ML20205E205
| ML20205E205 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/06/1985 |
| From: | Williams N CYGNA ENERGY SERVICES |
| To: | Council W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 84056.085, NUDOCS 8510170222 | |
| Download: ML20205E205 (39) | |
Text
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emeor services 415/397-5600 1
101 Cahternia Street. Suite 1000 San Francisco. CA 941115894 October 6,1985 84056.085 Mr. W. G. Council Executive Vice President Texas Utilities Generating Company Skyway Tower 400 North Olive Street, L.B. 81 Dallos, TX 75201
Subject:
Cygno Questions / Comments on the CPRT Plan Texas Utilities Generating Company Comanche Peak Steam Electric Station independent Assessment Program - All Phases
Reference:
W. G. Council (TUGCO) letter to V. Noonan (USNRC), " Comanche Peak Response Team (CPRT) Program Plan and Self-Initiated Actions," dated June 28,1985 (Rev. 2 Program Plan attached)
Dear Mr. Council:
Cygno hos completed a review of those portions of the above-referenced document which appear directly related to Cygno issues. Our questions and comments are attached. In many cases the questions may be answered once we have had on opportunity to review the various criterio documents being developed by the CPRT groups.
Regarding the scheduling of meetings between the CPRT and Cygno reviewers, the only unavailable time for the Cygno project team is the week beginning October 14,1985 since we have scheduled a Senior Review Team meeting that week. Assuming no scheduling are available at your conflicts develop, such as preparing for NRC meetings, we convenience to discuss our comments / questions.
Very truly yours, 6L v }
t N. H. Williams Project Manager NHW:jst Attachments cc:
Mr. V. Noonan (USNRC) w/ottachments Mr. S. Burwell (USNRC) w/attochments Mr. S. Treby (USNRC) w/ottachments Mr. W. Horin (Bishop, Libermon, et al) w/ottachments Mr. J. Redding (TUGCO) w/ottochments 4
h[3 Ms. J. von Amerongen (TUGCO/EBASCO) w/ottachments Mrs. J. Ellis (CASE) w/ attachments Mr. D. Pigott (Orrick, Herrington & Sutclif fe) w/ottochments
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Mr. F. Dougherty (TENERA) w/ottachments Mr. R. Ballard (Gibbs & Hill) w/ottochments Mr. R. Kissinger (TUGCO) w/ottochments n
9 San Francisco Boston Chicago Richland 8510170222 851006 PDR ADOCK 05000445
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CYGNA COMMENTS ON CPRT PIPE SUPPORT ACTION PLAN ITEM NUMBER V.o 1
TITLE:
INSPECTION FOR CERTAIN TYPES OF SKEWED WELDS IN NF SUPPORTS (Rev.1)
Cygno ogrees with this action plan in principle. However, the cdequacy of the plan depends largely on the revised procedures, inspection checklists, implementation of the reinspection program and the final interpretation of the results. The following are specific creas where insufficient details exists and clarification is required:
1.
Criteria and Attributes CPRT ISAP V.c., Section 4.0 - 4.1.2, 4. l.4.
A.
Please provide the inspection criteria.
B.
Will checklists be used in the sample inspection program! If so, what are the checklist of tributes?
II. Inspection Method CPRT ISAP V.o, Section 4.0 - 4.l.2.
What inspection method will be used?
Ill. Expansion of Somples CPRT ISAP V.o. Section 4.0 - 4.1.3.
What are the criterio for determining the need and extent for additional weld inspection in the event that undersized welds are found which con still carry their design loads? (Ref. Paragroh 4.1.3., e.g, trenas in load changes, margin, frequency of occurence, accessibility of welds, safety importance etc.).
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u CYGNA COMMENTS ON CPRT DESIGN CONTROL ACTION PLAN ITEM NUMBER: Vil TITLE: DESIGN CONTROL We reviewed those sections of the plan decling with design control, but could not find reference to the Cygno issues described below:
1.
Design Verification Design Control HIL #2 Cygno's cumulative effects and trending evoluotion hos identified that the design verification area contains a significant number of deficiencies. This finding shows that the design reviews and checker reviews were potentially deficient.
A.
How is the CPRT Plan going to assure that the procedures used during the design verification program are adequate and that the procedures will be properly implemented to prevent the recurrence of this type of deficiency?
B.
How will the CPRT plan assure that any future design verification activities os a result of plant modifications are adequately covered by procedures and that the procedures are implemented?
- 11. Control of Design Interfoces Design Control HIL ltem f/4 Cygna's cable troy support and piping reviews have indicated that some of the design problems may have been caused by site /home of fice interfaces.
No action plan has been developed to ossess the adequacy of the control of design interfaces between disciplines, aesign organizations, and site /home of fice.
Ill. Adequocy of Design Documentation Design Control HIL #6 The results of Cygno's technical reviews indicate that there were numerous instances of undocumented assumptions and inadequate references to design inputs.
It appears that no oction plan has been developed to address the adequcy of design documentation aspect of design process.
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CYGNA COMMENTS ON CPRT DESIGN CONTROL ACTION PLAN ITEM NUMBER: Vll.a.2 TITLE: NONCONFORMANCE AND CORRECTIVE ACTlON SYSTEM While this action plan tends to deal principally with site issues, Cygno concurs with its provisions. Questions involving design specific evoluotions are noted below:
1.
Design Deficiencies and Design Process Corrective Action Design Control RlL No. 7 CPRT, Appendix C, Action Plan Vll.a.2, Section 4.0 Section 4.1.3.1 discusses the development of "reportability checklists" which will oddress whether or not design documents released for construction met the SAR and performance specifications. How will this determination be mode? Will the results of the DSAP's be used to make this determination? -
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CYGNA COMMENTS ON CPRT PIPE SUPPORTS ACTION PLAN ITEM NUMBER Vll.b.3 TITLE: PIPE SUPPORT INSPECTIONS, Rev. O.
This plan is general in nature; the concept and procedures of the plan are acceptable in principle but locking in details as to how each specific issue / concern will be evoluoted and resolved. While TRT concerns are discussed, the plan does not appear to address any other Cygno walkdown items which were not identified by TRT.
In order to obtain a better understanding of the plan and to provide assurance that all concerns are properly and completely addressed, the following creas require clarification:
1.
Definition / Criteria of "Sofety Significant Discreponey" ond Inspection Attributes CPRT ISAP Vll.b.3, Section 4.0 - 4.1 A.
Section 4.1 states that "The results of these inspections will be evoluoted to identify any safety significant discrepancies such that if unrepaired, the item will be unable to perform its safety related function."
Please elaborate on the definition of the term " safety significant discreponey" with respect to meeting the code and FSAR requirements.
B.
Will the cumulative effects of two or more discrepancies be considered in judging whether o discrepancy is safety significant?
C.
Please identify which of the twenty-five deficiency categories listed in Table 2 of this action plan ore considered to be " safety significant" discrepancies. What are the reasons for these classifications?
D.
If the Pipe Support inspection action plan is intended to be all inclusive, what other attributes besides those identified by the TRT, if any, will be included in this action plan?
Examples of some of the Cygno identified attributes are listed below:
o Minimum spacing requirement (12" oport) between ottochments to embedded plates, o
Warping of structural members.
o insufficient or unclear dimensions shown on drawing (e.g. base plate I
edge distance specified as " min. I /2" Typ.").
Texas Utilities Generating Company I of 2 I
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.s CYGNA COMMENTS ON CPRT PIPE SUPPORTS ACTION PLAN (continued) o Minimum spacing requirements between the various types of onchor bolts : Hilti Kwik-Bolts, Civil Anchor, Richmond Inserts, Grouted-in Anchor and Thru-Bolts.
o Existence of pipe sleeve penetrations close to pipe support base plates and minimum spacing requirement.
E.
Please provide the checklists which will be used in the implementation of this action plan.
F.
Will the minimum sample size be selected based on identified attributes (i.e.,
one sompte set for each attribute with safety significance)?
G.
Cygno has identified some concerns with respect ter the control of cross-discipline interfaces such as spacing violation control between structural supports and pipe supports. Please identify which procedures, in addition to those listed in 4.l.6, will be reviewed.
- 11. Acceptance Criterio CPRT ISAP Vll.b.3, Section 4.0 - 4.5.2
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A.
Please provide the minimum acceptance criteria.
B.
The plan states that the acceptance criteria used during the re-inspection will be based on the " safety significance" of a discrepancy (Paragraph 4.I.5.3). The close-out Acceptance Criteria are related to meeting design requirements (Paragraph 4.5.2).
Depending on tiie more detailed definition of " safety significant discreponey" requested in I.A., there may be some inconsistency.
Texas Utilities Generating Company 2 of 2 L*h LG t Til 23CPRT-PSI Project No. 84056
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CYGNA COMMENTS ON CPRT PlPE SUPPORT ACTION PLAN ITEM NUMBER Vll. b.4 TITLE: HILTI ANCHOR BOLT INSTALLATION, REV. 0 The general approach of the action plan is acceptoble in principle, however the final acceptability of the plan depends on the minimum occeptance criteria os well as the decision criterio. Details of these attributes and criterio are not presently given in the plan.
In order to have o better understanding of the plan, the following clarifications are requested:
1.
Embedment Length Pipe Support RlL No.17 CPRT ISAP Vll.b.4, Section 4.0 A.
How will the discrepancies in embedment length dimension between os-built support, support drawings and calculations be resolved? (Via NCR on a case by cose basis os indicated in Section 4.1.8?)
B.
Since embedment lengths shown on the drawing may not be correct, what are the actions provided by this plan that will ossure the minimum required embedment length is provided and properly documented?
- 11. Criterio and Safety Significant Attributes Pipe Support RlL No.17 CPRT ISAP Vll.b.4, Section 4 - 4.1.1, 4.1.2, 4.6.2 and 4.7.1 A.
Please provide the acceptance criterio.
B.
Please provide a definition of " safety significant" attributes.
C.
Please provide the decision / closure criterio referenced in Section 4.7.1.
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CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN ITEM NUMBER: APPENDIX C, SECTION Vill TITLE: CIVIL / STRUCTURAL DISCIPLINE SPECIFIC ACTION PLAN Cygno has reviewed the CPRT plan to address the cable troy ond conduit support designs and perceives the flow of work to be os follows:
identification of critical porometers and immediate modifications using existing o
data identification of the various cable troy and conouit populations using existing o
data Selection of engineering samples based on lower bound performance o
o Selection of rondom samples based on statisticar requirements Development of os-built drawings for the chosen somples o
Determination of governing loads and load combinations o
Testing of components, supports, and/or systems to aid in modeling and to o
support the evoluotion criteria Modeling and analysis of individual supports using component test results and i '
o comparison with any support tests performed Modeling and analysis of systems using detailed or simplified support models and o
comparison with any system tests performed o
Development of acceptance criterio o
Evoluotion of the systems and supports The work required to perform the evoluotion for each system could be difficult and time-consumming. Considering the complexity of systems analyses, it may be advantageous to consider performing component tests and detailed onolyses for groups of individual supports only. However, our specific comments and questions on the stated opproach are ottoched.
1.
Cable Troy Review issues in Table Vill.2, o summary of the cable troy issues is provided. Cygno's comments on this table are presented below.
Texas Utilities Generating Company I of 12 l
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r CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
A.
Cable Troy Review issue 1 - Controlling Lood Case for Design Cygna's RlL indicted that for the three listed building elevations, the ratio of SSE to I/2 SSE exceeded 1.33. The 1.33 cut-off is based on the assumption of limiting structural steel to the yield stress for the SSE event and the acceptobility of a reduced factor of safety for Richmond inserts and Hilti Kwik-bolts at SSE loading. The reouced safety factors have not been justified by TUGCO/Gibbs & Hill.
B.
Cable Troy Review issue 2 - Seismic Response Combination Methods The description given is unclear. Gibbs & Hill combined the dead load with the seismic loads using the SRSS method. The increase in resultant load will be due to using the correct method of performing on algebraic sum of the dead load with the SRSS of the seismic loads.
Will closely spaced modes be considered in oli modal analyses in accordance with the USNRC Regulatory Guide 1.92?
C.
Cable Troy Review issue 3 - Anchor Bolt Design Cygno's concern over the use of ACI 349-76 to justify the capacities of certain anchor bolt installations is not included in the table.
D.
Cable Troy Review issue 4 - Design of Compression Members Cygno's concern also addresses Gibbs & Hill's choice of the effective length factor 'k' and the assumed bracing to the cable troy supports provided by the troy.
E.
Cable Troy Review issue 5 - Vertical and Tronsverse Loading on Longitudinal Type Supports This item states: "Tropeze type supports are rigidly connected...". This issue applies only to longitudinal tropeze type supports os shown on Gibbs & Hill drawing 2323-5-0902.
F.
Cable Troy Review issue 6 - Support Out-of-Plane Vertical Loods This item states: "Out-of-plane vertical loads..." The word " vertical" in this issue should read "inertiol".
Cygno's concern addresses the inconsistent consideration of the support self-weight in the designs. Dead load and seismic inertial loods in the restrained direction were not consistently included and seismic inertial loads in the unrestrained (i.e. out-of-plane direction for tropeze type supports) direction were not included in the support designs.
G.
Cable Troy Review issue 10 - System Concept in the original design process, each cable troy support was assumed to act independently, Eccentricities between support members and between the cable M*I,P.i t I A 1 Texas Utilities Generating Company 2 of 12 3
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CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued) tray centerline and the support frame were not considered. The odoed loads on supports developed through the system action were never considered in the original designs of any supports within Cygno's review scope. If system behavior con be justified, including the assumed clamp behavior, the additional loads on supports should be considered in all support evoluotions.
H.
Cable Troy Review issue 12 - Working Point Analysis Study Two of Cygna's issues were omitted from the description of this item: (l) the study does not check oil components of a given support to determine which item was governing, and (2) several of the modeling assumptions used were not adequately justified.
I.
Cable Troy Review issue 14 - Non-Conformance with AISC Specifications How will the CPRT plan comply with FSAR commitments in the qualification of the electrical raceway supports?
J.
Coble Troy Review issue 15 - Member Substitution Cygno's concern is over the possible interpretations lef t open by the indicated drawing note os to what member substitutions are acceptable. The walkdown
. finding cited was only on example provided to illustrate on interpretation of this note which is contrary to its intended meaning.
K.
Cable Troy Review issue 17 - Embedded Plate Design Three issues were omitted from the description of this item: (1) various support design groups had inconsistent requirements for the use of stiffeners on moment connections to embedded plates (see also Cygno comments on CPRT DSAP IX),
(2) there are differences between the ottochment location tolerances used for the cable troy support designs and those given in Gibbs & Hill Specification 2323-55-30, and (3) GC inspection requirements for cable troy support installations do not address the spacing limitations between ottochments to embedded plates.
How will the CPRT plan address Cygna's concerns on the design of cable troy supports employing embedded plates?
L.
Cable Troy Review issue 19 - Other Loads in FSAR Combination This issue oppears to be only partially addressed by the CPRT Plan (Tosk Vill.C). In addition to the high energy line break loads (i.e., pipe whip and jet impingement), thermal effects should be considered for supports in creas where such loads are expected to occur, such as inside containment. Will this issue be considered in the determination of governing loads? If so, how will this effect be considered in the selection of components which exhibit lower bound seismic performance?
Texas Utilities Generating Company 3 of 12 L*h FJLTA1 23CPRT-CSD I;;;;;;;=
- i Project No. 84056
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CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
M.
Cable Troy Review issue 22 - Design of Support No. 3136, Detail 5 Cygno reviewed the design of cable tray support 3136 (Detail "5", drawing 2323-S-0905). This Category I support was attached to the Category 11 steel of a firewall. Additionally, the original analysis did not consider tornado pressure loading which this wall should be designed to withstand. How will the CPRT plan address these concerns for similar supports elsewhere in the plant?
- 11. Conduit Review issues in Toble Vill.3, the conduit review issues are summarized. Cygna's comments on the table are provided below:
A.
Conduit Review issue I - Controlling Lood Case for Design item I of the referenced table discusses controlling load cases in terms of accelerations for specific building elevations. Cygno's concern includes the acceleration levels for the particular buildings in conjunction with the component allowables. For all catalog components, such as anchor bolts and Unistrut and Superstrut components, o reduced factor of safety for SSE loading is assumed, independent of building elevation. The reduced factors of safety have not been justified by TUGCO/Gibbs & Hill.
B.
Conduit Review issue 3 - Combination of Dead Weight and Seismic Response item 3 of the referenced table states "... and then continued using on SRSS combination..." Please define the context of " continued" in this statement?
C.
Conduit Review issue 4 - Measurement of Embedment from Top of Topping item 4 of the referenced table discusses bolts embedded in topping only.
Cygna's concern extends to bolts which may have reduced embedments due to orchitectural topping.
The effect of the decreased embedments were not included in the design.
D.
Conduit Review issue 5 - Bolt Hole Tolerance and Edge Violation item 5 of the referenced table states, " Bolt hole tolerances are given as a function of the bolt size instead of being a fixed quantity (1/16"). Minimum edge distance for oversite (sic) holes is not specified." The AISC Specification does not allow any tolerance in bolt hole size. A bolt hole shall be 1/16" larger than the nominal bolt size for all cases; thus, the phrase "instead of being a fixed quantity..." is incorrect. Minimum edge distance need not be specified, but the drawings should provide adequate edge distance for the maximum hole size.
E.
Conduit Review issue 6 - Other Loads in the FSAR Combinations See item 1.L.. -
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- 1 Project No. 84056
CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
F.
Conduit Review issue 7 - Support Self Weight Item 7 of the referenced table states, " Support self weights are not uniformly considered in analysis." This item should be interpreted as follows: Support self weights are not consistently considered from one design to another.
G.
Conduit Review issue 10 - Anchor Bolts Two issues were omitted in item 10 on the referenced table: (l) use of the 8th Edition method to calculate prying factors and (2) bending of onchor bolts for the CST-17 support anchoroge.
H.
Conduit Review issue 15 - Stresses in Cable Troys Due to Attochment Conduit Supports item 15 of the referenced table states, " Cable troy supports have not been designed..." The phrase should read "Coble trays have not been designed..."
How will stresses in cable troys due to the ottochment of conduit supports be addressed?
l.
Conduit Review issue 18 - Clamp Usoge Miodification of C-7085 clamps has been added to this Review issue.
J.
Conduit Review issue 19 - Documentation Deviations Between Inspection Reports, CMC's, and IN-FP Drawings Although Table Vill.5 indicates that these issues will be addressed by Population identification, Analysis, and Design Evoluotion, Cygno does not feel that these issues con be addressed by those tasks. Most of the deviations reported in this review issue are GC-related. Although the deviations may have on effect on the technical aspects of the design, those ef fects will be adequately addressed in other review issues. The resolution of these issues should be accomplished in the GC/ Structural Interfoce portion of the plan.
K.
Conduit Review issue 22 - Span increase for Fire Protected Spons Cygno's major concern is in regard to how Gibbs & Hill's used the conduit vendor's material test dato in the calculation of allowable conduit spons.
Specifically, the allowable stresses were established through a grouping of the test dato by the conduit nominal diameter.
L.
Conduit Review issue 23 - Grooted Penetration Loods How will the capacity of such penetrations be determined? Will such capacity calculations consider installation procedure?
Texas Utilities Generating Company 5 of 12 L a ( J L IAT 23CPRT-CSD 111111111111111111111111ll1111Project No. 84056
CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued) 111. Existing Design Calculations What will be the status of the original design calculations offer the CPRT plan has been implemented? Will the new onalyses become the analyses of record?
Will future engineering evoluotions (e.g., review of CMCs, thermolog evoluotion, etc.) be based upon the original design calculations or the results of the CPRT plan?
IV. Interface Between the QA/QC Plan and the Civil / Structural DSAP The " Quality of Construction and QA-QC Adequacy Program Plan", Appendix B, item II.D, " Relationship to Other CPRT Activities", indicates that any information that relates to design adequacy identified by the QA-QOC octivity will be referred to the oppropriate design adequacy team. The Civil / Structural DSAP, Task Vill, does not address how inputs from the QA-QOC section will be factored into the DSAP.
If QA/QC identifies problems that may offect the determination of supports or runs that exhibit lower bound behavior, will these problems be considered in the determination of the engineering sample selection and the selection of supports for the testing program?
If the QA/QC review indicates potential problems in support installations in specific plant areas or for support installations performed during a specific time period of construction, will the CPRT plan insure that these types of installations will be included in the engineering sample?
V.
Task Vlli.A. - Identification of Critical Systems, Supports, and Components A.
Identification of Lower Bound Performance Systems Section 1.0 states that " criteria will be developed for identification of lower bound performance systems to be selected in Task Vill.B." Section 2.0 states, "As-built dato recently collected from Units I and 2 cable trays os well as original design information will be utilized in conjunction with si>pporting analyses that have identified hardware more prone to lower bound seismic performance behavior."
1.
Please provide the procedures and criteria to be used in the screening process to determine those supports and systems which exhibit lower bound performance.
2.
Are the designs and installations of Units 2 supports consistent with those of Unit I, such that the extension of design methodologies and assumptions is justifiable?
Texas Utilities Generating Company 6 of 12 LehLGtr11 23CPRT-CSD Project No. 84056 t
l CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
B.
Supplemental Walkdowns i
Section 2.0 indicates that supplemental walkdowns may be performed if required to assist in the identification of hardware exhibiting lower bound performonce, l.
How much as-built dato currently exists for conduit supports?
2.
Under what circumstances will supplemental walkdown dato be necessary?
3.
How will the walkdown data be used with the S-0910 package and the Unistrut test data to identify lower bound components and supports? How will this information be used to choose the engineering sample?
C.
Modifications in Unit 2 Section 3.1 states: "During the course of that review (Unit 2), it was noted that physical modifications were at times more expeditious than detailed analysis."
What types of modifications were made? Which support types were offected?
What loadings were considered?
D.
As-Built Data for Cable Troy Supports Section 3.1 states that due to. the as-builting of 500 cable troy supports in Unit I and the design verification in Unit 2, "a number of support types and systems configurations have been identified which display lower bound seismic performance behavior."
1.
Please identify which support types exhibited lower bound seismic behavior.
2.
Please define o " cable tray system". What criteria were used to identify the cable troy systems?
3.
What is a critical run configuration? How con a review of support layout identify these?
4.
What was the sampling basis for the 500 Unit I as-built supports?
E.
Categorization of Cable Troy / Conduit Supports 1.
Section 4.1 states that cable troy " supports will be sorted in respective categories os a function of their geometries and expected dynamic behavior. Please provide o description of the categories and the criterio to be used in the sorting of the cable troy supports.
2.
Please provide the criteria to be used in determining the selection of representative conduit support types that exhibit lower bound behavior.
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CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (con?inued)
VI. Task Vill.B. - Identification of Populations and Choosing Somples A.
Random Sample Selection Criterio I.
There are three definitions for electrical raceway " runs" given in Section 4.2.1. Please describe the differences in the definitions and applications of the term system "run".
Which definition will be used to define the population of system " runs"?
2.
If the rondom sample selection task has not already been performed, how was the random sample size of sixty (60) conduit or cable troy runs determined?
B.
Engineering Sample Selection Criteria identification of supports and components which exhibit lower bound behavior will be performed in Task Vill.A. How will that information be utilized in the selection of the engineering sample, since the sample is based on the run configuration, rather than the support configuration?
C.
Identification of Conduit Populations The electrical raceway schedule and conduit inspection reports will be used as o basis for identifying the conduit populations and choosing samples.
1.
What kinds of populations (i.e., component, support, or system) will be identified?
Will one population of conduit runs and one population of conduit supports be identified?
2.
TUGCO has compiled a database which provides information regarding the number of each support iype in the plant.
Will this be utilized in determining the engineering sample?
3.
Are there any criteria on numbers and types of generic supports represented in the engineering sample?
D.
Walkdown and As-Builting Process 1.
What site procedures will be used in the as-built process that will occur of+er The run samples are selected?
2.
What tolerances will be used in the measurements?
How will this as-builting criteria be reconciled with the system analyses which will be performed later?
3.
How will the selection criteria and walkdown procedures address those circumstances when a component cannot be as-built either due to inaccessibility or Thermolog covering?
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Texas Utilities Generating Company 8 of 12 l
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CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continuca) 4.
In the scope discussion on nen-safety related conduits (CPRT Action Plan Section 1.c), one restriction was placed on the selection of the somple.
Systems judged to be "inoccessible" were removed from consideration when choosing the sample. Does this restriction opply to the selection process for this scope?
If any " inaccessible" systems or portions thereof are removed from consideration, how will this apparent selection bias be addressed by the plan? If these systems are retained in the sample, but incomplete as-built data is used, how will this affect the validity of the sample?
5.
How will the os-builting process address Cygna's concerns on the following matters:
a.
Proximity to mechanical equipment as specified in Gibbs & Hill Specification 2323-ES-100 b.
The undocumented use of cable troy cover plates c.
The undocumented use of built-up cable tray sections d.
Cable troy clamp bolt hole locations e.
Gaps between the ccble troy and clamp f.
Minimum onchorage spacing requirements 9
Other components supported on cable troy supports (e.g., conduits, pipe supports, lighting, etc.)
h.
General construction quality (i.e.,
member straightness, frame plumbness, connection seating, etc.)
- i. Bearing of base plates on concrete and the use of shims
- j. Location, type, and condition of cable troy / conduit fittings k.
Anchor bolts o
Anchor bolt projection to determine octual embedment o
Length and type (Kwik or Superkwik) of bolts 1.
Embedded plates o
Attachment location with respect to Nelson Studs and other attachments o
Nelson Stud edge distances Texas Utilities Generating Company 9 of 12 LYMiA 23CPRT-CSD lll1lllllll1lll111lllll1111111 Project No. 84056
CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
E.
Existing Design Drawing Verification 1.
What drawings will be used in this verification ef fort for the cable troy supports?
2.
Will opplicable oesign changes be identified and considered in the review process?
F.
Governing Support Configurations for Lower Bound Seismic Performance To Be Used in the Test Progrom 1.
Will the engir 4 + ring somple address all concerns in c. cumulative and bounding manne.c?
2.
Define the total population from which the sample of electrical raceway supports will be chosen to perform statistical or design maximum evoluotions, os discussed in Section 4.4.
3.
How does the evoluotion address those supports which exceed the maximum design allowobles?
4.
How does this evoluotion address individually designed supports?
Vll. Task Vill.C. - Determination of Governing Loods A.
Revised Seismic Response Spectro Section 1.0 of this task description states:
"If applicable, revised seismic response spectro and systems domping will be specified."
If these spectro are different from those currently in use, please provide the details on their generation and acceptobility per FSAR commitments.
B.
Seismic Analyses Will both OBE and SSE onalyses be performed? If not, how will the plan oddress Cygnc's concern regarding the normalization of OBE ond SSE loads in relation to allowables and factors of safety for catalog components and certain structural steel allowobles?
Vill. Task Vill.D. - Testino A.
Test Configurations How will the configurations be established in order to determine the required range of component and support behavior and strength?
l Texas Utilities Generating Company 10 of 12 TML M 23CPRT-CSD ll111llIlll1llllllllllllllllll Project No. 84056
CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
B.
Test Specifications and Procedures Please provide all test specifications and procedures for Task Vill.D.
C.
Expansion Anchor Tests Reference is made to testing the expansion anchors under different levels of prestress. How will such results be used in the component verification task? If they are to be used in this task, how will the prestress levels be verified in the walkdowns, and how will such levels be verified over the plant population?
D.
in-Situ Testing of Cable Troy and Conduit Systems it is Cygna's experience that more useful modal dato con be obtained if the troy / conduit system is excited using a shaker os opposed to o calibrated hommer.
IX. Task Vill.E. - Component and System Behavior and Modeling A.
Modeling For the Conduit Engineering Somple Will the system modeling for the conduit engineering sample reflect the os-built condition, or will it attempt to envelop the generic designs in any way? If the as-built condition is modeled, how will the bounding configurations of the generic design be considered?
B.
Sample Expansion The plan specifies that "the samples may be expanded consistent with the analytical results and established sample selection criterio." (Section Vill.4.1.1 of the CPRT Structural Discipline Action Plan, Page 9/35). Please provide the criteria which describes the circumstances for which it would be necessary or desirable to expand the samples?
C.
Model Simplification in Section 4.2, it is stated that " local effects may be quantified by developing a factoring procedure to be applied to member forces." How will this opproach be used without offecting the analytical response of the structural system?
D.
Conduit Fill Weight The fill we:ght offects the dynamic response of the conduit run. Will design fill weight or actual fill weight be used in the model?
Texas Utilities Generating Company iI of 12
[*)ltj i 23CPRT-CSD i
liiii.....n..
Project No. 84056
CYGNA COMMENTS ON CPRT CIVIL / STRUCTURAL ACTION PLAN (continued)
X.
Task Vill.F - System Analysis A.
Modification of Components and Supports Sections 4.2 and 4.3 of this task discuss the identification and trending of modifications that may result from the analysis of the engineering sompte. The incorporation of such modifications into the random sample analyses is also discussed.
l.
Please provide the criteria that will determine if a component or support should be modified or the analytical model refined.
2.
To what level will inadequate performance be attributed: system, support, or component?
3.
Please provide the criteria which defines the portion of the population to which modifications will be applied.
XI. TASK Vill.G - Component Design Evoluotion Please provide the acceptance / performance criteria for cable troy and conduit support components.
l Texas Utilities Generating Company 12 of 12 L*) Ltj L i 23CPRT-CSD llllll"""r
- i Project No. 84056
O CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN ITEM NUMBER: IX TITLE: PIPING AND SUPPORTS DISCIPLINE SPECIFIC ACTION PLAN, Rev. O.
In the piping and pipe support area, TUGCO has undertaken to initiate o significant level of re-onalysis to be performed by Stone and Webster Engineering Corporation (SWEC) and to be overviewed by a third party. The DSAP oppears to be comprehensive but some of the wording is general in nature.
The approach and methodology of this plan are acceptable in principle but they lack sufficient detail related to specific issues.
The following issues, questions and requests need to be addressed so that Cygno con be assured that all concerns are resolved in a complete and satisfactory manner.
I.
Areas Which Require Review of the SWEC Criteria A.
Inclusion of Fluid and insulation Weight at Volves and/or Flanges in the Piping Model Pipe Stress Rll No. 4 CPRT DSAP IX Attachment 2, Section D.I.o B.
Calculation and Checking of intensification Factors (SIFs)
Pipe Stress RIL No.10 CPRT DSAP IX Attachment 2, Section D.I.o C.
Modeling of Volves with Natural Frequencies Less Than 33 CPS Pipe Stress RlL No.18 CPRT DSAP IX Attachment 2, Section D.I.o D.
Design of Combination Welded / Bolted Connections Pipe Support RIL No. 2
,CPRT DSAP IX, Attachment 2, Section D.I.
Will all pipe supports within the scope of the pipe support qualification program be checked for compliance with paragraph XVil-2442 of Section lli of the ASME l
Code?
i E.
Effective Throat of Flore Bevel Weld CPRT DSAP IX, Attachment 2, Section D.I.
f Per AISC 8th Edition, the effective throat of flore bevel welds is given as 2 x t l
x S/16 (where t is the thickness of the tube woll). Will this definition be used l
for flore bevel welds in the pipe support qualification program? If not, what other definition will be used?
Texas Utilities Generating Company I of 9
[TFJ t 11 23CPRT-PAS m"i"" -,,,
Project No. 84056
CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (con?inued)
F.
AISC Manual Edition for Selection of Structural Tube Steel Section Properties Previous Review Question With Generic importance CPRT, DSAP IX, Attachment 2, Section D,l.
G.
Concrete Anchor Bolt Minimum Edge Distance.
CPRT, DSAP IX, Attachment 2, Section D,1.
It is noted that there ore some instances where pipe sleeve penetrations exist close to support base plates but are not shown on support drawing. How will the pipe support qualification program oddress this problem? Please supply the minimum edge distance criteria for anchor bolts (e.g. Hitti Kwik-Bolt) adjacent to pipe sleeve penetrations.
H.
Moss Participation / Moss Point Spocing Pipe Stress RlL No. I CPRT DSAP IX Attachment 2, Section D.I.o I.
Please supply the SWEC criteria which provides assurance that the requirments of the CPSES FSAR ore met.
2.
How will this program be utilized for seismic analysis to insure that pipe stress and particularly pipe support reactions are sufficiently occurate?
3.
Please supply the SWEC mass point spacing criterio.
4.
Please supply the decoupling criteria which will be used by SWEC in the piping reonalysis program.
I.
Calculation of Support Mass for inclusion in Pipe Stress Analysis Pipe Stress Rll No. 9 CPRT DSAP IX Attachment 2, Section D.I.o J.
Welded Attachments Pipe Stress RIL No. I I CPRT DSAP IX Attachment 2, Section D.l.a 1.
What methodology will be used to calculate local stresses at welded ottochments?
2.
To what allowable stresses will these local stresses be compared?
3.
How will local stresses be considered in evoluotions of break exclusion zones?
4.
How will the combined effects of two supports at a single welded ottochment be considered?
5.
How will the combined effects of two adjacent supports located on the some pipe cross-section be considered?
(
i r
Texas Utilit.ies Generat.ing Company 2 of 9 d gj 3 g iJ L T Al 23CPRT-PAS
!!!!!-ungn-m."'""I Project No. 84056
CYGNA GUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued)
K.
Tolerances For Use in Evoluoting Analysis vs. As-Built Pipe Support Locations and Orientations Pipe Stress RlL No.14 CPRT DSAP IX Attachment 2, Section D.6 L.
Methodology For Selection of Domping in Seismic Analysis of Piping Systems with Mixed Sized Piping Pipe Stress RIL No. IS CPRT DSAP IX Attachment 2, Section D.I.o M.
Incorporation of Eccentric Moss and its Effect on Piping and Welded Attochments (e.g., tropeze supports with and without trunnions)
Pipe Stress RlL No.19 CPRT DSAP IX Attachment 2, Section D.I.o N.
Determination of the Magnitude of Friction Forces on Supports and inclusion of Friction Forces in Pipe Support Design Pipe Support RlL No. 29 CPRT DSAP IX, Attachment 2, Section D.I.
O.
Consideration of Support Self-Weight Excitation During a Seismic Event Pipe Support RlL No.12 CPRT DSAP IX, Attachment 2, Section D.l.
P.
Consideration of Dyrxrnic Pipe Movements From Steom/ Water Hammer in Support Design Pipe Support RIL No.15 CPRT DSAP IX, Attachment 2, Section D.I.
i
- 11. Unique Pipe Support Designs and Issues At CPSES Which Require specific Criterio A.
Snubbers on Fisher Valves I
Pipe Stress RlL No. 6 l
CPRT DSAP IX Attachment 2, Section D.6.
The snubbers on the Fisher volve operators were not qualified for the as-built loads. This issue led to questioning whether the volve itself was capable of transmitting these loods and still mcintaining operability. TUGCO requalified all effected volves and snubbers, however, Cygno has not reviewed the qualification report.
Will the new loads generated from the piping reonalysis program be checked j
ogainst the loads for which volves were previously qualified?
B.
Isr.ue: Box Frames with 0" Gap Pipe Support RIL No. I CPRT DSAP IX, Attachment 2, Section D.I.
N, Texas Utilities Generating Company 3 of 9 r
Li:bj! L I A 1 23CPRT-PAS ll..;;;;iin-mniilillll Project No. 84056
i CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued)
I 1.
Will box frames with 0" gaps be used in the finalized designs of any pipe supports of Comanche Peak? If so, please respond to each of the three questions / requests in the Attachment to the Cygna Jonvary 28,1985 letter no. 84042.023.
2.
What allowable stress limits will be used for the frame steel and welds?
C.
Stability of Pipe Supports Pipe Support RlL No. 6 CPRT DSAP IX, Attachment 2, Section D.I.
How will the effects of potentially unstable supports be considered?
D.
Richmond insert Allowables Pipe Support RIL No. 3 CPRT DSAP IX, Attachment 2, Section D.I.
l.
How will Richmond Insert allowables be established?
2.
Please provide the methodology which will be used to determine the oxial force in a bolt / insert due to torsion in the tube steel. Will the present Richmond insert /tubsteel supports at issue be modified in any way to eliminate the necessity of using the above methodology?
3.
Will the tests and analyses referenced in the Affidavit of John C.Finnegan, Jr., Robert C. lotti and R. Peter Deubler "Regarding Design of Richmond inserts and Their Application to Support Design" be used in any way for the requalification of Richmond insert / tube steel supports.
If so, please respond to the questions / requests, in the Cygna January 31, 1985 letter no.
84042.025.
4.
For any as-built support, how will it be verified that the Richmond Insert allowables used in design correspond to the actual insert spacing requirements specified by the Civil / Structural group?
E.
Cinching of U-bolts.
Pipe Support RIL No. 7 CPRT DSAP IX, Attachment 2, Section D.I.
I.
Will cinched U-bolts be used in the finalized design of any pipe supports at Comanche Peak?
If so, will the Westinghouse Test / Analysis results be utilized in any way to substantiate the design of supports which use cinched U-bolts?
If so, please respond to each of the eleven questions in of the Cygno March 25,1985 letter No. 84042.036. If not, what data will form the basis for justifying the use of pipe supports with cinched U-bolts? Please supply this dato.
l l
l i =f j s Texas Utilities Generating Company 4 of 9 JL a 23CPRT-PAS
""""'!!!!!!!!!;;,,,,,,illi Project No. 84056
CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued) 2.
If U-bolts are cinched, how will pipe stresses from U-bolt cinching, pipe thermal expansion, internal pressure, dead load and seismic load be classified within the ASME Code Stress categories, and what allowables will be used for each of these categories?
3.
How will the U-bolts be qualified? And what consideration will be given to its effect on support frame / member?
F.
Dual Strut / Snubber Design Pipe Support Rll No.16 CPRT DSAP IX, Attachment 2, Section D.I.
1.
How will oxial restraints. and other types of dual restraint designs (tropezes, double trunnions, riser clamps with shear lugs) be modeled in the pipe stress reonalysis?
2.
If the dual restraint is remodeled as a single restraint, please provide the methodology which will be used to proportion the support reaction in the single restraint to each leg of the duct restroint for the purpose of support design?
Ill.
Other Specific Questions and/or Requests A.
Inclusion of Appropriate Response Spectro Pipe Stress RIL No.13 CPRT DSAP IX Attachment 2, Section D.4 Will all piping analysis be reviewed to ensure that all appropriate response spectro from oil buildings have been considered?
B.
Combination of Safety / Relief Volve Thrust and Seismic Loods Pipe Stress RlL No.16 CPRT DSAP IX Attachment 2, Section D.2 Will the stresses /loods due to safety relief volve thrust be combined with those due to SSE for the emergency cose for all four Main Stream lines outside containment?
C.
Force Distribution in Double Ported Safety Valves Pipe Stress RIL No.17 CPRT DSAP IX Attachment 2, Section D.I.o in the Gibbs & Hill piping analysis a 55/45 flow split was assumed for double ported safety volves instead of the 60/40 split suggested by the manufacturer, Crosby Valve. As a consequence the torque on the Main Stream pipe is halved.
What flow split will be used for double ported safety volves in the piping reonalysis program?
Lil FJLIA1 Texas Utilities Generating Company 5 of 9 23CPRT-PAS Project No. 84056
u CYGNA GUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued)
D.
Local Stresses in Piping Due to Line Contoct CPRT DSAP IX Attachment 2, Section 2.l.b For the situation where a pipe (without a pod) bears against a support (i.e. line contact between pipe and support) what criteria will be used to determine the conditions under which the stresses induced in the pipe due to this line contact are to be calculated? What criteria will be used to determine when these stresses are excessive?
E.
Thru-Bolts and Concrete Acceptability Pipe Support RIL No.10 CPRT DSAP IX, Attachment 2, Section D.I.
. There is no written procedure documenting the transmittel of the os-built pipe support loods acting on concrete structures to the structural group. Thus, there is no assurance that each areo, particularly those near free edges, is acceptable.
How will assurance be provided that the civil structures are acceptable for the as-built opplied loading?
F.
Methodology For Determining Allowable Punching Shear in Tube Steel Connections Pipe Support Rll No. 4 CPRT DSAP IX, Attachment 2, Section D.I.
Please justify the use of AWS DI.1-79, Section 10.5.1 for predicting tube steel allowable punching sheer for cases which differ significantly from those for which the equations were derived (e.g., the cose where either a hole is placed in the tube steel and the edge of the hole is loaded, or a rear-brocket is welded close to the end of the tube steel).
G.
Embedded Plate Design Pipe Support RlL No. 26 CPRT DSAP IX, Attachment 2, Section D.I.
Gibbs & Hill Specification 2323-55-30 requires that all attachments to embedded plates shall be assumed to be pin connections and that moment connections to the embedment require stiffening. However, Gibbs & Hill does not provide any guidelines for the stiffening.
The pipe support design organization assumes that any attachment to the embedded plate will effectively stiffen the local creo, but they did not cross-check this assumption with Gibbs & Hill. (See also Cygno comments on CPRT DSAP Vill.)
1.
How will this situation be resolved by the support qualification program?
2.
Will the specification be revised to provide guidance in selecting stiffeners for moment connections to embedded plates, and will all offected supports be modified to conform to the revised specification?
Texas Utilities Generating Company 6 of 9 3
- I NJ L 1
23CPRT-PAS Project No. 84056
CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTICrN PLAN (continued)
H.
Hydrotest Support / Stress Design Pipe Support RlL No.14 CPRT DSAP IX, Attachment 2, Section D.I.
How will hydrostatic test loads be incorporated into the pipe support and piping qualification program?
1.
Bolt Spocing Pipe Support RIL No. Ii CPRT DSAP IX, Attachment 2, Section D.I.
In certain base plate designs (CC-2-Ol9-715-A43K, for example), the bolt hole dimensions are detailed as "I I/2 MIN TYP" from the edge of the plate. In some cases, this could result in a dimension ranging from I-1/2 to 3-1/2 inches.
1.
How will this range of construction tolerances on bolt holes in base plates be accounted for in the base plate design calculations during the pipe support qualification program?
2.
Will actual as-built edge distances be shown on the drawings?
J.
Cover Plate for Tube End at Moment Joints.
Pipe Support RlL No. 4 CPRT DSAP IX, Attachment 2, Section D.I.
In many support frame designs, moment joints are used for tube-to-tube connections close to open tube ends.
For highly loaded joints, cover plates / stiffener plates may be required to make the moment joint truly effective (i.e. lood & moment transfers).
Will all joints of this type be evoluoted for the need of a cover plate? If not, will onalytical calculations be provided to document the adequacy of all joints of this type?
K.
Methodology For Calculation and Check of Pod, Trunion and Attochment Weld Stresses.
CPRT DSAP IX, Attachment 2, Section D.I.
L.
Discrepancies in Pipe Support Loads Between Analysis and Support Design Pipe Stress RlL No. S CPRT DSAP IX Attachment 2, Section D.S Will SWEC evoluote all pipe support desigr.s with load increases regardless of the magnitude of the increase?
M.
Snubbers Close to Equipment Nozzles Pipe Stress RlL No. 7 CPRT DSAP IX Attachment 2, Section D.6 Cygno noted several snubbers on the Component Cooling Water System (CCW) which were located close to equipment nozzles. Due to their proximity to o
, i NI L F A 1 Texas Utilities Generating Company 7 of 9 3
L 23CPRT-PAS 11111!!!!!!!!!
'::I Project No. 84056
CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued) rigid ottochment point, the dynamic displacements at these locations will be very small such that the snubbers may not perform their intended function.
Does SWEC plan to eliminate these supports as part of the reonalysis effort?
N.
Steam /Woter Hammer Analysis Pipe Stress RlL No. 20 CPRT DSAP IX Attachment 2, Section D.4 1.
Which systems will be analyzed for fluid transients?
2.
Please supply the criterio SWEC will use for mass point spacing and time step sizes in the fluid transient dynamic analysis.
3.
Please supply the criteria which will be used to determine the reasonability of output support loads.
O.
Volve Acceleration and Flange Lood Generic Studies Pipe Stress RIL No. 21 CPRT DSAP IX Attachment 2, Section D.6 As part of the pipe stress reonalysis program will all volves and flanges be checked to determine if volve accelerations and flange loads meet oppropriate allowables?
P.
Support Stiffness Pipe Support Rll No.13 CPRT DSAP IX, Attachment 2, Section D.I.
How will the piping analysis support stiffnesses be evoluoted to assure close correlation to the stiffness of the as-built pipe support configurations?
G.
Closed Observations Pipe Support RIL Nos. 22 and 23 CPRT DSAP IX, Attachment 2, Section D.I.
Several observations concerned either incorrect assumptions made in calculations or engineering judgements which were used in lieu of performing the calculations. These have been closed on the basis of Cygno calculations which demonstrate that the incorrect assumptions or engineering judgement had no impact on design for the supports within the Cygno scope. During the piping reonalysis and support qualification programs it is anticipated that support loods and tiie distribution of individual support forces and moments will change os a result of changes in analysis methodology (e.g. missing mass, mass point spacing), changes in piping loads (e.g. support moss, friction forces), changes in piping geometry (e.g. support removal or modification), and changes in support stiffness. As a consequence, Cygna would like to be assured that these issues will be incorporated for review within the support qualification effort. Several of these issues are:
4<3 r
Texas Utilities Generating Company 8 of 9 Li FJ L h.il 23CPRT-PAS llllllllll115..........llllll Project No. 84056 l
CYGNA QUESTIONS ON CPRT PIPING / PIPE SUPPORT ACTION PLAN (continued) o improper weld calculation for three-sided welds, o
improper weld calculations for composite sections.
o Thermal lock-up of onchors Local stress ef fects (tube, wide flange and channel web crippling) o IV. General Questions A.
Please provide the pipe support design criteria document which will be used for the qualification program.
B.
Please provide the checklist (s) which will be used for pipe support qualification.
C.
What other procedures will be used in the quohficanon program related to pipe supports?
D.
Will the SWEC checklists be fully employed in the evoluotion of 100% of the supports at CPSES.
E.
Will the analyses and designs provided by SWEC become the analyses and designs of record?
1 E
Texas Utilities Generating Company 9 of 9 3
r i d' ' L f Al L
23CPRT-PAS 1lllllllllllllllllllllll111111 Project No. 84056 c'
o
,N CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTION PLAN ITEM NUMBER: X TITLE: MECHANICAL SYSTEMS AND COMPONENTS DISCIPLINE SPECIFIC, ACTION PLAN Cygno agrees with the selection of the AFW system os the system of review for the DSAP. This system is sufficiently complex in the mechanical, electrical and control creas to test the adequacy of the engineering design function ond also includes both safety and non-sofety functions.
In order to assure that the conclusions drawn from this self-initiated review of the AFW system, when combined with the results of the Cygno review of the CCW system, provide o brood-based confidence in the mechanical systems design, some of the following questions and comments are related to the scope of this additional review.
1.
Areas Related to the Scope of the CPRT Plan A.
Review Scope CPRT DSAP X, Section 4.1.4. Page 6 of 33 This section references Toble X-3 for a list of A/E and vendor documents to be used in the evoluotion. The table does not include any reactor building drawings or steam generator dato. To provide consistency with the scope of the plan as stated in Section 3.0 (i.e., inclusion of components inside and outside containment), both of these should be included in this table.
B.
Review Scope CPRT DSAP X, Section 3.0, Page 2 of 33; Table X-1, Page 18 of 33 1.
Per this section, components inside and outside containment are included in the scope of review but the components inside containment are not defined. It is suggested that the flowpath up to and including the steam generator nozzle be included in the scope of review.
2.
Note 2 of this table states that a portion of the feedwater system up to the steam generator nozzle is included in the review. This portion of the review is not addressed in the scope of the plan or indicated on the simplified flow diagram, Figure X-l.
The scope and figure should be revised to include this item.
Texas Utilities Generating Company I of 6 r
j' y s LS ='JLr11 23CPRT-MAT
!!P.. :m
- lll:
Project No. 84056
CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTION PLAN (continued)
C.
Testing Mechanical Systems RIL No. 8 CPRT DSAP X, Section 4.1.3, Page 5 of 33 The plon states that, where assumptions con be verified by test, the test programs or.d results will be reviewed. Does this statement include the review of startup and pre-operational tests? If not, they should be included since they may be the best and most important method of verifying system design.
D.
Heat Removal Copacity Section 4.1.5.3. Page 9 of 33 It is not clear how or what heat removal capability is being evoluoted. The AFWS does not contain any heat exchangers or other heat removal devices, it is designed to supply a specified mass flowrote of water to the steam generator to meet the steam generator heat removal performance requirements. Are the heat removal performance requirements of the steam generator and atmospheric steam dump systems going to be evoluoted by the plon?
E.
High Energy Line Break CPRT DSAP X, Section 4.1.5.9.1. Page !I of 33 Please clarify the extent of the high energy line breal: review. Does the review cover the following: (a) only breaks in the AFW system, (b) breaks in other systems that have on external effect on the AFWS or require it to functic.n, (c) oil HELB, even those that only offect other safe shutdown equipment.
F.
Missile Protection CPRT DSAP X, Section 4.1.5.9.4. Page 13 of 33 Please provide o definition for the phrase "other safe shutdown systems". is it the intent of the review to look at the missile protection design of all safe shutdown systems or just certain systems ossociated with the AFWS? Please provide the criteria or define which systems are within the scope.
G.
Environmental Qualification CPRT DSAP X, Section 4.1.5.9.5. Page 13 of 33 This section states that environmental qualification requirements will be reviewed for correctness of the envelopes but does not address the review of the source of these envelopes. Will the review verify the correctness of input environmental conditions?
l Texas Utilities Generating Company 2 of 6 A
i FI L Project No. 84056
~" '"
CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTION PLAN (continued)
H.
Rodiation Monitors Mechanical Systems RIL No. 2 CPRT DSAP X, Section 2.0, Page 2 of 33 This section excludes area radiation
- monitors, portable radiation instrumentation, and other radiation instruments without control functions.
Since the control function was deleted from the CCW system radiation monitors, they would now not be included in the plan scope. Cygno believes that all process and effluent radiation monitors should be included in the scope to determine if a control function is required.
1.
Mechanical IAP iswes Scope Mechanical Systems Rll Nos. I, 2, 3, 5, 6, 7 & 9 CPRT DSAP X, Section 4.0, Page 4 of 33 The first paragraph, lost sentence states that this plan will address all mechanical issues to determine if they " occur in another system or in the same system when the previous design ossessments did not perform a generic review". Please provide on explanation of the meaning of this statement.
J.
Accident Analyses Mechanical Systems RlL Nos. 5 and 7 CPRT DSAP X, Section 4.l.5.3. Page 7 of 33 is it the intent of the telon to review the Westinghouse occident onalyses, such as small break LOCA ond MSLB, or just to take them os input to the design requirements for the AFW system?
K.
FMEA Mechanical Systems RIL Nos. 5 and 9 CPRT DSAP X, Section 4.1.5.6. Page 10 of 33 The plan indicates that existing FMEA's will be reviewed to determine compliance with the single failure criterio. This should be expanded to include components and support systems not included in the existing FMEA's. The FMEA that is included in the FSAR for the CCW system did not address any of the single failure issues raised by the IAP.
L.
Hozords Protection Mechanical Systems RlL No. 4 CPRT DSAP X, Sections 4.I.5.9.l. through 4.1.5.9.4. Pages I I & 12 of 33 Will the plan include a field walkdown verification of the implementation of the design requirements for hozords protection as described in the referenced sections?
Texas Utilities Generating Company 3 of 6 7i NJ L f AI 23CPRT-MAT 3
L llll1H!!Il1ll1111111llllll111 Project No. 84056
CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTION PLAN (continued)
- 11. Issues, Comments and Questions Related to the CPRT Review Criterio A.
NPSH CPRT DSAP X, Section 4.1.5.2.1. Page 7 of 33 How will the plan consider analysis of vortexing in the suction water source?
B.
Design implementing Documents CPRT DSAP X, Sections 4.1.3., Page 5 of 33; Table X-2, Page 20 of 33 1.
This section references Toble X-2 for a preliminary list of design implementing documents.
Included in this table is the AFW System Technical Description (2323-TD-0206), AFW System Reliability Study (FSAR Port II.El.1), and the AFWS Reliability Study Evoluotion (NUREG-CR-2248, SAND 81-1625).
Why are these documents included as implementing documents since they do not appear to be used as such by G&H? The technical descriptions were not kept up-to-date by G&H and were not considered design basis documents. The reliability studies are more of a design verification type document than on implementing document.
2.
The technical description, FSAR reliability study, and NUREG-CR-2248 listed in Table X-2 do not appear to belong on this list of design implementing documents.
C.
Steam Supply Review Mechanical Systems RlL Nos. 6 and 7 CPRT DSAP X, Section 4.l.5.2.4. Page 8 of 33 in addition to the steam flow requirements mentioned in this section, the plan should also address the design of the steam supply in relation to entrained water, steam line warming, supply volve operating times, volve locations, etc.
These are needed to meet turbine and AFWS operating requirements.
D.
Water Source Volu:ne Mechonical Systems Rll No. 7 CPRT DSAP X, Section 4.1.5.4. Page 9 of 33 How will the plan address water source volume margins, instrumentaton errors, interlocks, and tank nominal versus actual volumes?
Texas Utilities Generating Company 4 of 6 N IU L I A1 23CPRT-MAT Project No. 84056 l111111"'"
1 CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTION PLAN (continued)
III. Other Specific issues, Comments and Guestions A.
Single Failure Criterio Mechanical Systems RIL Nos. 5 and 9 CPRT DSAP X, Section 3.0, Page 3 of 33 The single failure issue addressed in the third porograph of this section is only one of the single failure issues noted by the IAP. Since it is not clear which single failure design problems are covered in the AFW system design, additional information is required to determine if all issues are addressed. This includes assessment of the design for protection from single failures which prevent it from meeting its safety function and also from ones which protect it from failures in other systems which could impact its ability to meet its safety function.
B.
Fire Doors Mechanical Systems RIL No. 4 CPRT DSAP X, Section 3.0, Page 3 of 33 The fif th paragraph states that the IAP issue of non-qualified fire doors is addressed in the "QA/QC Construction Adequacy Plan." However, Cyno is unable to find any reference to this issue in that section of the plan.
C.
Class 5 Piping Mechanical Systems Rll No. 3 CPRT DSAP X, Section 3.0, Page 3 of 33; Section 4.1.5.8, Page 10 of 33 1.
It is not clear how the class 5 piping issue addressed in the second paragraph applies to the AFW system.
Please provide additional information on what class 5 piping interfaces exist in the AFW system.
2.
In order to ossess the applicability of the Class 5 piping review in addressing the LAP issue, more information is required on the quantity of Class 5 piping included in the AFW system, the manner in which it interfaces with the seismic piping in the AFWS, and provisions for isolating it from the seismic piping.
D.
Support Systems Review CPRT DSAP X, Section 4.1.5.7. Page 10 of 33 The review of support systems should include verification that the most up-to-date normal and faulted system heat loads from the AFW ond other systems have been used in the support system design.
E.
Pressure Temperature Ratings Mechanical Systems RIL No. I CPRT DSAP X, Section 3.0, Page 3 of 33 The first paragraph oddresses the LAP concern on component pressure-temperature,rotings not meeting current system operating conditions due Texas Utilities Generating Company 5 of 6 3
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CYGNA COMMENTS ON CPRT MECHANICAL SYSTEMS ACTlON PLAN (continued) to changes caused by the design evolution. This concern is to be addressed by reviewing the AFW system. However, it is not evident that the AFW system has gone through suf ficient changes in design process conditions to odequately test this concern. How will the plan address this issue?
F.
System Interioces CPRT DSAP X, Table X-1, Page 18 of 33 The table does not list any interface associated with cooling of the AFW pump bearings or oil coolers. Unless these items are cooled by the pumped fluid, this interface should be defined in the table.
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CYGNA COMMENTS ON CPRT ELECTRICAL AND l&C ACTION PLAN ITEM NUMBER: XI TITLE: ELECTRICAL /I & C SYSTEMS AND COMPONENTS DISCIPLINE SPECIFIC ACTION PLAN Cygno agrees with the selection of the AFW system and the electrical power supply systems for the DSAP. The addition of the components discussed in porograph 3.2.5.8 results in a system that is sufficiently complex in the electrical and control areas to test the adequacy of the engineering design function and it also includes both safety and non-safety functions. Cygno's questions and comments on the specifics of the plan are provided below, in order to assure that the conclusions drawn from this self-initiated review of the AFW system and electrical power supply systems, when combined with the results of the Cygno review of the CCW system, provide a broad-based confidence in the electrical systems design, some of the following questions and comments are related to the scope of this additional review.
l.
Areas Related to the Scope of the CPRT Plan A.
Overcurrent Protection of Electrical Containment Penetrations CPRT DSAP XI, Section 3.2.5.8, Page 17 of 30 1.
Does the review of containment electrical penetrations include the primary and backup protective devices for 120 VAC and DC loods inside containment?
2.
Is the review of containment electrical penetrations limited to power circuits or does it include control and instrumentation of circuits?
B.
Fire Pump Motor CPRT DSAP XI, Section 3.2.5.3, Page 14 of 30 3.2.5.7, Page 16 of 30 Does the plan include a review of the voltage available at the fire pump motor and the overcurrent protection provided for compliance with the appropriate articles of the NFPA Code?
C.
Coordination of Protective Devices CPRT DSAP XI, Section 3.2.5.7, Page 16 of 30 Does the plan include a review of the coordination of protective devices on the UPS or DC systems?
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I CYGNA COMMENTS ON CPRT ELECTRICAL AND l&C ACTION PLAN (continued)
D.
Separation and Independence of Safety Systems CPRT DSAP XI, Section 3.2.5.9, Page 18 of 30 1.
Does the plan include a review of the electrical system for associated circuited?
2.
Does the plan include a review of the qualification report for isolation devices for the hot-short voltages and short-circuit currents expected?
E.
Inclusion of Cable Ampocity Derating Proctices in the Review of Power Cable Sizing Electrical RIL No. 8 CPRT DSAP XI, Sections 3.2.3,3.2.5.3, Pages 12 and 14 of 30 1.
The Cygno review revealed that the G&H cable ampacity calculations do not show derated cable ampacities for the long term post accident temperatures inside containment. To what extent will the plan review power cables inside containment to verify that the post accident ambients will not result in derated ampacities being less than the required ampocity.
2.
In addition, the plan should include a review of cable ampacity derating practices for fire barrier materials and troy covers. The review should include o verification of the derating factor for the thermo-lag material and that both derating factors are applied if both items are used.
II. Issues, Comments and Questions Related to the CPRT Review Criterio A.
Externally Developed Design Criterio CPRT DSAP XI, Section 3.2.2, Page iI of 30 Cygno has identified cases where Gibbs & Hill calculations have imposed restrictions and requirements on other Gibbs & Hill calculations. How will the plan address the identification of design criterio developed / imposed by calculations outside of the review scope?
B.
AFW Pump Motor Review Mechanical RlL No. 8 CPRT DSAP XI, Section 3.2.5.8, Page 17 of 30 I.
Does the review of the AFW pump motor include motor sizing and food acceleration?
2.
Will the evoluotion of the relay coordination consider the diesel generator's short-circuit capability.
l Texas Utilities Generating Company 2 of 4
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I CYGNA COMMENTS ON CPRT ELECTRICAL AND I&C ACTION PLAN (con?innd) 111.
Other Specific issues, Comments and Questions A.
Transducer and Indicator Ranges and installation CPRT DSAP XI, Section 3.2.5.7, Page 16 of 30 1.
How will the plan verify that transducers and their associated indicators have compatible ranges?
2.
How coes the plan address instrument tubing installations and compliance with the opplicable design criteria?
3.
How will the plan address the review of system flows and flow element orifice plate sizing for compatibility?
B. Single Foilure Criteria for RCP Electrical Penetrations Electrical RIL No. 7 CPRT DSAP IX, Sections 3.2.1, 3.2.5.8, 3.2.5.9, Pages i1,17 and 18 of 30.
The plan does not appear to include o review of the primary and back-up overcurrent protection for the RCP electrical penetration conductors. The plan should verify that the protection system design (from the current transformers to the brecker trip coil including the control power) complies with the single failure criterion.
C.
Inclusion of Storting/ Accelerating Voltages During Review of 480V Motors Electrical RIL No. 6 CPRT DSAP XI, Sectons 3.2.1 and 3.2.5.3, Pages 1I and 14 of 30 The G&H calculations did not study system voltages during 480V motor starting.
How will the plan address the adequacy of system voltages to accelerate 480V loads during conditions discussed in Paragraph 8.3.1.1.1 of the FSAR concurrent with normal grid voltage variations?
D.
Consideration of Offsite Supply in Review of System Voltages and Short Circuit Currents Electrical RIL No. 5 and 6 CPRT DSAP XI, Sections 1.0,2.2, 3.2.1 and 3.2.5.3, Pages I,2,9, and 14 of 30 The Cygno review has identified instances where system voltages are below acceptable levels when fed by the offsite supply. How will the plan address adequacy of system voltages during conditions discussed in Paragraph 8.3.1.1.1 of the FSAR. The Cygno review has also identified instances where bus short-circuit currents may be greater than the equipment's ratings when fed by the offsite supply. How will the poln evoluote short-circuit currents?
Texas Utilities Generating Company 3 of 4 T M}2 11 23CPRT-ES Project No. 84056
d CYGNA COMMENTS ON CPRT ELECTRICAL AND I&C ACTION PLAN (continued)
E.
Protective Relaying and Coordination Calculations Electrical Rll No. 7 CPRT DSAP XI, Sections 3.2.3 and 3.2.5.7, Pages 12 and 16 of 30 The G&H relay setting calculation did not consider the motor's thermal limit nor the transformer's ANSI point in setting the protective devices. How will the plan consider setpoints for adequate load protection and for posssible nuisance tripping?
F.
Electrical System Grounding CPRT DSAP XI, Section 3.2.5.3, Page 14 of 30 1.
The diesel generator and the 480V system is high impedance grounded which limits the ground fault current to o very low value. Does the plan include o review of the ground resistor sizing and the distribution system's capacitance to determine the likelihood and the magnitude of overvoltages during ground faults?
2.
Does the plan include o review of the ground fault detection schemes employed and its ability to detect the low magnitude fault currents expected?
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