ML20196H956
| ML20196H956 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/10/1988 |
| From: | Arros J, Levin H, Streeter P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5805 OL, NUDOCS 8803140116 | |
| Download: ML20196H956 (29) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _
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00CMETED Filed:
March 10, 1988 0SNRC UNITED STATES OF AMERICA
,88 MM 10 P1 :20 NUCLEAR REGULATORY COMMISSION DOC fikGhhM(('
before the BRANCH g -
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report II.d In accordance with the Board's Memorandum: Proposed Memo-randum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan II.d,
\\
"Control Room Ceiling."
Opening Reauest:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
Three checklists were used during implementation of this Action Plan.
The first checklist (Attachment 1) was used in review of the Gibbs and Hill design of the control room ceiling.
8803140116 880310 PDR ADOCK 05000445 O
PDR 0
35
The second (Attachment 2) was used in review of the concrete slab above the control room ceiling.
The third (Attachment 3) was the Source / Interaction Evaluation Checklist, used as a limited-purpose checklist to aid in engineering evaluation of the original Damage Study program.
Question No. 1:
1.
Describe the problem areas addressed in the report.
prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it dis-cover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Response
An allegation was made that field run conduit, drywall, and lighting fixtures installed in the area above the ceiling panels in the control room were classified as non-seismic, were supported only by wires, and might fail as a result of a seismic event.
The TRT investigation generally supported the allegation but was more specific in identifying commodities with either inadequate or nonexistent seismic calculations.
As a result of the allegation, three problem areas were addressed in this Action plan.
The first was the control room ceiling.
An attempt was made to demonstrate that all portions of the control room ceiling, including those commodities attached to and above the ceiling, satisfied the provisions of Regulatory Guide 1.29.
Although a preliminary design assessment of the control room ceiling by the project concluded that the design complied with Regulatory Guide 1.29, this conclusion l
relied on the assumption that potential failures of i
2-I
architectural features with small masses would not be adverse to equipment in or occupants of the control room.
Rather than develop further confirmatory analysis to support the above posi-tion, the Project elected to remove and replace the original ceiling, which also completed the structural evaluation.
Subse-quent activities involved design and installation of a new ceil-ing by the Project and third-party review of the new design.
The second problem area addressed was non-safety-related conduit two inches or less in diameter in the control room.
The action was to demonstrate that the conduit satisfied the provi-sions of Regulatory Guide 1.29, which was referred to larger-scope actions involving such conduit, addressed in ISAP' I.c,
"Train C Conduit and Supports."
The third problem area addressed was applicability of the problems identified in the control room to other commodities in the plant that are not Seismic Category I.
Addressing this problem area resulted in an extension of the original Damage Study Program by the Project to include as potential sources all commodities identified as architectural features; i.e.,
items l
purchased under architectural specifications and specifically identified on architectural drawings.
This activity identified many potential seismic interactions, the resolution of which is ongoing and involves some hardware modifications.
The third-party review of the original Damage Study Pro-1 gram as well as the review of the extension o.f that program indicated that implementation was generally in conformance with
(
i 1 l l
l
procedures.
However, several areas of concern were identified involving the adequacy of the original Damase Study Program procedures, the adequacy of some of the supporting documentation as input to the pro-developed by other engineering disciplines gram, and the completeness of the program extension.
In all cases, procedure revisions or commitments to revise procedures have been made by the Project to address these concerns.
Sampling was used by the third party to investigate:
(1)
Project activities involving the original Damage Study Program.
process (Attachment 3 was used for this effort), (2) use of engineering judgment during that process to resolve potential interactions, and (3) the process by which architectural fea-tures were included for consideration in the Damage Study Pro-gram extension.
In each case, sampling was used to aid in the overview effort to identify potential concerns, not to identify the extent of known problem areas.
Sampling was used by the Project in two cases:
first, to the potential for unacceptable interactions caused by assess horizontal away for the more than 2,000 suspended light fixtures in Seismic Category I buildings and, second, as part of a test program to qualify existing handrail connections.
The problems with the original Damage Study Program arose l
because of inadequate Damage Study Prcgram procedures, less-l l
than-desirable experience among Damage Study Program personnel, l
and weakness in the design control elements of the engineerina program.
The Results Report includes additional discussion of :
problem areas, third-party investigations, and Project correc-tive actions.
QA/QC documentation was not explicitly reviewed for ade-quacy during ISAP II.d implementation.
However, where such documentation was involved, no observations of QA/QC procedural inadequacies were noted.
Question No. 2:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be inter-preted or applied.
Response
Attachments 4 and 5 are copies of the sections of the Engi-neering Evaluation Report, "ISAP II.d, Control Room Ceiling" (Reference 9.25 of the Results Report), that describe applica-17: 5n review checklist and the tion of the control room ceilire 4
concrete slab design review checklist, respectively.
Attachment 6 describes application of the Source / Interaction Evaluation checklist.
Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same at, tributes.
Response
The three checklists were developed and used by the third party specifically to investigate the process of the control room ceiling design and the original Damage Study Program.
Consequently, they did not duplicate any related QC inspection checklists, nor were they intended to do so.
-S-
Question No. 4:
Explain the extent to which the checklists contain fewer 4.
attributes than are required for conformance to codes to which Applicants are committed to conform.
Response
The three checklists contain the attributes necessary to assess the project's compliance with the applicable codes and FSAR commitments.
Question No. 5:
5.
(Answer Question 5 only if the answer to Question 4 is that the checklists do contain fewer attributes.)
Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded than are by using checklists that contain fewer attributes required for conformance to codes.
Response
This question is not applicable by reason of the response to question 4.
Question No. 6:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
No changes were made to the checklists while they were in use.
Question No. 7:
I 7.
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the train-ing has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
t I
l l --
Response
The control room ceiling and concrete slab checklists were prepared by the Issue Coordinator and used by an experienced engineer who worked closely with him.
Therefore, specific training in the use of these checklists was not required.
The Source / Interaction Evaluation checklist was used only by the Issue Coordinator, who prepared it.
As a consequence, a spe-cific training program to apply this checklist was also not necessary.
g_uestion No. 8:
8.
provide any information in Applicants' possession concern-ing the accuracy of use of the checklists (or the inter-observer reliability in using the checklists).
Were there any time periods in which checklists were used with questionable training or QA/QC supervision?
If applicable, are problems of inter-observer reliability addressed statistically?
Response
Because of the limited use and controlled application of the three checklists (i.e., only the individuals who prepared the checklist or the reviewer who worked in close coordination with the preparer applied them), establishing the accuracy of I
each checklist application was not considered necessary, nor was QA/QC supervision of any checklist applications.
Inter-observer l
reliability is not an issue.
l l
Question No. 9:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists.
Provide the factual basis for believing that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.
Response
No audits were performed regarding training or use of the checklists or the overall implementation of this action plan.
Question No. 10:
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected to (including by an employee, supervisor, or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the earlier drafts said and why they were modified.
Explain how dissenting views were resolved.
Response
No substantive modifications were made to the Results Report as a result of management action.
Question No. 11:
11.
Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached.
How were each of these un-expected difficulties resolved?
Response
Early in the investigation of the control room ceiling issue, the conclusion was reached that engineering evaluation and analysis could probably demonstrate the structural integrity of the ceiling, but it would involve modeling assumptions or test configurations for which published literature or regulatory communications were not available to support the assumptions and tests.
In view of the concern that this coul,d delay obtaining the technical consensus required to resolve the issue, a
l i
l 8-I
1 decision was made by the Project to replace the original design with one that could readily be qualified and to subject the design to third-party review.
Question No. 12:
12.
Explain any ambiguities or open items in the Results Report.
Response
Several ongoing TU Electric activities related to corree-tive actions have been established to meet commitments made to the third party in support of the Results Report conclusions.
These activities are associated with the original Damage Study itself and the extension to encompass architectural Program and each such activity is identified in Section 5.6 of
- features, the Results Report.
To the best of our knowledge, no ambigui-ties exist in the Results Report.
Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or super-visor was reviewing or evaluating his own work or supervis-ing any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Response
No actual er apparent conflicts of interect were associated with implementation of this Action Plan.
Investigatory activi-
\\
l ties not performed by third-party personnel were closely moni-tored by third-party personnel.
Question No. 14:
14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is ambiguous l
_g_
l l
or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
Response
The Issue Coordinatora and others who aided in the prepara-tion and approval of the Results Report have reviewed and checked the report for clarity and believe that it contains no ambiguities.
Respectfully submitted, R.
m
~
.~StrVefer Action Plan II.d Issue Coordinator
/h J.f K. Arros Action Plan II.d Issue Coordinator
/
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um
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H.
A.' Levin Review Team Leader The CPRT Review Team has reviewed the foregoing responses and concurs in them. l l
l
Pag 2 1 cf 7 IEAMS Conculation Comprweion/
She No, flending Tension Interoc ion Sheer Terseen AISC I 5.1.3 AISC AISC CAH Description Elevotion Drowing No.
SAB-171C AISC I.5.l.4 18.5.I.1 1.6.8 & I.6.2 1.5.8.2 (1)
W10s in mein freming M2'4" 2323-5-706-01 133-159 (Set 2)
=
=
m
=
=
I
-\\
47-54 (Set 4)
(centr I eroep
-k N/A y
a a
a a
W6s la mein frW 842'4 "
2323 5-706-01 63 4 9, 207-209, 310, 315-319, 324 O
Q north & south ends (Set 2)
-k 0
7 N/A N/A hA m
a x
2L3:2mS/I6 in leuwer 839'-4" 2323 5-706 07 4-),86-95,(Set 1) ceiling 2323 5-706-08 F
{
e m
a a
a a
U W6ml4 edge beem ell 83?' 4*
2323-5-706-07 8-l), 52, 53 67, 68 (Set I)
-l around louver ceiling N/A
=
m a
a Wlos la rnoin framing, 842'4 "
2323-5-706-01 191-193,358 (Set 2) 49-54 (Set 4) north & south oroos T5 2=2m3186 (lighting 841*-8" 2323-5-706-02 4-7 (Set 2) m
=
=
=
=
(Sheer fixture m,pport) due to torsion) x
=
=
=
m TS 5 2m3/16(eenergency 841*-8" 2323-5-706-02 8,53 55 (Set 2)
(Snoor lighting supper:)
due to torsion)
N/A N/A C6m6.2 & L 3m2 5/I6 839*-104" 2323-5-706-08 63-66(Set I) m a
a (1) Al5C,"Torsional Analysis of Steel Members" o
G TN-86 7145 (Beams)
Pcg2 2 cf 7 HAMERS Colculation Compression /
Sheet No.
Bending T.nsion lateraction sheer Tereien C&H AISC l.5.1.3 AISC AISC Description Elevation Drowing No.
S AB-17 t C Al5C l.5.l.4
/1.5.I.I 1.6.1 & l.6.2 1.5.1.2 (1)
L 3x3mt la trwss oil 839*-5" to 2323 5-706-07 15,49,54 (Set 1)
N/A a
N/A N/A N/A erowid & etwve the 841*4 -
Secticas 20-20 tevver ceiling 2I-21,22-22, 23-23,24-24.
1 l
W4=13 laterior hengers 337.4* to 2323-5-706-07
'l6,17,41,42 (5et I) m a
m N/A N/A
(
84 t
- 2323-5-706-08 Secs. 51 A-51 A,
& 518-518.
k D
Nr W6 20 and heepers oil 839* 4" to 2323-5-706-07 25,26,50,51,55 m
a a
N/A N/A around I.ovver Ceiling 841'-8*
Secs.20-20 (Set 1) 21-21 o
T e
b
{>
2323-5-706-08 E
Sec.57-57 2 L 3m3m3/16 (not back-642*4" to 2323-5-706-01 186,187 (Set 2) a a
a N/A N/A sm) 848* 2323-5-7 % -04 above mein framing Secs.1-1,2-2 3-3 2323-5-706-03 Secs. 8-8 to 12-12 2 L 3%=2%u5/16 (bock to-842*4 to 2323-5-706-03 I60, 168, 183-185, a
a a
N/A N/A beck) above main trening M 8*-7*
Sec. 4-4 to 7-7 208, 202, 214, 325,
& 13-13 to 326,331-333 (Set 2) 16-16 T5 2 2mL 842*-4" to 2323-5-706-03 264, 265, 277-282 m
a u
N/A N/A T5 3m3m% 3n nerth &
853*-l" Secs.4-4,5-5 321-325, 337-346, savth ends 6-6. 14-14, 157,358 I5et 2) 15-15, 16-16 (I) AISC,"Tors 4~1 Anotysis of Steel Mea.,ers" TN-86-7145 (Heupers)
Pcg2 3 cf 7 '
N Cesculation Congression/
Sheet No.
Rendirg Tenelen lateraction Sheer Tereien C&H AISC l.5.1.3 AISC AISC Descripelen Elevation Drowing No.
SAS-lH C AISC 1.5.1.4
/s.5.I.I 1.6.1 & I.6.2 1.5.1.2 (l) 2 L 3m2 5/16 In plane of 842' 4 "
2323-5-706-01 168-173 (Set 2)
=
a a
a a
(Sheer enoin freming dueto)
M forslan)
-(
L 3m3ml/4 in N-5 trvsses 83?'-5* to 2323-5-706-07 14,47,49,54 (Set I)
N/A u
N/A N/A N/A d&
Q east & west side of the 84 t *-8" Secs 20-20, J
lovver ceiling 21-21, 22 22, 0
23-23
-b 3
N/A N/A g
C 2 L 3%m2%m5/16 inE w 842'4 to 2323-5 706-03 162 867, 174,175, a
a a
a trusses 848'-7* or seen. 7 7 to 198-190 (Set 2)
[
852'-10' 13-13 4
2 L 3n=2nm5/86 in N-5 842'4 to 2323-5-706-04 176-178 (Set 2) a a
a N/A N/A trusses, secs. I-I to 3-3 848*-7*
2 L 6m4m3/8 in N-5 truss, 842'4'to 2323 5 706-04 177-182 (Set 2) m a
u N/A N/A Section 3-3 852*-10*
Sec.3-3 N/A N/A T5 3m3=% in E w teveses 842'4" to 2323-5-706-03 261-263,256-276, a
a a
@ north & south ends 848*-7*or Sees.4 6,5-5, 118-326, 147-350 852'-10" 6 4, 14-14 (Set 2) 15-15, 16-16 (1) AISC,"Terstonel Analysis of Steel Members
- TN-86-7145 (Broces)
Pag? 4 Cf 7 CODGEN Gunnet Plate Bolts Colevlotion Tension Shear Beading Tenste Sheer Prying Welds Sheet No.
A6C A6C A6C A6C A6C A6C C&H Description 1.5.1.1 I.S.I.2 1.5.l.4 1.5.2 f.6.3 Botta riege I.5.3 SAB-171C Dre-iag No.
2 L 3m2=5/I6 elurninurn a
N/A a
a a
N/A N/A
=
21,41,42 2323-5-706-08 lovver suppert (Set 1)
Seca. 5I A-51 A, 518-518, SIC-5IC, SID-51D D
W4ml3 heger to leuwer a
N/A u
N/A N/A N/A N/A
=
41,42 (Set I) 2323-5-706-(2
.l cdling (complete 5eca. 51 A-51 A,
,[
penetration) 538-518, 51 C-51C,
)
SID-51D g
W4ml3 heger to main N/A N/A N/A a
a a
a
=
17-19, 42 2323-5-706-08 T
tteel frame (Set I)
Sees. $1 A-51 A, J
518-518 0 (n om h{
i Conwwction Plose
~{
W6s20 heger to Wsul6 m
a a
N/A a
N/A N/A a
22-24 57 2323.5-706-08 in lovver ceiling (Seti Section 57-57 W6=20 henger to ensin N/A N/A
=
=
=
m a
n 26-28,43,56, 2323-5-706-08 steel frorne u (Set I)
Section 57-57 Diogenel W6ml6 to a
N/A N/A N/A a
N/A N/A
=
68 (Set 1) 2323-5-706-08 W6ml6 in north & south AISC Detoit 52 & 52A ends af h ceiling P.4.4 Wh and flonge plates SpInce of W6ml6 in a
a N/A N/A m
N/A N/A a
57-62 (Set 1) 2323.5 706 08 lovver ceiling AISC Spilce detoll for P.4-4 W6ml6 TN-86-7145 (Connections, p. l}
Page $ cf 7 COpeECTIOp6 (CeneJ Carsnet Plote Bolt Celeviction i
Tenelen Sheer Bending Tension Sheer Prying W elds Sheet No.
AISC AtSC AISC AISC AISC AISC C&H Deerwistion 1.5.l.8 1.5.I.7 1.5.l.4 1.5.2 8.6.3 Seite Flege 1.5.3 5AB-178 C Drawing No.
L 3m3=E brace and heng-Note i Note i N/A Note i Note i N/A N/A N/A I4-15 (Set 1) 2323-5-706-05 era in truss oil around Typ. bracing lowwer ceiling conn.
Sent plate to concrete N/A N/A m
a a
N/A N/A
=
29-31 (Set I) 2323-5-706-07 &
b 55-30 55-30 08 (Sect. 25 25) 286-228,3C9 2323-5-706-01 W10 to W10 in enoin a
m N/A a
a a
a m
frerne Splice or continuity plate Bending of (Set 2)
Sec. A-A & B-8 p
@ north and sasth ends of cilp ongle typ. & elter-centrol moln f tome note conn. detell O
(W10 to W10) 7 e
M[
N/A N/A
=
381 (Set 2) 2323 5-706-01 WIO to W6 in enoin a
a N/A N/A m
frarne Section C-C W10 *o sirewed W6 in N/A N/A N/A a
m N/A N/A N/A 238-243 2323-5-706-02
{
rnein frorne (Set 2)
Detail 20
\\
T5 2=2=3/I6 te WlO N/A N/A N/A
=
=
m a
m 49-52 2323-5-706-02
/
305 (Set 2)
TS 542m3/16 to Wlo N/A N/A N/A m
a a
a m
56-60(Set 21 2323-5-706-02 Braces ed hegers to a
N/A N/A a
a M!A N/A m
80,320 (Set 2) 2323-5-706 09 WT 12:58.5 @ onchor.
AISC Sec.IA-lA, oge points P.4 -6 IB-IB Note la Loads are small, connection not molyred.
e TN-86-7145 (Cormections, p. 2)
Page 6 of 7 COPeECTION5 (CameJ Cosset Plate Bolts g g,,
Tenelen Shear Bending Tene;on Snear Prying Welds 5.*w+t No.
AISC AISC AISC Al5C AISC AISC C&H Description 1.5.1.1 f.5.1.2 8.5.I.4 1.5.2 0.6.3 Bolts Flange 1.5.3 SAB-178 C Drewing Na, WT 82=58.5 tobene N/A N/A N/A a
a a
a m
76-80 (Set 2) 2323-5 706-09 plete en shie of conc.
beern Sec.1 A-I A, IB-IB Type I enchorage a
a a
a
=
a a
m 74-75 3M 2323-5-706-09 (Web Sheer Spec 55.30 Spec 55-30 (Set 25 Sec.IA-8A, M
in WT 12)
(Hitti)
(Hilti) 18 18 Web & Fhmge Plotes
,{
Splice of W10 22 in a
a N/A a
a N/A N/A N/A 211-213 2323-5 706-01 vnoin frame AISC (Set 2)
Typicol splice
.j i
P.4 4 detoll q
2 L 3%=2%m5/16 horizon-m N/A N/A a
a N/A N/A
=
320 (Set 2) 2323-5 706-04 pJ tot bracing in mein frame v
,7 so
? Type 3 erwforage a
N/A e
a a
a N/A m
104-121, 301, 2323-5 706-09 0
f)
Spec $5-30 Rev I 327, 335, 354 y
(Hilti)
(Set 2)
Type 3A ewserege a
N/A a
a a
a N/A 122,302, 2323-5-706-09 a
Spec 55-30 Rev i 335 (Set 2)
Type 4 & 4A emchorage m
N/A a
a a
a N/A m
126,335 2323-5 706-09 Spec 55-30 Rev i (Set 2)
Type 5 or 58 erchoroge a
N/A m
a a
a N/A a
127,303,3M, 2323-5-706-09 Spec 55-30 Rev i 356 (Sat 2)
Type 2,2A & 28 m
N/A a
a a
a N/A 223 233, 258-2323-5 706-09 a
Wege Spec 55-30 Rev I 260,334 (Set 2)
T5 hemger or brace in a
a a
a m
N/A N/A 283, 284 2323-5 706-03 a
l end sectiom
& bending (Set 2) of bolt a
TN-86-7145 (Connections, p. 3)
Pcga 7 cf 7 CECKLIST OF REEVALUATION OF C(NCf(E IE FLOOlt AT LL. 854'4" l
u Y
Sifl ACI )AR Dh 11 4 CAL.Ct A. ATION=
Un BEAM NO.
DEAMS ANALYZED AS:
OlN HilG 1 1.(>, 1 1.14 PAGE NO.
b.
W8
.(
s.
65,83 T-Ocam X
X 6,7,42
_l j
68,79 T-Beam X
X 7, 8, 24, 53-55 Ti p
Y 71,77 T-Scom X
X 9, 30-32 f
74 T-Beo.n X
X 10,36 s
n I",
62,86 T-8eam X
X 5, 6, 47
{
7
.7 49 - 52, Rectangular 61 - 63 E$
55,56 Beam I
p Slob of Rectongular 58 - 60 El. 854'-4" Beam y
y 1
- Colculation No. 5AB-171C Set 3, Rev. I I ACI 318-71
]
4 h
1
\\ ok ?b Source / Interaction Evaluation Checklist I. Source Identification source description:
I.1 Brief Sources Room:
Bldg:
the physical Approa Elevt source identification match the documented I.2 Does situation?
in conformance with the scope of
!.O Has the source been selected the DSP procedures?
of pipe, equipment (length in conformance with DSP the source Are the "boundarles" ofconnections, etc.)
specific in this I.4 structural not general mountings, Or where the procedures arewith respect to procedures?
reasonable boundaries are
- regard, engineering principles?
Identification II. Interaction the potential interaction region conformance "boundaries" of "f alling" distance)where the procedures in Are the 11.1 ver ti c al / hor i z ont alfailure "envelopes"* Or reasonable (e.g..
tnis regard, are the coundarles with DSP procedures' are not specific in engineering princ1ples?
with respect to general 11.2 Is any interaction documented?
match the does this documented, within the targets as interaction there no i.e..
are and documentation 21.0 If no region per the scope physical situation, potential interaction the DSP procedures" requirements of provide brief descriptions is documented,
!!.4 If an interaction match the description documented interaction
!!.5 Does the phys 1 cal si tuat i on*
in conf,ormance with the scope identified been II.6 Has the target the DSP procedures" of 24A002
A t r a c_ m e. x,
3 2,
o [
3 Source / Interaction Evaluation Checklist (continued)
III. Interacti on Resolution III.1 What method of resolution was used for the interaction?
(proceed as appropri ate to A.
B.
C. or D below)
III.A Use of FMEA to Resolve III.A.1 Were all SSE-concurrent plant conditions appropriately considered?
III.A.2 Are the target's (system / component) functional requirements completely defined?
III.A.0 Is the assessment of the target's (system / component) failure modes and consequential effects complete and reasonable?
III.A.4 Is documentatlon (i.e.,
assumptions, references, conclusions) complete?
III.B Use of Calculations to Resolve III.B.1 Does calculation input (d i mensi on s,
distances,
- weights, etc.)
adequately describe the physical situation?
III.B.2 Have appropriate seismic spectra and/or acceleration levels been used with respect to
- locatlon, direction, and damping?
111.B.O Are the calculation methods used c onsi st ent with FSAR commi tments f or similar items which are SCI? Or are the methods otherwise consistent with accepted engineering principles / practice?
III.B.4 Do the calculation results ade quat el y resolve the interaction'
!!I.B.5 15 the calculation prepared in accordance with appropriate CPSES procedures?
And is the resolution otherwise adequately documented?
III.C Use of Physical Modifications to Resolve III.C.1 Briefly describe modification designs III.C.: Has justification been provided in the form of a
new
(
calculation er reference to e::1 st i ng c al c ul a t i on s that the modification will preclude the need to postul ate the interaction under consideratt on?
f I
24A003
3 Q-r r A ce E. N7 15 of
'5>
(continued)
Source / Interaction Evaluation Checklistbeen prepared specifically has c al cul ati on III.C.T. Where a new III.B above.
review per for the interaction, been made to existing calculations,in question' has III.C.4 Where referencecalculations applicable to the interaction III.B above.
Where necessary, review the calculations per are such 15 the is performed or referenced. of the to preclude post ul ati on III.C.5 Where no calculation sufficient modification Provide rationale.
interaction?
Is the resolution adequately documented?
III.C.6 III.D Other Resolution Methods resolution:
describe method of III.D.1 Briefly he interaction?
III.D 2 Does the method adequately resolve t t d?
III.D.; Is the resolution adequately documen e Resolution Follow-up IV.
as appropri ate)
B below (Proceed to A or Modification IV. A Resolution without Physical action by requiring resolutions interaction adequate to "close is documentation IV.A.1 For those groups other than the DSG, the interaction
- out" IV.B Resolution with Physical Modification requiring action by resolutions int 9raction adequate to "close is documentation IV.B.1 For those groups other than the D5G, the interaction?
match what wAs Out" adequately modification IV.B.O Does the actual (ref er to !!1.C above) intended?
Program Maintenance of the V.
identification to initial surveillance to the adequate source / interaction.
conclusions and/or resolution are still Subsequent has there been V.1 insure that the initial I
(refer valid?
this surveillance?
V.7. Is there adequate documentett on of to Ref C43) 24A004
h i T (A c um c fu'T 4
4.0 EVALUATION PROCESS AND EXTENT OF REVIEW The process of evaluating the design of the control room ceiling structure was initiated by reviewing the design procedure (DP 3) prepared by Gibbs & Hill specifically for the design of the control room ceiling steel frame, followed by the review of all existing Gibbs & Hill design calculations pertinent to this subject.
All hand calculations performed were reviewed line-by-line for methodology and for compliance with the acceptance criteria of Section 5.0.
Input for the equivalent static computer analysis (STRUDL program) was checked line-by-line for consistency with the Gibbs & Hill design drawings identified in Table 1.
The items checked included geometry input, material properties, section properties, load
- input, and member end conditions. The computer analyses for the response spectrum analyses (NASTRAN program) were spot checked for inputs and reasonableness of results. The hand calculation for the analyses of the concrete structure at elevation 854' 4' was reviewed line by-line.
Numerous questions or discrepancies as documented in Attachment I were identified in the initial review by TERA.
These were transmitted to Gibbs & Hill for resolution or clarification.
The concerns that could not be resolved were documented in DIR D 2252.
Gibbs & Hill responded to this DIR by revising the calculations or generating new calculations to resolve the discrepancies.
The review and evaluation of the design calculations based on equivalent static analysis was documented on checklists prepared for the this purpose.
These checklists identify the appropriate acceptance criteria fcr the ceiling components and connections, and provide a mechanism for assuring that the criteria have been addressed and met.
The checklists are included in Appendix 1.
A x in a column indicates that the criteria was addressed and met.
'P l -17 T A c_ H M E_.A.,-T
\\
ok
\\
.~
6.2 Calculations and Computer Analyses for the Equivalent Static Analysis 19 the review of the original calculations and computer analyses questions were raised by TERA.
Some of the ques-tions required only a clarification, whereas in other cases, in the questions resulted in identification of discrepancies the calculations and in the computer model Documentation of the comunication between TERA and Gibbs & Hill is included in Attachment 1.
The identified discrepancies were documented on the DIR D 2252.
Subsequently the discrepancies were resolved and corrected by Gibbs & Hill in new revisions of drawings and calculations.
ThJ following discussions reflect the Gibbs & Hill analyses as presented in the calculations listed in Table 2.
The equivalent static analyses are performed in two parts:
(1) the main frame by computer analyses (STRUDL program; Calculations SAB-171 C Set 2; SAB 171 P), and (2) the portion below main horizontal frame, i.e.,
the lower frame with the hangers by hand calculations (SAB 171 C,
Set 1).
Occumentation of the review of these equivalent static analyses are contained in the checklists of Appendix 1.
These checklists list on their vertical axis the components and connections of the ceiling frame and on their horizontal
(
axis the applicable acceptance criteria for which the l
A cross mark (x) indicates that the components were checked.
applicable criterion is met.
l
b h 77 A C \\4 MC. M 7
\\
of?
?
O 2.4 DSP Implementation 2.4,1 Evaluation Objective The primar y objective of this evaluation was to assess the overall implementation of the D5P. A secondary objective wes an extension of this assessment for those particul ar interactions (Ref C63).
Impact Criteria were resolved using the Dynamicf rom the criteria evaluation of 2.0.
that This second effort resulted 2.4.2 Evaluation Process described below specifically addressed The evaluations the f ollowing procedures and criteri a:
implementation of Seismic /Non-Seismic Component Interaction "Con t r ol of Evaluations" (Ref C;])
"Maintenance of Damage Study Analyses" (Ref C43)
Iculations and Failure Mode &
"Design Control of r.o M A's) for Damage Study" (Ref C53)
Effects Analysts (Ref C63)
Interaction Criteria" "Comanche Peak Seismic w1th the above to the DSP documentation associatedcalculations were In additton di sci pl i ne-spec i f i c interact 2on several procedures, calculations f ormed the basis f or re,1ewed where such resolution.
2.4.2.1 Overall DSP Seismic /Non-Seismic Impitoentation presented On the basis of the summary of interact 1on resolutt ons architectural features since in Fef C243 (which didn't includeto initiation of ISAP II.d),
a witn and without was prepared prior the summary l i mi t ed number of source commcdnttes, Table 2.4-1.
interectlens, were selected in accordance with evaluation l
(interaction matrices s the DSG with The e>:isting DSP document ationthese commodities were provided by forms. etc.)
for be selected as much as the sources the only provision being that Additional document at t ori rooms or areas.
on site possible from different other discipline groups Each was provided as necessary by modificationse.
calculations, designs f or physical checklist to assure evaluated against's standard efforts and (e.g.,
implementation was pac 6 ace A
blani of the adequate consistencyDSP seismic /non-seismic procedures.
competibility with the beginning of Append 11t 2.4A.
chec6:11st is included at 2.4.2.2 Ure of Dynamic Impact Criteria were On the b a s t '4 of the total number of interactions that was selected a sample of interactions of all DIC resolved using the DIC.
0.4C contains a listing (see Appendix 2.4D). Appendix 045 1
p,, n c a ma s, G
bo b
i i
Interactions along with interaction matrices f or each of the selected interactions.
Each of the selected interactions was independently resolved by quantitative means based on engineering principles.
It was not intended that thi s ef f ort specifically evaluate whether the appropriate DIC (of the nine given) was selected to resolve an interaction.
- Instead, each of the selected interactions was quantitatively assessed so as to measure the acceptability of interaction resolution whenever any of the qualitative DIC was employed.
2.4.3 Acceptance Criteria 2.4.3.1 DSP Implementation Acceptab111tv of DSF implementation was based on reasonable checklist responses for each of the sources and/or interactions evaluated.
Because the FSAR (Ref CO3) doesn't generally include criteria specific enough for the level of methodology reviewed
- here, comparisons were primarily to accepted engineering principles.
Where it was clearly and1cated in available documentation that SCI criteria were applied, such was considered acceptable without further review.
2.4.3.2 Dynamic Impact Criteria Acceptability of the DIC was based on satisfactory conclusions being reached for each of the selected interactions.
Thas involved performing independent c al c ul at i on s to verify the D5G evaluation results.
The calculations were not intendeo to insure strict compliance with FSAR criteria for seismic category 1 Items but rather to provide reasonable assurance either that source f ailure would not occur or that if it did. target function woulo not be impaired.
2.4.4 Evaluation 2.4.4.1 DSP Impl ement ati on Based on physical waltdowns and review of documentation.
evaluation chccklists were completed for twenty-two (22) sources
(
l for which there were fourteen (14)
Identified interactions.
l Completed checklists are included in Appendix 2.4A. Also includeo are photographs where such would facilitate a
better physical understanding of the sources / interactions.
The checLitsts are sequential by room number.
In each
- case, copies of the associated completed interaction matrix and interaction evaluation L resolution form (If applicable) are included.
1 i
One area common to all items evaluated involved program maintenance to insure that interaction evaluation results remained
/al a d during and after subsequent construct 1on activities.
Initially, such activities were carried out bv visual inspections as per paragraph 0.3.5.5 of Ref (43.
Third party revi ew of visual inspection fccms attached to Ref CT43 046
h "i~' T' A C H f-i C.tW T b
3 od b
o t'
indicated that this approach was used until about mid-1984 (Jur e to August period).
Review also indicated that by this time.
there were very few changes being made that were affecting DS#
results.
Accor dinalv, the maintenance ef+ ort changed from complete phvsical inspections to a review of change documentation (e.g., DCA'st to determine whether there was a need for physical inspection.
This paper review was done an accordance with Ref
[953. The methods described were considered adequate by the tnied party to insure tnat potential changes to DSP results were appropriately identified.
Documentation of the results et that process were also considered adequate by the third party.
The cra teria review of 0.3.4.10 addressed the acceptability of target definition and indicated that the DSP implementation evaluation would provide further substantiation of target definition adequacy.
As indicated above, fourteen interactions were r ev i ewed as part of this effort.
In all
- cases, DSF-identif i ed targets were conf i rmed by the third party.
For the eight source commodities without DSP-identifled interactions, the third party confirmed thtt there were no targets within potential interaction zones.
The criteria review of 0.3.4.OE specifically addressed the use of intervening barriers during the interaction identification process.
It was noted that this would need to be assessed during the CIA portion of this evaluation.
- However, it was also
+
addressed here (at least in pert).
Three cases are discussed below (speci fic details can be f ound in Append 1:, 0.4A):
Room 93 -- It was noted in the checillst response in II.3 that the onis interactions were with wal l s and the floor although these were not ident141ed during the DSG walldowns.
Wi thout the surround 1 ng walls, the ladder 116ely would be the source for other potential interections.
However, none were identified because judgement was spplied at the time of the DSG wall downs to the extent that such interacti ons were not considered credible.
The third party concur s wi th this judgemert.
It was noted in the chectlist respsnse in 11.7 Room 151 that a large motor control center was in close proximi ts to a safetv-related target (emergency 11ohtino condutti but that thi s was r.ot identified as a
potent i al interaction.
l This was a cas:-e where JudQement was used during the D50 i
wall down J a it was considered by the third party to have been appropriately applied.
r It was noted i n the checkli st response in II.4 Room 205 that an interaction was postulated with a nearby condult.
Revi ew of the associated i nter act i on matr1 >: also shows that one other interaction was postulated with the val ve oper ator l
to which the conduit is attached.
Physical inspection clso showed at macht be pos sibl e to Dostul ate Interactions. wi th J
the adjacent ASME chemical additive tani and/or ettached 047
(
i
N77ACHMEN7 Oh o
piping (see photo).
However, a JudQement was made at the tame of the DSG wal l. downs. that the platf orm to which the ladder attached would provide sufficient capacity es a
bser t er to preclude such interactions.
As
- such, no interactions were postul ated between the ladder and the tani/ptping.
The third party concurs that this was a
reasonable judgement.
The barriers described above are of the first group di scussed in 0.0.4.
E. As was ind1cated there, the third party concludes that such applications of judgement were practical necessities an order for the DSP to focus on those interactions that are of significance.
The criteria review of 0.0.4.0B andicated that use of FMEA would review.
Two of the be assessed during the DSP 1mplementation interactions ine.luded in this review were resolved on the basis of FMEA (ref er to the completed checklists for rooms 160 and 189 in Append 12: 2.4A).
Third party review andicated that acceptable methodolcoy hhd been used but that the FMEA calcul ations were not bened on the current (at the time of third party revtew) FSAR.
Because of tSis, the Project commited to updating periodically the FMEA r;al c ul ati ons to assure that FSAR changes are incorporated as necessary.
This commitment was included in Ref C1163 and has also been incorporated into the new SIP proceduren.
lne crit aria re view of 0.0.4.0C andicated that acceptabilit< of resolut3on calculattens would be assessed during the D5P Ten of the Inter actions included in this 1mplementation review.
restew involved resolution calcul ations (two cf the ten were resolsed strictly on the basis of calculations while the remasq1ng eight were resolved us'ing physical modafications which Third party review themselves required supporting calculations).
of the calculations and1cated that, in general, SCI methods were not always the case.
The third parts
- usea, but this was (f or the methods and conclusions were reasonable considered that to the completed checillcts f or refer more detailed discussion, rooms 58,
- 117, 109, 174 205.
- 206, 207-1.
207-4 tboth interactions 3, and 000 in Appendia 2.4A).
i l
there were a f ew di screpancies It f i nal l y should be noted that numbers anL actual numbers, identified between recorded eautement but these were minor in nature and had no effect on interactico r es ol ut t on.
i process provided reasonable in summary, the DSP t er.p l emen t a t i on assurance that potential source commoditles and interactions were and that reasonable Identified in accordance w1th DSP crateria, resolutions were made.
2.4.4.2 Dynamic Impa:t Cri teri a As indicated in O.4.0.0.
se,eral interactions that had been I
04S l
1 i
1
- i0CKEIED USHBC UNITED STATES OF AMERICA y ISR 10 P1 :20 NUCLEAR REGULATORY COMMISSION ggg y before the
$0CKEllHGhN^Fi BRANCH ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2
)
}
CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the foregoing Answers To Board's 14 Questions was served this 10th day of March 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to:
- Peter B. Bloch, Esquire
- B.
Paul Cotter, Jr., Esq.
Chairman Chairman Atomic Safaty and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Assistant Director for
- Alan S.
Rosenthal, Esq.
Inspection Programs Gnairman Comanche Peak Project Division Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Panel Commission U.S. Nuclear Regulatory P.O. Box 1029 Commission Washington, D.C.
20555 Granbury, TX 76048
(
Asterisk indicates service by hand or overnight courier.
- /
- Juanita Ellis Robert D. Martin President, CASE Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St.,
N.W.
Dr. Kenneth A. McCollom Washington, D.C.
20007 Administrative Judge 1107 West Knapp
- William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C.
20555 Suite 1250 1050 Connecticut Avenue, N.W.
- Billie Pirner Garde Washington, D.C.
20036 Government Accountability Project
- Janice E. Moore, Esquire Midwest Office office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C.
205S5 Susan M. Theisen Assistant Attorney General
Environmental Protection Suite 600 Division Washington, D.C.
20005 P.O. Box 12548 Austin, Texas 78711-1548 Lanny A.
Sinkin Christic Institute Robert A. Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C.
20002 1350 New York Avenue, N.W.
Washington, D.C.
20005-4798 Nancy Williams CYGNA Energy Services, Inc.
- Elizabeth B. Johnson 2121 N. California Blvd.
Oak Ridge National Laboratory Suite 390 P.O.
Box X Building 3500 Walnut Creek, CA 94596 Oak Ridge, Tennessee 37830 David R.
Pigott
- Dr. Walter H. Jordan Orrick, Herrington & Sutcliffe 881 West outer Drive 600 Montgomery Street Oak Ridge, Tennessee 37830 San Francisco, CA 94111
- Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201
- W. G. Counsil Executive Vice President Texas Utilities Electric -
Generating Division 400 N. Olive, L.B.
81 Dallas, Texas 75201 Thomas A.
Schmutz 6/
Dated:
March 10, 1988 m -.._..