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns regarding design drawing discrepancies have been adequately resolved.
The conduit support technical issue concerning design drawing discrepancies, there-l fore, is closed for CPSES.
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Comanche Peak SSER 16 71 Appendix A i
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27 WALKDOWN DISCREPANCIES As a result of CYGNA's walkdown of conduit supports in its Independent Assess-ment Program, a number of discrepancies were identified.
The CPRT third party (TENERA, L.P.), in conjunction with the Design Adequacy Program (DAP), identi-fled two related concerns from its review of various source documents.
In its conduit Trains A and B results report (Reference A5), TENERA categorized the discrepancies into the areas listed below.
(1) clamp installation (2) anchor bolt installation (3) installation of structural steci (4) installation of Unistrut (5) conduit / pipe interferences (6) conduit placement The celevant project documents and the corresponding DAP review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
Position paper on DAP-E-C/S-309 quality of construction of conduits and conduit supports (TV Electric)
CPE-EB-FVM-C/5-014 DAP-E-C/S-301 CPE-EB-FVM-C/S-033 DAP-E-C/S-30' 27.1 Clamp Installation The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
This concern deals vith the identification of clamp distortion and excessive gap between clamp ears and shim plate for some supports.
The Ebasco resolution methodology and staff evaluation for clamp distortion is addressed in Section 18.3 of tnis appendix.
The gaps between the clampt a..d shim plate were inspected in the Comanche Peak Response Team (CPRT) Quali6y of Construction (QOC) Program and were found to be acceptable.
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 72 Appendix A
TENERA's review of Ebasco's position paper, "Quality of Construction of Conduits and Conduit Supports," has confirmed that the issue related to clamp gaps has been adequately addressed by the CPRT Q0C Program.
Impell is performing as-built walkdowns and identifying construction defi-ciencies for Train C conduit systems.
Each identified deficiency is. qualified using the as-built configuration or modified to an acceptable configuration.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
L 27.2 Anchor Bolt Installation The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and 8 project status report (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
CYGNA found that Hilti expansion anchors identified in the field had been in-stalled with less than the minimum distance used in the design.
These anchor violations occurred in the spacing between anchors of adjacent supports.
Other anchor violations identified were concrete edge-distance violation, im-proper seating of Richmond inserts ::nd support angles, and differences between field installation of Hilti anchors and design drawings.
The resolution for spacing violations and construction installation discrepan-cies of anchor bolts and the staff evaluation will be addressed in conjunction with the staff's review of the civil / structural Corrective Action Program.
27.3 Installation of Struct ral Steel The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status repoat (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
In its Independent Assessment Program, CYGNA found that installation tolerances for structural steel members exceeded those specified on the design drawing for conduit supports.
In addition, the maximum size allowed on the design drawing for steel components was exceeoed in the field installation.
Ebasco addressed these concerns by performing an engineering walkdown to obtain l
as-built data to validate the design of the conduit surports.
TENERA's review of Ebasco's walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that adequate procedures and requirements were specified to identify the type, location, and size of structural steel components.
Comanche Peak SSER 16 73 Appendix A
1 For Train C conduit systems, Impell is performing as-built walkdowns and identifying construction deficiencies.
Each identified deficiency is either qualified using the as-built configuration or modified to an acceptable con-figuration.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that the as-built walkdowns performed to obtain the data regarding type, location, and size of structural steel components and its use in the design validation of conduit supports provide an adequate basis for resolving the concerns identified in this issue and are acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
27.4 Installation of Unistrut The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B resalts report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
A namber of discrepancies were identified in the installation of Unistrut components.
Unistrut nuts were not properly seated in the Unistrut channels.
Dif ferent members were substituted for Unistrut members specified on the t
design drawing. A support brace member was rotated about its axis from the orientation shown on the design drawing.
Unistrut connections and members were installed skewed and some connections had gaps that exceeded design drawing tolerances.
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Ebasco is addressing the seating of Unistrut nuts under the Post-Const10ction l
Hardware Validation Program (PCHVP).
The other discrepancies in installation of Unistrut components were addressed by the Ebasco engineering walkdowns, I
l which obtained as-built data to validate the design of conduit supports.
TENERA's review of Ebasco's walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that adequate procedures and requirements were specified to identify the member types, member orientation, and connection details.
Impell performed as-built walkdowns and identified construction deficiencies for Train C conduit systems.
Each identified deficiency was qualified using the as-built configuration or was modified to an acceptable configuration.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff cc.ic'udes that the design validation of the conduit supports, based on as-bui2t uJormation, provides an adequate basis for resolving the concerns related t the installation of Unistrut components (other than seating of Unistrut nuts) and is acceptable.
Comanche Peak SSER 16 74 Appendix A
l l
The CYGNA review of this issue and of the CAP resolution has resulted :n closure of all CYGNA conduit support issues as documented in Reference A7.
27.5 Conduit / Pipe Interference The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
In its Independent Assessment Program, CYGNA found that a number of pipes and conduits were in contact with other conduit supports.
The issue of commodity clearances is being addressed by the Stone & Webster Engineering Corporation in conjunction with the mechanical Corrective Action Program.
The staff evaluation is provided in conjunction with the staff's review of the mechanical Corrective Action Program.
Impell performed as-built walkdowns and identified construction deficiencies for Train C conduit systems.
Each identified deficiency was qualified using the as-built configuration or modified tc an acceptable configuration.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
27.6 Conduit Placement The background of this issue is provided in Section 3.2.7.27 of the conduit Trains A and B results report (Reference AS).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A27, Section 2.0) (Reference A3).
The DAP evaluation is summarized in Section 3.2.7.27 of the results report.
CYGNA found that the minimuc distance between flexible conduits attached to a support violated the spacing shown on the design drawing.
In addition, con-duits were installed skewed with respect to the tube steel supporting them although the design drawing shows the conduits to be perpendicular to the tube steel.
Ebasco addressed these concerns by performing an engineering walkdown to obtain as-built data to validate the design of the conduit supports.
TENERA's review of Ebasco's walkdown procedures (CPE-EB-FVM-C/S-014 and CPE-EB-FVM-C/S-033) confirmed that adequate procedures and requirements were specified to identify the location and routing of conduits and to identify their attachment location on the conduit support, Impell performed as-built walkdowns and identified construction deficiencies for Train C conduit systems.
Each identified deficiency was qualified using the as-built configuration or modified to an acceptable configuration.
TENERA's review of the applicability of this issue to Train C found that the issue is Comanche Peak SSER 16 75 Appendix A
implicitly captured by the adequacy review of the overall seismic quali'ication program.
The staff concludes that the design validation of conduit and supports, based on as-built information, provides;an adequate basis for resolving the concerns identified in this issue and is acceptable.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
27.7 Conclusion On the basis of the above evaluations, the staff concludes that the concerns associated with construction not matching design have been adequately resolved.
The conduit support technical issue concerning walkdown discrepancies, there-fore, is closed for CPSES.
l A
M Comanche Peak SSER 16 76 Appendix A i
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l 28 SYSTEMS CONCEPT Concerns were raised with Gibbs & Hill conduit support calculations that con-sidered the interaction between a conduit span and adjacent supports to reduce the loads on the support.
The relevant project documents and the corresponding Design Adequacy Program (DAP) review documents for this issue are listed below.
Project Document
- DAP Review Document *
(Ebasco)
Book SUPT-1301 DAP-CLC-C/S-833 DAP-E-C/S-307 Book #10 DAP-CLC-C/S-828 DAP-E-C/S-307 Book #13 DAP-CLC-C/S-801 DAP-E-C/S-307 Book #57 DAP-CLC-C/S-828 DAP-E-C/S-307 28.1 Design Interaction Between Conduit and Supports The background of this issue is provided in Section 3.2.7.28 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status report (Subappen-dix A28, Section 2.0) (Reference A3).
The OAP evaluation is summarized in Section 3.2.7.28 of the results report.
In its Independent Assessment Program, CYGNA found that for most supports in the drawings 2323-S-0910 package, the design evaluations by Gibbs & Hill represented the conduits as applied point loads.
The loads consiuted of the tributary conduit spans acting in each restrained direction on a particular support.
However, for the design evaluation of CA-Sa supports and the CSD-la detail (Z-clip), the interaction betwaen supports on a conduit run or between the support and the conduit was used to reduce loads on the support or connec-tion.
In the case of CA-Sa supports, the longitudinal load was assumed to be resisted by a load couple between the adjacent CA-Sa supports.
The rigidity of the conduit in transferring the longitudinal load into a tensile and com-pressive load on the adjacent supports was not demonstrated.
For the CSD-la detail, the calculations assumed that the presence of the conduit attachment to the support provided bracing for the support in the longitudinal direction, preventing rotation of the support and CS0-la detail.
The applicability of the assumptions made for supports using this detail were not demonstrated.
- All relevant project and CPRT review documents are listed in Appendix B to this supplement.
Comanche Peak SSER 16 77 Appendix A f
The specific Unistrut supports identified by CYGNA in this issue have been eliminated by Ebasco.
The system concept design approach was used by Ebasco only for surface mounted conduit supports with two-bolt anchnrs.
The load couple approach was not utilized in the design validation of conduits and supports.
The moments resulting from the eccentrically applied longitudinal loads were evaluated based on the stiffness of the system components.
The DAP reviewed sample calculations for Ebasco's surface-mounted conduit supports with two-bolt anchors (Books SUPT-1301, #10, #13, and #57) and con-firmed that issue has been adequately addressed.
The Gibbs & Hill calculations on the S-0910 supports (referenced above) have not been used by Impell on the Train C work; rather, Impell used a system con-cept on the Train C work to perform rigorous computer analyses of selected conduit systems.
Results from these system analyses provide additional justi-fication for some of the screening criteria.
Applicability of these criteria is strictly limited to support types considered by the system analyses.
Load eccentricity effects are considered in both testing and analyses.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualifica-tion program.
The staff concludes that an appropriate evaluation of moments resulting from eccentrically applied loads using the appropriate stiffnesses of the system components provides an adequate basis for resolving the concerns when a systems concept is used for design validation and is acceptable.
The CYGNA review of this issue and of the CAP resoiution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
28.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns identified in this issue have been adequately resolved.
The conduit support technical issue concerning rystems concept, therefore, is closed for CPSES.
l Comanche Peak SSER 16 78 Appendix A
29 CUMULATIVE EFFECT OF REVIEW ISSUES The additive effects of the various issues described in this appendix raised some concerns.
The CPRT third party (TENERA, L.P.) identified four related concerns from its review of various source documents and. combined them into one primary issue.
29.1 Cumulative Effect The background of this issue is prnvided in Section 3.2.7.29 of the conduit Trains A and B results report (Reference A5).
Ebasco's resolution methodology is presented in the conduit Trains A and B project status' report (Suhappen-dix A29, Section 2.0) (Reference A3).
The Design Adequacy Program (DAP) eval-uation is summarized in Section 3.2.7.29 of the results report.
It is recognized that the effect of some of the issues discussed in this appendix may not have a significant effect when considered separately.
However, the cumulative effect of more than one issue affecting a support may be significant.
Ebasco has addressed the above concerns by developing the design validation program for all conduits and conduit supports.
The design validation program has addressed each technical issue on conduit supports ar.d incorporated the resolutions collectively into the validation of the design of conduit supports.
For Train C conduit supports, this issue is inherently addressed by the com-prehensive engineering approach to the design verification and by the imple-mentation of extensive plant inspecti e, analysis, qualification, and test activities.
The conduit technical usues fall into three categories:
deviations between the as-designed and as-built conduit systems, analysis assumptions and methods, and design assumptions and methods.
The as-built versus as-designed issues are addressed cumulatively via the comprehensive qeilification by inspection procedure.
All accessible conduit supports have been inspected.
Inaccessible supports are evaluated for the worst effect in design verification.
In addition, this program has resolved instances of improper installation and poor construction quality.
All analytical issues (analysis assumptions and methods) and design issues (design criteria and assumptions) have been simultaneously addressed by the development of procedures and instructions, supported by studies, which have systematically considered each issue.
By virtue of the overall approach that has been imple-mented, the cumulative effect of these issues has been addressed directly.
In summary, the overall design verification approach has fully addressed and resolved each of the technical issues on conduits both individually and collec-tively and provided a complete field qualification of the conduit system designs including resolution of improper installation or construction.
This ensures that the margin of safety in the Train C conduit systems is acceptable.
TENERA's review of the applicability of this issue to Train C found that the issue is implicitly captured by the adequacy review of the overall seismic qualification program.
The staff concludes that Ebasco's design validation of conduit supports using as-built information and criteria verified throt.gh testing provides an adequate Comanche Peak SSER 16 79 Appendix A
basis for resolving the cumulative effects of the conduit support technical issues and is accept 00le.
The CYGNA review of this issue and of the CAP resolution has resulted in closure of all CYGNA conduit support issues as documented in Reference A7.
29.2 Conclusion On the basis of the above evaluation, the staff concludes that the concerns related to additive effects of multiple issues affecting a particular support have been adequately resolved.
The conduit support ~ technical issue concerning j
cumulative effect of review issues, therefore, is closed for CPSES.
i I
i Comanche Peak SSER 16 80 Appendir A
i
)
30 REFERENCES A1. 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.
A2. Ebasco Services Incorporatcd, "Generic Issues Report - Evaluation and Resolution of Generic Technical Issues for Conduits and Conduit Supports,"
Revision 2, Docket Nos. 50-445/446, March 30, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated May 19, 1987.
A3. TU Electric, "CPSES Unit 1 and Common Corrective Action Program - Project Status Report Conduit Supports Trains A and B, and Train C Larger Than 2 Inch Diameter," Revision 0, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TU Electric) to USNRC dated November 18, 1987.
A4. Impe11 Corporation, Report No. 01-0210-1523, "Generic Technical Issues Report - Evaluation and Resolution of CYGNA Train A and B Issues as Applicable to Train C Conduit Supports," Revision 0, October 22, 1986, Docket Nos. 50-445/446, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 4,1986.
A5. Comanche Peak Response Team, "Discipline Specific Results Report:
Civil /
Structural - Trains A and B Conduit and Supports," 0AP-RR-C/S-002, Revi-sion 1, Docket Nos. 50-445/446, November 4, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 18, 1987.
A6. Comanche Peak Response Team, Results Report ISAP I.c, "Train C Conduit and Supports," Revision 1, Docket Nos. 50-445/446, October 28, 1987, transmitted in a letter from W. G. Counsil (TV Electric) to USNRC dated November 9-1987.
A7. Letter from N. H. Williams (CYGNA) to W. G. Counsil (TV Electric),
Subject:
Conduit Support Review Issues, Comanche Peak Steam Electric Station, Independent Assessment Program - All Phases, Occket Nos.
50-445/446, June 15, 1988.
A8.U.S.NuclearRegulatoryCommission,RegulatoryGuide1.20,"SeismicDesign Classification.'
A9. U.S. Nuclear Regulatory Commission, "Methodology for Combining Dynamic Responses," Revision 1, USNRC NUREG-0484, May 1980.
A10. AISC, Manual of Steel Construction, Seventh Edition, 1970, American Institute of Steel Construction."
All. AISI, "Sp'ecification for the Design of Cold-Formed Steel Structural Members, American Iron and Steel Institute (1980).*
^Available through public technical libraries and at the NRC Library, 7920 Norfolk Avenue, Bethesda, MD.
Comanche Peak SSER 16 81 Appendix A
APPENDIX B LIST OF PROJECT AND CPRT DOCUMENTS FOR CONDUIT SUPPORTS Ebasco Documents Specification No. SAG.CP2, Unit 2 Design Criteria for Seismic. Category I Electrical Conduit System, Revs. 4, 5, 6, 7, and 9.
Specification No. SAG.CPIO, Unit 1 Design Criteria for Seismic Category I Electrical Conduit System, Revs. O, 2, 3, and 5.
Specification No SAG.CP12, Unit 2 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit Systems, Revs. O, 2, and 4.
Specification No. SAG.CP17, Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System, Revs. 1, 3, 5, and 7.
Technical Guidelines for System Analysis of Conduit Span Configurations, SAG.CP20, Revs. O and 4.
4 t
Technical Gui6elines for Thermal Analysis of Seismic Category I Electrical l
Conduit System, SAG.CP21, Rev. 3.
^
Technical Guidelines for Thermal Analysis of Seismic Category I Electrical Conduit Systems, SAG.CP22, Rev. 2.
l Technical Guidelines for seismic Category I Electrical Conduit Isometric Validation, Unit No. 1 and Common Areas, SAG.CP25, Rev. 1.
General Instructions for Design Verification of Electrical Conduit and Box Supports, Unit #1, SAG.CP29, Revs. O and 4.
Technical Guidelines for Seismic Category I Electrical Conduit ISO Validation, Unit 2, CP-SG-02, Rev. 2.
Guidelines for Design Validation of Seismic Category 1 Electrical Conduit and Box Supports, CP-SG-03, Rev. 1.
Position Paper on Quality of Construction of Conduits and Conduit Supports, Rev. O, dated October 16, 1987.
Paper on Effects of Bolt Hole Oversize in CTH and Conduit System Adequacy, i
Rev. 4.
CPSES Unit #1 Calculation Book SPAN-1116, LS-Straight Aux., Rev. PR.
l CPSES Unit #1 Calculation Book SPAN-1131, LS-DBL Bend Int., Rev. PR.
l i
Comanche Peak SSER 16 1
Appendix B
CPSES Unit #1 Calculation Book SPAN-1170, LS-Overhang w/ DBL Bend AB, Rev. O.
CPSES Unit #1 Calculation Book SPAN-1189, CYGNA Issue 17 - Substitution of Next Heavier Structural Member Size, Rev. 1.
CPSES Unit #1 Calculation Book SPAN-1199, Conduit Span Design Validation Using I
l Yield Stress F = 25 Ksi, Rev. O.
CPSES Unit #1 Calculation Book $ PAN-1200, Generic Study on Revised Clamp Allow-ables, Rev. O.
l l
CPSES Unit 1 Conduit Calculation Book SUPT-0246, Support Design Verification for CYGNA Issue No. 5, Rev. 1.
1 CPSES Unit #1 Calculation Book SUPT-0247, Substitution of Next Heavier Struc-1 turai Member, Rev. O.
CPSES Unit #1 Calculation Book SUPT-0253, Effects of Oversize Bolt Holes, l
Rev. 1.
1 CPSES Unit #1 Calculation Book SUPT-1010, CSM-18a, Rev. 1.
CPSES Unit #1 Calculation Book SUPT-1020, CSM-23, Rev. 0.
CPSE5 Unit #1 Calculation Book 3UPT-1024, CSM-27, Rev. O.
CPSES Unit #1 Calculation Book SUPT-1050, CSM-43, Rev. PR.
CPSES Unit #1 Calculation Book SUPT-1226, JS-36, Rev. O.
CPSES Unit #1 Calculation Book SUPT-1301, Support Type CA-3a & 3b, Rev. O.
CPSES Unit #1 Calculation Book THER-1760, Use of Unit #2 Calc. Books 84, 85, and 91 for Unit #1, Rev. O.
CPSES Unit #1 Calculation Book THER-1761, Study of Multiple Run Conduits on Single Support, Rev. O.
CPSES Unit #1 Calculation Book THER-1901, Thermal Analysis, Rev. O.
CPSES Unit #1 Calculation Book THER-1961, Conduit Support Stiffnesses, Rev. O.
CPSES Unit #1 Calculation Book THER-1981, Hand Calculations - Add Thermal, Seismic, and Deal Loads and Compare with Capacity, Rev. 1.
CPSES Unit #2 Calculation Book #10, CSM-2b, Rev. 1.
CP5ES Uni'. #2 Calculation Book #11, CSM-7b, Rev. O.
CPS S Unit #2 Calculation Book #13, CSM-2a-IV, Rev. O.
CPSES Unit #2 Calculation Book #23, CSM-12a, Rev. 0.
Comanche Peak SSER 16 2
Appendix B
CPSES Unit #2 Calculation Book #27, JS-la, Rev. 2.
CPSES Unit #2 Calculation Book #30, CSM-11b, Rev. 3.
CPSES Unit #2 Calculation Book #36, LS-10a, 10b, & 100, Rev. O.
CPSES Unit #2 Calculation Book #41, LS-6a, 6b, 6c, & 6d, Rev. 1.
CPSES Unit #2 Calculation Book #44, CSD Series, Rev. 1.
CPSES Unit #2 Calculation Book #48, JS-2b-II, Rev. 0.
CPSES Unit #2 Calculation Book #55,.m 3C-II, Rev. O.
CPSES Unit #2 Calculation Book #57, CSM-2b-IV, Rev. O.
CPSES Unit #2 Conduit Calculation Book #60, Study on Conduit Support Anchorage, Rev. 1.
CPSES Unit #2 Calculation Book #61, LS-2a, Rev. O.
CPSES Unit #2 Calculation Book #69, LLS-6a & 6b, Rev. 1.
CPSES Unit #2 Thermal Study calculation Book #81, Straight Run Conduit Graphs, System Stiffness Versus Thermal Loads, Rev. 1.
CPSES Unit #2 Thermal Study Calculation Book #82. Surface Mounted Conduits -
Graphs of Clamp Stiffness Versus Thermal Loads, Rev. 1.
CPSES Unit #2 Thermal Study Calculation Book #84, Comparison of Single and Double Bends versus Projected / Straight Runs, Rev. 0.
CPSES Unit #2 Thermal Calculation Book #85, Comparison of Variation in Span Lenghts and Support Stiffness for Straight Run Conduit, Rev. 1.
CPSES Unit #2 Thermal Calculation Book #86, Study of Multiple Run Conduits on Single Supports, Rev. O.
CPSES Unit #2 Thermal Study Calculation Book #87, Volumes I & II, Straight Run Conduit Combining Seismic Load with Thermal & Dead Load (Group IV), Rev. 1.
CPSES Unit #2 Thermal Calculation Book #91, Thermal Loads on One End Fixed Straight Run, Rev. O.
CPSES Unit #2 Thermal Study Calculation Book #92, Volume I, Rev. O and Vol-umes II & III, Rev. 1, Accident Thermal Analysis.
CPSES Unit #2 Thermal Study Calculation Book #94, Combining Loads for Surface Mounted Conduit, Rev. O.
CPSES Unit #2 Thermal Study Calculat Nn Book #111, Volumes 1-11, Junction Boxes Thermal Analysis, Rev. 0.
Comanche Peak SSER 16 3
Appendix B
CPSES Unit #2 Calculation Book #133, Vols.1-23, Anchor Bolt Interaction Ratio, Rev. O.
CPSES Unit #2 Conduit Calculation Book #145, Anchor Bolt substitution (G-3a),
Rev. 0.
CPSES Unit #2 Conduit Calculation Book #151, Concrete Embedment Forces and Allowables, Revs. 0 & 1.
CPSES Unit #2 Conduit Calculation Book #156, Effect of Oversize Hole on 2 Bolt Supports, Rev. 2.
CPSES Unit #2 Conduit Calculation Book #158, Calculations to Respond to Third Party Concerns, Rev. O.
Calculation No. TNE-CS-CA-CA-la, Capacities of Conduit Supports, Rev. 3.
Calculation No. THE-CS-CA-CA-2b, Design of Conduit Supports, Rev. 1.
Calculation No. THE-CS-CA-JA-1, Design of Conduit Supports, Rev. O.
Impell Documents Project Instruction 0210-052-004, "As-Built Waikdown," Rev. 1.
Project Instruction 0210-052-005, "Procedures for Implementing Screen Level 6," Rev. 3.
Report No. 01-0210-1527, "Justification of Damping Value," Rev. 2, Impell l
Corporation Walnut Creek, California, May 1988.
Report No. 01-0210-1483, "Hilti Kwik Bolt Concrete Expansion Anchors, Justifi-cation of Factor of Safety," Impell Corporation, Walnut Creek, California, July 1987.
Test Laboratory Documents CCL Report No. A-678-85, Seismic Qualification Test Report of Conduit Support Systems, Volume I and II, October 9, 1985.
CCL Report No. A-699-85, Coreo ci ap Test Report, Phase I, December 17, 1985.
CCL Report No. A-702-86, Co,,tU
.p Test Report, Phase II, April 7, 1986.
TV Electric Documents CPSES Design Basis Document, 080-C5-90, "Conduit and Conduit Supports Design Train A, B, and Greater than Two Inches Diameter Train C Conduit," Rev. 1.
CPSES Design Basis Document, DBD-CS-93, "Seismic Adequacy of Train C Conduits (Two Inch Diameter and Less)," Rev. 1, November 1987.
Comanche Peak SSER 16 4
Appendix B
CPE-EB-FVM-C/S-002, Field Verification Method, Design Control of Electrical Conduit Raceways, Unit 2, Rev. 4, July 6, 1987.
CPE-EB-FVM-C/S-Old, Field Verification Method, Design Control of Electrical Conduit Raceways for Unit 2 Installation in Unit 1 and Ccmmon Areas, Rev. 5, July 31, 1987.
CPE-EB-FVM-C/S-033, Field Verification Method, Design Control of Electrical Conduit Raceways for Unit 1 installation in linit 1 and Common Areas, Rev. 2, June 19, 1987.
DAP Review Documents DAP-CLC-C/S-602 Train A & B Conduit Support Procedure Review Checklist, August 6, 1987.
DAP-CLC-C/S-604 (Including Suppl. 1) Train A & B Conduit Support Procedure Review Checklist, August 6, 1987.
DAP-CLC-C/S-605 (Including Suppl. 1) Train A & B Conduit Support Procedure Review Checklist, August 6 and August 19, 1987.
DAP-CLC-C/S-606 (Including Suppl. 1 & 2) Train A & B Conduit Support Procedure Review Checklist, August 6 and August 19, 1987.
DAP-CLC-C/S-607 (Including Suppl. 1, 2 & 3) Train A & B Ccnduit Sepport Proce-dure Review Checklist, August 6 and October 16, 1987.
DAP-CLC-C/S-609 (Including Suppl. 1, 2, & 3) Train A & B Conduit Support Pro-cedure Review Checklist, August 6 and October 16, 1987.
DAP-CLC-C/5-790 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-791 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-792 Train A & B Conduit Support Calculation Review Checkl st i
August 19, 1987.
DAP-CLC-C/S-800 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-801 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/5-303 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/5-804 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
Comanche Peak SSER 16 5
Appendix B
DAP-CLC-C/S-805 Train A & B Conduit Support Calculation Review Chec'klist, August 19, 1987.
DAP-CLC-C/S-806 Train A & B Conduit. Sup p rt Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-807 Train A & B Conouit Support Calculation Review Checklist.
August 19, 1987.
DAP-CLC-C/S-810 Train A & C Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-811 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-812 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-814 Train A & B Conduit Support Calcuiation Review Checklist, August 19, 1987.
DAP-CLC-C/S-815 Train A & B Conduit Support Calculation Review Checklist,.
August 19, 1987.
DAP-CLC-C/S-816 Train A & B Conduit Support Calculation Review Checklist, Auglst 19, 1987.
DAP-CLC-C/5-819 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-820 Train A & B Conduit Support Calculation Review Checklist, 4
Augtist 19, 1987.
DAP-CLC-C/5-821 Train A & B Conduit Support Calculation Er ew Checklist, August 19, 1987.
DAP-CLC-C/S-822 Train A & B Conduit Support Calculation Review Checklist.
August 19, 1987.
0-CLC-C/S-32; Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/5-824 Train A & B Conduit Support Calculation Review Checklit,t.
August 19, 1987.
DAP-CLC-C/S-825 Train A & B L iuit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-827 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-C'.C-C/S-818 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
i.
Comanche Peak SSER 16 6
Apper..iix B
DAP-CLC-C/S-830 Train A & B Ccnduit Support Calculation Review Checklist.
August 19, 1987.
DAP-CLC-C/S-831 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987 DAP-CLC-C/S-833 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-834 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-835 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-836 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-837 Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/S-839 Train A & B conduit Support Calculation Review Checklist, August 19, 1987.
DAP-CLC-C/5-840 (Including Suppl. 1) Train A & B Conduit Support Calculation Review Checklist, August 19, 1987.
DAP-E-C/S-301, "Unit #1 Train A & B As-Builting Procedures," Rev.1.
DAP-E-C/S-302, "Unit #2 Train A & B As-Builting Procedures," Rev. 2.
DAP-E-C/S-304, "Unistrut Testing to Establish Unistrut Allowables for CPSES Unit #1," Rev. O.
DAP-E-C/S-305, "Thermal Effects on Conduit Systems," Rev.1, q
DAP-E-C/S-307, "Units 1 & 2 Train A/B Conduit Support Capacity Validation,"
Rev. 1.
DAP-E-C/S-308, "Evaluations of Conduit Clamp Te ts," Rev. O.
DAP-E-C/S-309, "Documentation of Quality of Construction for Train A & B Conduit and Conduit Supports," Rev. O.
DAP-E-C/S 310, "Evaluation of the Procedure for Train A & B Conduit Inaccessible Attributes," Rev. O.
DAP-E-C/S-311. "Evaluation of CPSES Train A & B Conduit Electricai Junction Boxes Design Validation," Rev. O.
DAP-E-C/S-313, "Span Allowable Studies," Rev. 1.
0AP-E-C/S-314, "Train A & B Conduit Isometric Drawing Design Validation,"
Rev. O.
Comanche Peak SSER 16 7
Appendix B
APPENDIX C CllRON0 LOGY OF NRC STAFF MEETINGS, AUDITS AND INSPECTIONS RELATED TO CONDUIT SUPPORT DLSIGN Event No.
Date Description 1
October 25, 1985 NRC staff audit at Ebasco offices, (New York, NY) of the cable tray-and conduit support activities 2
October 28-November 1, 1985 NRC staff inspection at TERA Corporation (Bethesda, ;40) of CPRT's Design Adequacy Program 3
November 8, 1985 NRC staff audit at Ebasco offices (New York, NY) of the cable tray and conduit support design criteria and procedures 4
Novemt er 12-13, 1985 NRC staff audit at TERA Corporation (Bethesda, MD) of CPRT's. Design Acequacy Program 5
February 14, 1986 NRC staff audit at Ebasco offices (New York, NY) of the Unit 1 and common conduit support program and Train C conduit program 6
March 24-27, 1986 NRC staff audit at CPSES site (Glen Rose, TX) of Unit 2 conduit supports 7
June 9-12, 1986 NRC staff audit at Inspell c,ffices (Walnut Creek, CA}-of the Train C conduit program methodology 8
April 21, 1987 Public meeting between CYGNA and TU Electric to discuss CYGNA open J
items related to conduit supports and other design disciplines 9
June 23, 1987 NRC staff witnessed conduit clamp tests at ANCO Engineers, Incorporated (Culver City, CA)
X Comanche Peak 5SER 16 1
Appendix C
//
l t
Event No.
Date Description 10 July 28-30, 1987 NRC staff audit at CDSES site (Glen Rose, TX) of the status of HVAC, piping, and Train C conduit programs under the Corrective Action Program i
11 August 6, 1987 NRC staff audit at CPSES site (Glen Rose, TX) of the status of cable tray hanger and conduit support activities under the TV Electric Corrective Action Program l'(
August 10-13, 1987 NRC staff audit at CPSES site (Glen Rose, TX) of the Train C conduit as-built verification program 13 September 8-10, 1987 NRC staff audit at CPSES site (Glen Rose, TX) of the Trains A and l
B as-built verification program 14 September 14, 1987 Public meeting between TU Electric j!
and NRC staff at Ebasco offices (New York, NY) to discuss the resolution to generic technical issues'for Trains A and B conduit supports 15 October 5-9, 1987 NRC staff audit at CPSES site (Glen Rose, TX) of CPRT third party review (TENERA) of Trains A and B conduit supports 16 October 5-9, 1987 NRC staff audit at CPSES site (Glen i
Rose, TX) of CPRT third party review (TENERA) of Train C conduit supports 17 November 2-6, 1987 NRC staff inspection at Ebasco offices (New York, NY) of the design t
criteria and methodologies used in the CAP design validation of' cable tray hangers, conduit supports, and-HVAC 18 December 7-11, 1987 NRC staff audit at CPSES site (Gian Rose, TX) of the application of design criteria and methodologies developed for Train C conduit 4
supports I
Comanche Peak SSER 16 2
Appendix C.
)
Event No.
Date Description 19 March 30-31, 1980 NRC staff followup inspection at-Ebasco offices (New York, NY) of cable tray hanger, conduit supports, and HVAC open items and root:causes:
of design issues' 20-May 23-26, 1988 NRC staff audit at CPSES site (Glen Rose, TX) of TAP audits on Train.C conduit support activities l
21 June 13-16, 1988 NRC staff audit at CPSES site (Glen Rose, TX) of the application of.
design criteria and analysis methods for conduit supports (Trains A and B) and TAP review of conduit supports l
1 l
l e
4 f
i
\\
I
)
r i
^
I
' Comanche Peak SSER 16' 3
Appendix C i
- l
-l
i l
APPENDIX 0 RESOLUTION OF OPEN ITEMS FROM NRC INSPECTION REPORTS D.1 NRC Inspection Reports 50-445/87-39,50-446/87-30 and 50-445/88-33,50-446/
88-29.
The five sections that follow provide th resolution of the remaining open items in the conduit support Trains A and B discipline which were identified in Inspection Reports 50-445/87-39, 50-446/87-30, dated February 9, 1988, and 50-445/88-33, 50-446/88-29, dated June 6, 1988.
These remaining open items were ultimately closed out during a staff audit conducted at CPSES site (Glen Rose, TX) on June 13-16, 1988.
The numbers of the open items correspond to the numbers used in the referenced inspection reports.
The Corrective Actior Program (CAP) response and NRC evaluation are given for each item.
D.1.1 Open Item CS-3.1-1 (Closed)
The basis for the seismic adequacy of flexible conduit and electrical cable air drops was requested.
CAP Response The seismic adequacy for flexible conauit and cable air drops were provided in two parts.
Two Imnell reports address the concern of insufficient slack:
Repor t No. 09-0210-104, Rev. A, "Project Report - Flexible Conduit Slack Eval-uation for CPSES," and Report No. 09-0210-78, Rev. A, "Project Report - Cable Slack Evaluation for CPSES." To address the seismic inertial load, Ebasco de-veloped a report entitled, "Seismic Qualification of Flexible Conduit," dated June 22, 1988.
The Impell report for flexible conduit slack presents the results of the engi-neering evaluation for flexible conduit slack in building shake space transitions and for ficxibie conduit in raceway-to-equipment transitions.
The engineering evaluation of flexible conduit slack was performed to assess whether the as-built flexible conduit transitions, which were installed in accordance with the design specifications, could accommodate end-coupling displacements.
To evaluate the adequacy of flexibl. conduit slack, a two part, tension mode and compression mode, multi-step analytical approach was developed.
This pro-cedura was applied to a sample population of transitions.
The results of this evaluation indicated that the flexible conduit slack provided for building-to-building transitions and for raceways-to-equipment transitions were sufficient to accommodate design-basis di: placements.
The Impell report for cable slack presents the results of the engineering eval-uation for electrical cable slack in air-dropped transitions.
The evaluation was performed to determine the acceptability of existing cable slack at CPSES comanche Peak SSER 16 1
Appendix D
k during a seismic event.
The rateway transitions are the electrical raceway where cables are "air-dropped" from one raceway component to another raceway component.
The raceway components considered are cable trays, conduits, equip-4 ment, and penetration sleeves.
The cable slack evaluation was performed on randomly selected transitions.
The directly measurable slack was compared to the imaosed three-dimensional seismic displacements.
If the measured slack was less tian the relative displacements, 2e tension developed in the cable was computed and compared to an allowable cable tension based on vendor-supplied data.
The cable transition was deemed qualified if the cable tension was within the allowable limits.
The results of the cable slack evaluation indicated that the existing cable slack at CPSES is acceptable. This conclusion was based on (1) the evaluation described above and (2) standard industry practice for cable installation which only requires meeting minimum bend radii and maximum cable pulling tension.
To address the seismic adequacy of flexible conduit under seismic inertia loads, the Ebasco report, ' Seismic Qualification of Flexible Conduit," extra-polated existing test data performed for other nuclear plants.
Comparisons wert. made of the conduit lengths tested, cable weight, and test response spectra to CPSES required response spectra.
The report concluded that the seismic qualification of CPSES flexible conduit was adequate.
1 HRC Evaluation The staff reviewed Impell Report Nos. 09-0210-104, Rev. A, and 09-0210-78, Rev. A.
These reports evaluate as-built flexible conduit slack and cable slack conditions, respectively, at CPSES.
Based on the analytical evaluation per-formed for the as-built transitions, conformance with industry installation standards, and experience data referenced in the Impell report, the staff concludes that the concerns relating to flexible conduit slack and cable slack under this open item have been adequately addressed.
The staff review and evaluation are further discussed in conjunction with the staff's review of the CAP equipment qualification workscope.
The staff reviewed the Ebasco report, "Seismic Qualification of Flexible Con-doit," dated June 21, 1988, and concurs with the approach and results.
- Thus, L
j the seismic adequacy of the flexible conduit has been adequately demonstrated, l
and the issue is considered closed.
D.1. 2 Open Item CS-3.4-1 (Closed)
In determining the loads acting on conduit clamps, Ebasco only considered the seismic inertial loads of the conduit and neglected the inertial load of the J
filler plate and clamp.
CAP Pesponse l
An evaluation was made to judge the effect of the seismic inertial loads result-ing from the filler plate and clamp.
This evaluation which was presented in Calculation Book SPAN-1204, showed that the effect of the filler plate and 1
a i
clamp weights on clamp capacities is minimal.
Comanche Peak SSER 16 2
Appendix 0
1 l
l NRC Evaluation The staff reviewed Calculation Book SPAN-1204 and concurs with the analysis which demonstrated that the effect of the filler plate and clamp weights is not significant and would not affect the design of clamp attachments.
There-fore, the CAP response adequately addresses the NRC concern relating to this item, and the issue is closed.
D.1.3 Open Item CS-3.4-2 (Closed)
Ebasco Calculation No. 0253 addressed the concern of oversized bolt holes for two bolted Hilti anchor connections.
This calculation, although conservative, resulted in factors of safety less than four for the anchors.
OP Response Ebasco revised Calculation No. 0253 (now Rev. 2) to reflect the use of a 5/3 interaction equation for 9xpansion anchors.
Previously, a linear interaction equation was used.
Ebasco indicated that this 5/3 exponent is permitted by DBD-C/S-15, Rev. 1, prepared by Stone & Webster Engineering Corp (SWEC).
The revised calculation shows that with the use of the non-linear interaction equation, the factors of safety are acceptable.
NRC Evaluation The staff reviewed Calculation No. 0253, Rev. 2, and confirmed that in using 6 5/3 exponent in the shear / tension interaction equation for expansion anchors, the factors of safety are acceptable.
The staff evaluation of the acceptability of the 5/3 exponent in the interaction equation for expansion anchors is ad-dressed in conjunction with the staff review of the civil / structural CAP.
The issue relating to the factors of safety for oversized bolt hole anchor connec-tions for conduit supports is considered closed.
D.1. 4 Open Item CS-3.4-4 (Closed)
The issue of bolt-hole oversize as it affects steel-to-steel connections has not been resolved.
In particular, the approach or methodology that would be used to address the oversized holes in steel-to-steel connections has not been determined.
CAP Response For generic supports, only CSM-23 contains steel-to-steel connections and its adequacy was demonstrated in Calculation SUPT-0253.
For IN supports containing steel-to-steel connections that are identified, the connections will be welded.
NRC Evaluation The welding of steel-to-steel connections for IN supports rather than relying on the bolted connections with oversized holes is acceptable to the staff, and the issue is closed.
Comanche Peak SSER 16 3
Appendix 0
0.1. 5 Open Item CS-3.7-1 (Closed)
During the review of the criteria / methodology of the Unistrut support qualifi-cation, it appeared that the calculation did not check for both cases of operating-basis earthquake (OBE) and safe-shutdown earthquake (SSC).
CAP Response All generic Unistrut support calculations will be reviewed to ensure that both OBE and SSE load combinations are evaluated or that SSE loads are used to com-pare against OBE allowables.
For modified or IN supports, the same approach described above will be utilized during the reconciliation phase of the design validation program.
NRC Evaluation The above item appears to be an isolated case and the CAP response adequately resolves the staff's concern.
The issue is considered closed.
I l
i i
l Comanche Peak SSER 16 4
Appendix C
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~NUREG-0797 Supplement No. 16 un iut ver,on o i.. ans 1
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Safety Evaluation Report related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2 j
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Supplement 16 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 prepa' ed 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 Fo;t Worth, Texas.
This supplement presents the staff's evaluation of the applicants' Corrective Action Program (CAP) related to the design of conduit supports. The scope and methodologies for the CAP workscopes as summarized in Revision 0 to the conduit support project status reports and as detailed in related documents referenced in this evaluation were developed to resolve various design issues raised by the Comanche Peak Response Team (CPRT), CYGNA Energy Services (CYGNA), and the NRC staff.
The NRC staff concludes that the CAP workscopes for conduit supports provides a comprehensive program for resolving the associated technical concerns identified by the CPRT, CYGNA, and the NRC staff and their implementation ensures that the design of conduit supports at CPSES satisfies the applicaole requirements of 10 CFR 50.
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