ML20211K160

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Rev 0 to Generic Technical Issues Rept,Evaluation & Resolution of Cygna Train a & B Conduit Issues as Applicable to Train C Conduit Supports
ML20211K160
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/31/1986
From:
ABB IMPELL CORP. (FORMERLY IMPELL CORP.)
To:
Shared Package
ML20211K089 List:
References
01-0210-1523, 01-0210-1523-R00, 1-210-1523, 1-210-1523-R, NUDOCS 8611170065
Download: ML20211K160 (94)


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TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS O

PREPARED BY:

TEXAS UTILITIES GENERATING COMPANY GLEN ROSE, TEXAS i

IMPELL CORPORATION l WALNUT CREEK, CALIFORNIA l

IMPELL REPORT NO. 01-0210-1523 REVISION 0 OCTOBER,1986 i

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REPORT APPROVAL COVERSHEET Generic Technical Issues Report - Evaluation and Resolution

$3pgrt h of CYGNA Train A and B Conduit Issues As Aopli_ cable to Train C Conduit Supports Report Number. 01-0210-1523 Revision: o Cgggt Texas Utilities Generatino Co. Job Nwnber: 0210-osa-13ss t

hoject: Train C Conduit l

l RECORD OF REVl8DN g' REVSON DATE PREPARED REVEWED APPROVED p to//6/4 dihh M y A. % 'y /d/ ,

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TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION 1 0F CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS TABLE OF CONTENTS PAGE TITLE PAGE REPORT APPROVAL COVER SHEET i

! 11 TABLE OF CONTENTS LIST OF GENERIC TECHNICAL ISSUES iii I INTRODUCTION 1 ISSUE RESOLUTION PROCESS 1 II

III REPORT ORGANIZATION AND ISSUES PROCESS 2 IV ABBREVIATIONS 2 O Y REFERENCES 2 APPENDICES O

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TEXAS UTILITIES GENERATING COMPANY COMANCHE i EAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION O 0F CYGNA TRAIN A AND B CONDUIT ISSUES U AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS LIST OF GENERIC TECHNICAL ISSUES APPENDIX ISSUE TITLE 1 Governing Load Case for Design 2 Dynamic Anplification Factors 3 Combination of Deadweight and Seismic Responses 4 Measurement of Embedment from Top of Topping 5 Bolt Hole Tolerance and Edge Distance Violation 6 FSAR Load Combinations 7 Support Self Weight 8 Torsion of Unistrut Members 9 Improper Use of Catalog Components 10 Anchor Bolts 11 Longitudinal Loads on Transverse Supports O 12 siiti-xwik Boit Substitutions 13 Substitution of Smaller Conduits on CA-Type Supports 14 Use of CA-Type Supports in LS Spans 15 Stresses in Cable Trays Due to Attached Conduit Supports 16 Increases in Allowable Span Lengths 17 Substitution of Next Heavier Structural Member 18 Clamp Usage 19 Documentation Deviations Between Inspection Reports, CMC's and IN-FP Drawings 20 Nelson Studs 21 Conduit Fire Protection Calculations 22 Span Increase for Fire Protected Spans 23 Grouted Penetrations 24 Rigidity of CA-Type Supports 25 Enveloping Configurations for Design i 26 Design Drawing Discrepancies 27 Walkdown Discrepancies O 28 29 syste=> coacePt Cumulative Effect of Review Issues 111

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TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS I. INTRODUCTION Texas Utilities Generating Company (TUGCo) has undertaken an extensive program to resolve the TUGCo Technical Review Team (TRT) Issue 1.C regarding Train C conduit two inch and under. The TRT examination showed that the support installation for non-safety related conduits less than or equal to 2 inches was inconsistent with seismic requirements and no evidence was found that substantiated the adequacy of the installation for non-safety related conduit of any size. According to Regulatory Guide 1.29 and the CPSES FSAR Section 3.78.2.8, the Seismic Category II and non-seismic items should be designed in such a way that their failure would not adversely affect the function of safety-related components or cause injury to plant personnel.

A plant inspection shall be performed to verify the adequacy of all Train C Conduit Supports. Impell Corporation has developed a screening process which will be used to qualify all supports for seismic loads or to verify that adverse interactions with safety-related features do not occur.

Some generic support types will be screened out of the population as acceptable by inspection. Other supports will be screened out and shown to be acceptable based on analyses. The remaining supports will be modified to meet an acceptance criteria for seismic loads.

Prior to the Train C seismic qualification program, the Train A and B i conduit work has undergone a detailed independent assessment program (CYGNA). As a result of this review, a list of design concerns has been identified (Reference 1). These concerns have been reviewed to determine their applicability to Train C conduit work. Where applicable, steps are taken to address conditions or situations of a similar nature. All applicable concerns will be addressed by the Train C conduit program through its associated plant inspection, analysis, design, and construction activities.

This report is a working document developed by Impell to provide a map of the methods used to resolve each independent review issue. As a working document it will progress with the project and will be updated as further studies and development efforts to address particular issues are completed .

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II. ISSUE RESOLUTION PROCESS The following steps were taken to evaluate and resolve each of the generic technical issues:

1. Impell reviewed tne summary reports issued by Cygna on the Train A and B conduit work. Impell then summarized its understanding of the issue.
2. Impell reviewed each issue on Train A and B to determine its applicability to the Train C work. For issues which may have potential' impact on the Train C work, an approach was developed to resolve the isste. The approach consisted of procedures development, special study definition and implementation. For issues not applicable to the Train C work, no action is required.
3. The resolution for each applicable generic technical issue is then
implenented. .

III. REPORT ORGANIZATION AND REVISION PROCESS The body of this report describes the background and approach to evaluate and resolve Train A and B technical issues as applicable to design verification of Train C systems by Impell . A separate Appendix has been O 8eveioned for eaca seae'ric techaicei issue- eaca anneadix faciudes a sumary of the issue background, the Impell understanding of the issue, the action plan to resolve the issue, a complete list of relevant documents reviewed by Cygna or other external reviewers, and the Impell implementation of the resolution. The background section is a verbatim reproduction of the sumary section in the Cygna RIL. References quoted in this section refer to the list of relevant documents reviewed by Cygna summarized in Section 4.0 of each Appendix. The implementation section contains detailed references to appropriate sections and revisions of criteria, procedures, special study, or test program documentation which resolve the generic technical issue. These references are summarized in

Section V.

r IV. ABBREVIATIONS l

The following abbreviations have been used in this report:

t AISC: American Institute of Steel Construction

CCL
Corporate Consulting & Development Company, Ltd.

CPSES: Comanche Peak Steam Electric Station l

l DAF: Dynamic Amplification Factor Final Safety Analysis Report

( FSAR:

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O MMF: Multi-Mode Factor OB E: Operating Basis Earthquake RIL: Review Issues List SRSS: Square-Roo t-o f-th e-Sum-o f-th e-Squa re s SSE: Safe Shutdown Earthquake TRT: Technical Review Team TUGCo: Texas Utilities Generating Company ZPA: Zero Period Acceleration Y. REFERENCES

1. Letter No. 84056-095 from N. H. Williams (Cygna) to W. G. Counsil (TUGCo) dated November 26, 1985,

Subject:

Review Issues List (RIL),

Texas Utilities Generating Company, Comanche Peak Steam Electric Station, Independent Assessment Program - All Phases.

2. Impell Project Instruction " Seismic Evaluation of Train C Supports",

Project Instruction No. 0210-052-003, Revision 1, Job No.

q 0210-052-1355, Impell Corporation, Walnut Creek, CA,1986.

V 3. Impell Calculation No. ROTC-06, " Multi-Mode Factor Evaluation -

Train C Conduf t", Revision 1, Job No. 0210-052-1355.

4. Impe11 Project Instruction " Multi-Level Screening Criteria for Train C Conduit (Two Inch and Under) at Comanche Peak Steam Electric l

Station", Project Instruction No. 0210-053-001, Revision 5, Job No.

0210-053-1355, Impell Corporation, Walnut Creek, CA,1986.

5. Comanche Peak Steam Electric Station Final Safety Analysis Report, Section 3.0.
6. " Test Report for Static Testing of Train C Beam Clamps and Unistrut Hangers for CPSES", CCL Report No. A-720-86, July 10,1986.

! 7. Impell Calculation No. ROTC-02, " Prying Factors," Revision 0, Job

No. 0210-052-1355.

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8. Impell Project Instruction " Rigorous Analysis of Train C Conduit",

Project Instruction No. 0210-052-006, Revision 1 Job No.

0210-052-1355.

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9. Impell Report No. 01-0210-1479, Rev.1, " Comanche Peak Steam Electric Station, Train C Conduit Two Inch and Under Criteria l Document," June,1986.

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10. Impell Project Instruction, " Dynamic Analysis of Cable Tray S stems" Project Instruction No. PI-02, Revision 4, Job No.

0 10-040,

11. Impell Calculation No. ROTC-28, " Evaluation of Moment Loadings an Anchor Bolts", in progress.
12. CCL Report No. A-699-85, " Conduit Clamp Test Report, Phase I", dated 12/17/85.
13. CCL Report No. A-702-86, " Conduit C1 amp Test Report, Phase II",

dated 4/7/86.

14. Impell Report 09-0210-0017, "CPSES Cable Tray System analysis / Test Correlation", In Progress.
15. " Test Plan - Dynamic Testing of Typical Cable Tray Support Configurations", Document No. A-000150 Rev.1, December 1986 by ANCO Testing Laboratory.
16. Impell Special Study No. 5.9, " Oversize Bolt Holes", Preliminary Issue.
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1 TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 1 CYGNA ISSUE NO.1: GOVERNING LOAD CASE FOR DESIGN O

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APPENDIX 1 CYGNA ISSUE NO.1: GOVERNING LOAD CASE FOR DESIGN O

1.0 BACKGROUND

Gibbs & Hill used the equivalent static method to design the condJit supports. In all load cases, the equivalent static accelerations used in designing the supports for SSE events are less than 160% of the corresponding accelerations for 1/2 SSE (OBE) events. Based on this finding and citing Section 3.8.4 of the CPSES FSAR which allows a 60%

increase in allowables for structural steel between OBE and SSE events, Gibbs & Hill determined that the design was governed by the OBE event.

To validate this conclusion, the 60% increase in allowables must be liberally interpreted to be applicable to all support components rather than applicable only to structural steel as specified in the CPSES FSAR.

Catalog items such as Unistrut components and Hilti expansion anchors do not have increased allowables for SSE events. By designing these catalog components to the OBE event, the manufacturer's design factor of safety is not maintained for the SSE event.

Furthermore, for the design of structural steel, the 60% increase in allowables is acceptable for axial and strong-axis bending stresses in structural members. The 60% increase cannot be applied to certain other allowable stresses. For example, the maximum increase in baseplate stresses may only be 33%, at which point the material yield is reached.

A limit on maximum allowable stress is not provided in the FSAR.

These limitations were not considered in the selection of the governing seismic load case.

2.0 UNDERSTANDING 0F THE ISSUE OBE (1/2 SSE) was used as governing load for all supports, based on the ratio of corresponding SSE to OBE accelerations and provision of Section 3.8.4 of the CPSES FSAR which allows a 60 percent increase in allowables for structural steel between the OBE and SSE events.

To validate this conclusion, the 60 percent increase in allowables must be interpreted to be applicable to all support components rather than to structural steel only. However, this increase is not applicable to some components, anchor bolts for example, and even to some structural steel stresses, baseplate stresses for example.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Train C Supports have been evaluated for SSE loads only (Reference 9).

Appropriate SSE stress allowables for structural steel, welds, anchorages and catalog items have been used to assure structural integrity.

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APPENDIX 1

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CYGNA ISSUE NO.1: GOVERNING LOAD CASE FOR DESIGN (Cont'd)

O OBE considerations are not required except for fatigue evaluation.

Cumulative fatigue usage factors due to both OBE and SSE load cycles are determined and compared to the available fatigue life of the components.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Comunications Report between R. Kissinger (TUGCO), B. Bhujang (Gibbs & Hill), and J. Russ and N. Williams (Cygna) dated 10/1/84.
2. CPSES FSAR, Sections 3.8.3 and 3.8.4.

5.0 IWLEMENTATION OF THE RESOLUTION Section 4.2.1 of Impell's Project Instructions (Reference 2) describes the loads to be considered for the Train C conduit support evaluation.

For elastic evaluation, the structural integrity of Train C conduit supports are demonstrated by considering SSE seismic loads in combination with gravity loads and the corresponding SSE stress criteria. For simple nonlinear evaluation, cyclic loading as a result of both OBE and SSE are considered in fatigue evaluation.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 2 CYGNA ISSUE NO. 2: DYNMIC AMPLIFICATION FACTORS O

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APPENDIX 2 CYGNA ISSUE N0. 2: DYNAMIC AW LIFICATION FACTORS

1.0 BACKGROUND

Reference 4 specifies that a dynamic amplifications factor (DAF) of 1.5 be used unless otherwise justified. Gibbs & Hill submitted a calculation demonstrating a DAF of 1.0 for both cable tray and conduit runs. That calculation was based on a Class 5 piping damage study.

A reanalysis was performed for cable tray runs (see Cable Tray Review Issue 8), which established 1.14 as an acceptable DAF for the design of supports (with certain restrictions). Cable Tray Review Issue 25 identifies the need to perform a reanalysis to address the DAF for tray stress as well.

2.0 UNDERSTANDING 0F THE ISSUE A DAF of 1.0 was used by Gibbs and Hill for the design of conduit supports. The DAF was not justified by an appropriate method.

3.0 ACTION PLAN TO RESOLVE THE ISSUE The Gibbs and Hill calculations have not been used as the basis for justifying the use of MFs (Impell equivalent terminology for DAFs) less than 1.5. Impell has provided justification for the use of a lower MMF p in certain situations. A MF of 1.0 shall be used if the fundamental v system frequency is greater than 33 Hz or the rigid cut-off frequency of the appropriate floor response spectrum. A MF of 1.25 shall be used if the fundamental system frequency is less than or equal to 33 Hz or the rigid cut-off frequency, the conduit run is straight (no elbows or offsets) and the conduit does not behave like a cantilever. A MMF of 1.5 shall be used for all other cases.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Communications Report between P. Huang (Gibbs & Hill) and J. Russ (Cygna) dated 2/5/85.
2. Communications Report between P. Huang (Gibbs & Hill) and J. Russ l

(Cygna) dated 2/6/85.

l 3. Gibb & Hill Calculation 2323-SCS-100C, Set 4, Sheets 1-11.

4. CPSES, FSAR, Section 3.78.3.5.

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APPENDIX 2 CYGNA ISSUE N0. 2: DYNAMIC AWLIFICATION FACTORS (Cont'd) 5.0 IWLEMENTATION OF THE RESOLUTION Impell Project Instructions (Section 4.1.3, Reference 2) define the MMFs .

to be used for the Train C~ conduit evaluation. The basis for the values

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! GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES i AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS  !

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! APPENDIX 3 i CYGNA ISSUE N0. 3: COMBINATION OF DEADWEIGHT AND SEISMIC RESPONSES l i

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APPENDIX 3 CYGNA ISSUE NO. 3: COMBINATION OF DEADWEIGHT AND SEISMIC RESPONSES

1.0 BACKGROUND

In all Gibbs & Hill design calculations, the acceleration due to deadweight is combined with the seismic accelerations using the SRSS method. A 1.0 g deadweight acceleration is first added to the vertical seismic acceleration. The sum is then combined with the two horizontal seismic components using the SRSS method.

Gibbs & Hill has submitted calculations which compare the acceleration vector magnitudes calculated with the standard combination method and with the SRSS method. For most buildings and elevations, the magnitude of the resultant acceleration using the SRSS method does not differ significantly from the resultant using the standard combination method.

However, the difference in vector direction was not considered and is of greater importance, since each load direction contributes to different components of response in the conduit supports. To properly assess the impact of this combination method, the critical response should be evaluated instead of the magnitude of the acceleration applied to the support.

2.0 UNDERSTANDING OF THE ISSUE Accelerations due to deadweight and seismic were combined using SRSS method.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Absolute summation method has been used to combine deadweight and seismic loads.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Gibbs & Hill Calculation 2323-SCS-109C, Set 1, Sheets 154-163.

5.0 IMPLEMENTATION OF THE RESOLUTION The SRSS method to combine deadweight and seismic accelerations has not been used. Stresses or loads due to deadweight and seismic effects have been added absolutely. The Impell procedure is described in Section 4.2.2 of Reference 2.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 4 CYGNA ISSUE NO. 4: MEASUREMENT OF EMBEDMENT FROM TOP OF TOPPING

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APPENDIX 4 g CYGNA ISSUE NO. 4: MEASUREMENT OF EMBEDMENT FROM TOP 0F TOPPING V

1.0 BACKGROUND

Note 5a on Gibbs & Hill Drawing 2323-S-0910, Sheet G-4a allows reduced expansion anchor embedment for certain supports at lower building elevations. SDAR CP-80-05 states that the integrity of the architectural topping cannot be assured, thus evaluation of all affected designs must be made to satisfy the corrective action requirements of the SDAR. Cygna has not reviewed any design calculations resolving the above-mentioned note with the implications of the SDAR. The generic design calculations do not address the note.

Such a reduction in anchor embedment is not acceptable for 1/4" and 3/8" Hilti-Kwik bolts with 2" embedment requirement, since these bolts are embedded in topping only. Additionally, Hilti does not manufacture a 1/4" Kwik bolt of sufficient length to accommodate the 2" topping and the 2" minimum embedment in structural concrete.

The anchor embedment reduction may not be acceptable for other sizes of Hilti-Kwik bolts, depending on the actual accelerations applicable to the floor-mounted supports versus the design accelerations. The affected support types within Cygna's scope are the CSM-18 series and CST-17.

2.0 UNDERSTANDING 0F THE ISSUE n

U Gibbs & Hill drawings 2323-S-0910 allows the consideration of topping thickness in determining the expansion anchor embedment for certain supports. However, integrity of architectural topping cannot be assured.

3.0 ACTION PLAN TO RESOLVE THE ISSUE For supports located on the floor, topping have been identified through as-built walkdowns and review of structural drawings. Embedrr,ent length l

due to floor topping has been discounted.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. SDAR CP-80-05, "Use of Architectural Concrete in Floor Slabs," dated August 8, 1980.
2. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCO), " Cable Tray / Conduit Support Review Questions," 84056.094, dated October 30, 1985.

5.0 IMPLEMENTATION OF THE RESOLUTION Impell's walkdown Project Instructions (Part II, Reference 4) and analysis Project Instructions (Section 4.3.5, Reference 2) explicitly specifies that floor topping is to be accounted for in embedment calculations, and the anchor bolt capacity to be reduced accordingly.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND 8 CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 5 CYGNA ISSUE N0. 5: BOLT HOLE TOLERANCE AND EDGE DISTANCE VIOLATION

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APPENDIX 5 CYGNA ISSUE N0. 5: BOLT HDLE TOLERANCE AND EDGE DISTANCE VIOLATION O

1.0 BACKGROUk]

A. Reference 1 allows bolt hole tolerances which vary with the bolt size, whereas the AISC Specifications provide zero bolt hole tolerances . Therefore, the bolt holes in Gibbs & Hill designs should be considered oversized and should be treated as such in bearing connection calculations.

B. Reference 2 requires that a minimum clear distance be maintained for oversize holes. Some Gibbs & Hill designs do not provide the minimum edge distances required in the AISC Specifications. For example, support types CA-Sa and CSM-42 provide edge distances of 3/4". Per Reference 2, 25/32" is required.

2.0 UNDERSTANDING OF THE ISSUE A. Gibbs & Hill allows bolt hole tolerances, whereas AISC provides zero tolerance. Evaluate connection as oversized.

B. AISC requires minimum edge distance be maintained for oversize holes. Gibbs & Hill drawings do not always provide this.

3.0 ACTION PLAN TO RESOLVE THE ISSUE O A. The effects of oversized bolt holes have been generically considered in the cable tray hanger design verification through analytical work and interpretations of available test data. It has been determined that oversize bolt holes have insignificant effect on component capacities and may actually contribute to decreased dynamic response.

B. The available edge distances will be generically justified by evaluating plate stresses for bearing type connection.

! 4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Gibbs & Hill Drawing 2323-S-0910, Sheet G-lb, Note 15.
2. AISC Specifications, 7th Edition, Section 1.16.5, Minimum Edge Dis tance.
3. AISC Specifications, 7th Edition, Section 1.23.4, Riveted and Bolted Construction - Holes.

5.0 IMPLEMENTATION OF THE RESOLUTION References 14 and 15 will investigate the effects of oversize bolt hol es . Reference 16 is investigating load distribution in connections with oversize bolt holes.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 6 CYGNA ISSUE NO. 6: FSAR LOAD COMBINATIONS i

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APPENDIX 6 CYGNA ISSUE N0. 6: FSAR LOAD COMBINATIONS

1.0 BACKGROUND

Cygna is concerned that all applicable loads, as defined in Reference 1, were not explicitly considered in the conduit support designs.

These concerns include loads due to pipe whip and jet impingement as well as the use of design accelerations which do not envelop Containment Building and Internal Structure spectra.

2.0 UNDERSTANDING 0F THE ISSUE All load cases, as required by FSAR were not explicitly considered (eg.,

pipe whip, jet impingement, as well as use of design accelerations which do not envelope Containment Building and Int. Structure Spectra). -

3.0 ACTION PLAN TO RESOLVE THE ISSUE FSAR requires evaluation of non-safety related conduits only for the SSE load (see Section 3.2.1.2, Reference 5). Impell has met this FSAR requirement. Also, where the conduit systems are attached to both Containment and Internal Structure, Impell has enveloped Containment and Internal Structure spectra for evaluation of Train C conduit.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. CPSES FSAR, Section 3.8.4.3.3 5.0 IffLEMENTATION OF THE RESOLUTION The Criteria Document (Section 4.3, Reference 9) specifies that the evaluation of Train C conduit is only required for the SSE load. Al so ,

Impell Project Instructions (Section 4.6.2, Reference 8) define the spectra being used for the evaluation.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 7 CYGNA ISSUE N0. 7: SUPPORT SELF WEIGHT O

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APPENDIX 7

. CYGNA ISSUE NO. 7: SUPPORT SELF WEIGHT G

1.0 BACKGROUND

Cygna's review has noted that support self weights were not uniformly considered in the various ~ designs. For most CA-type supports, the support weight is negligible and was not included in the calculation of support loads. For the CSM- and CST-type supports in the review scope, part or all of the self weight was neglected in the designs. The omitted self weight may be an insignificant portion of the total load on the support; however, for most designs, the anchor bolts are designed to an interaction ratio of 1.0. Any additional load will produce unacceptable interaction ratios over 1.0.

In the design of the CSM-6b, CSM-18 series, and CSM-42 supports, only a portion of the support weight was considered. The CSM-6b support is a braced cantilever configuration composed of Unistrut members. The weight of cantilever member was included in the load calculation, but the weight of the brace member was neglected. For most of the supports composed of structural tubes (CSM-18 series and CSM-42), the member length considered in the calculation of self weight was taken as the length from the base plate to the conduit centerline. The additional length from the conduit to the free end of the cantilever was neglected.

For the CST-3 and CST-17 Unistrut support designs, the total support self weight was neglected. For larger support frames, the tributary conduit pJ

s. weight capacity is quite small, and the self weight can be a large portion of the total load on the support.

2.0 UNDERSTANDING OF THE ISSUE Support self-weight was sometimes not considered, or unconservatively considered. Some such supports have anchor bolt interaction ratios of 1.0. Any additional load will produce unacceptable interaction ratios over 1.0.

3.0 ACTION PLAN TO RESOLVE THE ISSUE l

Support weight is explicitly considered in Impell calculations for Train C conduit supports. The only Gibbs & Hill calculations used to substantiate Impell criteria are for Type 6 supports and they have been reviewed to identify any such impact on the screening criteria.

Additional analyses are being performed by Impell to confirm the Type 6 support screening criteria, and to eliminate any dependence on the Gibbs

& Hill calculations.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Cygna Generic Conduit Support Review Checklists (not yet issued)

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APPENDIX 7 CYGNA ISSUE N0. 7: SUPPORT SELF WEIGHT (Cont'd)

O 5.0 IWLEMENTATION OF THE RESOLUTION Impell analysis and walkdown Project Instructions require the consideration of support self-weight in the support evaluation (Section 4.2.1 of Reference 2 and Part II of Reference 4). Significant restrictions and limitations in span lengths and total weight exist where the screening criteria for Type 6 supports are presently based on the Gibbs & Hill calculation. Impell is in the process of confirming these criteria independently of Gibbs & Hill's analyses.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 8 CYGNA ISSUE NO. 8: TORSION OF UNISTRUT MEMBERS O

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APPENDIX 8 CYGNA ISSUE N0. 8: TORSION OF UNISTRUT MEMBERS q

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1.0 BACKGROUND

Torsional loading of Unistrut member is not considered in the support designs. Unistrut does not support the use of members for torsional loading. Since analysis of asymmetric sections is difficult, testing of the members was proposed.

TUGC0/Gibbs & Hill are evaluating the effects of torsion in Unistrut components by a support qualification test program (References 6 and 7).

Cygna personnel visited the CCL test labs (References 5, 6, and 7) and provided the following coments on the test scope and procedures:

1. Enveloping of Conduit Supports:

- TUGC0/Gibbs & Hill assume that the group of tested conduit supports adequately envelops all generic type supports at CPSES. Detailed documentation is required to assure the validity of this assumption. The documentation should address the weak link of each enveloping support and how the tests correlate with the perceived weak link of each support qualified by comparision.

- The conduit support test scope does not address concerns from

' the Review Issues List. When screening each support to pV determine the enveloping group to be used in the test scope, l

all applicable concerns from the Review Issues List should be included in the comparison of design and configurational requirements.

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- The effect of applicable generic and support-specific design changes should be addressed in the qualification test program. ,

2. Worst case support configuration and loading for the tested support:

l - The chosen member lengths and load magnitudes and directions may not be the critical case. Cygna noted that the selected configurations may not adequately address torsional behavior of the generic support design.

- The choice of larger diameter conduits in the testing of some supports resulted in the testing of C708-S clamps. P2558 clamps were not tested in the majority of the support configurations.

- Clamp loadings should induce tensile forces in the clamp bol ts. Many tests load the members in bearir.g instead of maximizing clamp load.

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APPENDIX 8 CYGNA ISSUE NO. 8: TORSION OF UNISTRUT MEMBERS (Cont'd) v

3. Test Procedures:

- In the visit documented in Reference 5, Cygna noted that a yoke plate had impinged upon an outrigger, which imparted additional, unintended forces into the support. The effect of this additional load must be considered when reducing the test data.

- In the visit to the test lab documented in Reference 6, Cygna noted two discrepancies in the test setup. The hydraulic ram which applied the transverse and vertical load was attached in a manner such that longitudinal conduit displacement rotated the ram from the perpendicular. Due to this rotation, a force in the longitudinal conduit direction was imparted in a direction opposite to the load applied by the longitudinal conduit direction was imparted in a direction opposite to the load applied by the longitudinal ram. The impact of the effective reductions in the longitudinal and transverse forces should be addressed in the data reduction.

Cygna noted that in a test of a conduit support using detail CSD-la (Reference 6), the supporting wide flange beam to which the detail was attached via a strainsert bolt was not sufficiently stiffened to prevent a deflection in the flange s due to a rotation in the connection detail . Technical justification should be given for the ability of the support member flanges to resist bending due to imparted connection moments without significant deflection. Otherwise, the effect of flange deflections must be considered in the data reduction.

- Strainsert bolts were used to anchor the specimens to the test fixture. These bolts were preloaded to 3200 lbs. for all test cases. Cygna is concerned that the preload used may not be applicable for all test cases. The supports employ expansion anchors of various diameters and embedments, which implies a range of allowable bolt tensions. Additionally, use of a preload will affect the support stiffness and hence any deflections measured in the test.

l In addition to the testing scope, Gibbs & Hill is also reanalyzing I supports which are not subjected to torsional loads using AISI code provisions. Gibbs & Hill intends to address the adequacy of the majority of conduit support designs utilizing Unistrut members by either testing or analysis, t

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APPENDIX 8 CYGNA ISSUE NO. 8: TORSION OF UNISTRUT MEMBERS (Cont'd)

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U 2.0 UNDERSTANDING OF THE ISSUE

- Selection of conduit support test configurations to envelope all generic support types at CPSES was not documented.

- Test scope did not address applicable concerns from the RIL.

- Worst case support configuration and loading for the tested supports may not have been selected.

Test procedure inadequacies were identified. As a result of these inadequacies, additional unintended loadings were imparted to the test supports.

3.0 ACTION PLAN TO RESOLVE THE ISSUE The above comments are very specific to the Train A and B test program conducted by Gibbs and Hill and CCL. Impell has not applied these Train A and B test data to the Train C conduit qualification. Impell has und'ertaken an independent test program for Train C conduit.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) lette' to J.B. George (TUGCO), "Cygna Study of O uaistrut Torsioae' cePecity." 84oss o4o. detea ae#uery '8. '985-
2. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCO), " Cable Tray / Conduit Support Review Questions," 84056.094, dated October 30, 1985.
3. Communications Report between R. Kissinger (TUGCO) and J. Russ (Cygna), dated 1/8/85.
4. Communications Report between S. McBee (TUGCO) and J. Russ (Cygna),

dated 2/21/85.

5. Communications Report between R. Miller (CCL), R. Kissinger and S. McBee (TUGCO), and J. Russ and N. Williams (Cygna), dated 2/25/85.
6. Communications Report between R. Kissinger and S. McBee (TUGCO),

R. Miller (CCL), and D. Leong, J. Russ, and N. Williams (Cygna),

dated 4/9/85.

7. Communications Report between R. Kissinger and S. McBee (TUGCO),

P. Huang (Gibbs & Hill), R. Miller and R. Yow (CCL), and D. Leong and J. Russ (Cygna), dated 4/10/85.

5.0 IMPLEMENTATION OF THE RESOLUTION Reference 6 describes the testing performed to date by Impell for the Os Train C conduit program. Unistrut torsion induced stresses were replicated for field conditions in the testing.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 9 CYGNA ISSUE NO. 9: IMPROPER USE OF CATALOG COMPONENTS O

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APPENDIX 9 CYGNA ISSUE N0. 9: IMPROPER USE OF CATALOG COMP 0NENTS

1.0 BACKGROUND

A. In addition to Cygna's comments on the implicit increase in allowables for SSE loads (see Review Issue 1), Cygna has other concerns regarding the support designs using catalog components.

AISC-derived allowables are used in the design process. These values are generally conservative for bending, but are generally unconservative for axial allowables, as catalog allowables are based on the AISI Code which considers buckling of thin, open sections.

Examples of Cygna's concern are discussed below:

CSM-6b: 20 ksi was used for Fa, the axial allowable. This value is equal to .6 Fy, where Fy = 33 ksi and was used for any member length without considering slenderness effects. Catalog values range from 5.77 ksi for a brace length of 60" to 13.9 ksi for a 24" brace.

CST-3: The design employed the AISC table of axial stress allowables for 36 ksi steel, r -

CST-17: The design employed the AISC tables of axial stress

\ allowables for 36 ksi steel . The table value was then reduced by a ratio of 33/36.

B. Components were used in ways not intended by the vendors.

Cygna concerns in this area are as follows:

Allowables are not listed for P1001C3 sections in the Unistrut catalog. Member properties are given for the X-Y axes instead of the principal axes. Discussions with Unistrut indicate that the uses of P1001C3 are unique with respect to load application and member restraint. Thus, no generic allowables can be provided. Unistrut places the l

burden on the designer to properly consider the capacity of I the section for its intended use. Gibbs & Hill has not l provided adequate evaluation of these members.

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The Unistrut catalog indicates that the intended use of l P1325, P1331, P1332 brackets is for single members in a pinned connection. Gibbs & Hill uses two brackets on double l members, which Cygna believes to be a moment resisting l

connection. Gibbs & Hill considers these connections pinned l for some brackets in CSM-6b, CST-3, and CST-17 supports.

Unistrut does not provide allowables for this bracket configuration.

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APPENDIX 9

,, .3 CYGNA ISSUE NO. 9: IMPROPER USE OF CATALOG COMPONENTS (Cont'd)

U Gibbs & Hill references Unistrut Test C-49 to obtain allowables for the double bracket connection in CST-3. The designed connection is subject to tensile and shear loads.

The test provided data for loading the bracket in tension only. Gibbs & Hill compared the calculated tensile load to the allowable, ignoring the calculated shear.

P1941 plate connectors are used to connect headers to outriggers in CA-la and CA-2a supports. Gibbs & Hill calculations indicate that tightening the Unistrut bolts to the specified torque overstresses the plate and causes excessive bowing of the plate. Discussion with Unistrut indicates that these connectors are to be used to construct frames where the connected members are restrained at both ends. Clarification of this concern is required for CA-la and CA-2a supports, since the member end restraint required by Unistrut has not been provided. Evaluation of the connection to transfer the required load was not performed.

In Revision 1 of Gibbs & Hill Drawing 2323-S-0910, Sheet CA-la, Note 7 was added to provide P1064 plates if bending of the P1941 plates occurs. In Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37, a discussion of field installation practice documents that the P1064 plates do not reduce the J bowing of the outriggers. Unistrut tests showed no bowing of the outriggers when the P1064 plates were used. Verification of the bolt torques used in the test setup is required.

Four types of Superstrut clamps are specified for use on conduit suppcrts: C708, C708-U, C708-S, and modified C708-S (see Review Issue 18). These clamps are not designed for three-directional loading but are used in that capacity.

Allowables for tensile loading only are given in the Superstrut Catalog.

2.0 UNDERSTANDING 0F THE ISSUE A. Axial allowables are unconservative due to the use of 36 ksi vs. 33 ksi for steel yield strength, and the lack of buckling consideration.

B. Components were used in the following non-standard ways:

- Evaluation of P1001C3 Unistrut sections is inadequate.

- Unistrut double brackets were assumed to be pinned connections. Cygna believes this to be a moment connection.

- Shear loads on double bracket connection were ignored.

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APPENDIX 9 CYGNA ISSUE NO. 9: IMPROPER USE OF CATALOG COMPONENTS (Cont'd)

O - Superstrut clamps were designed for 3-D loading. Only tensile load allowables were provided.

3.0 ACTION PLAN TO RESOLVE THE ISSUE A. The Impell Project Instructions define allowables to be used for cold-formed structural members..

B. Impell walkdown procedures specify the various support configurations which can be qualified by walkdowns. Use of components in non-standard ways will be disqualified or screened out for further evaluation or modified.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Comunications Report between P. Patel et al. (Gibbs & Hill) and J. Russ, et al . (Cygna), dated 9/20/84.
2. Comunications Report between D. Kissinger (TUGCO) and N. Williams (Cygna), dated 10/11/84.
3. Communications Report between E. Irish (Unistrut) and D. Leong and J. Russ (Cygna), dated 1/21/85.

O 4. Communications Report between E. Irish (Unistrut) and D. Leong and J. Russ (Cygna), dated 2/4/85.

5. Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37.
6. Cygna Generic Conduit Support Review Checklists (not yet issued).

5.0 , IMPLEMENTATION OF THE RESOLUTION A. Impell Project Instructions (Section 4.3.2 Reference 2) define the allowables for cold-formed structural members, using the AISI yield stresses and with due consideration of buckling failure mode.

B. Impell walkdown Project Instructions (Part II, Reference 4) specify all acceptable support configurations. Components used in non-standard ways will be screened out for further evaluation or modi fied. Justification for acceptable support configurations will be provided in Impell calculation files for each support type.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 10 CYGNA ISSUE NO. 10: ANCHOR BOLTS 5

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APPENDIX 10 CYGNA ISSUE NO. 10: ANCHOR BOLTS l

l.0 BACKGROUND Cygna has the following concerns regarding anchor bolt designs: j A. For the conduit support designs reviewed, Gibbs & Hill was inconsistent in the treatment of prying of concrete attachments on anchor bolt tension. The increase in anchor bolt tension was handled in one of three ways:

- In some support designs, prying was neglected.

- For most supports with baseplates, a prying factor of 1.5 was used. For this case and the one above, justification for the assumed prying factor or the lack thereof was not provided by Gibbs & Hill.

- In a few other support designs, the method on pages 4-89 to 4-90 of the 8th Edition AISC Manual of Steel Construction was used to justify the use of a prying factor of 1.0. For this '

case, justification of the applicability of the method is required, since the concrete attachments in the conduit support designs differ from the steel-to-steel connections addressed in the 8th Edition Method.

O 8- The coacrete coaaectioas for coaauit support cst-17. Type 17 coas4st of box brackets around the P5000 header members, through which the Hilti-Kwik bolts pass. The header is 3.25 inches deep, and the anchor bolt is loaded at a considerable distance above the concrete surface. The Gibbs & Hill design does not consider moments induced in the anchor bolt due to shears applied above the concrete surface.

C. In the design of CA-2a supports, Gibbs & Hill assumed that longitudinal forces on the conduits are resisted only by the l outriggers bearing on the concrete surface. Because of this l assumption, the Hilti-Kwik bolts in the outriggers do not carry any

! load; however, the anchors may carry some load due to the conduit l loads and also due to prestressing of the support by the cinching of the bolts in the P1941 and P1064 plates connecting the header and outrigger. Additionally, the current revision of the CA-2a design drawing waives proximity violations between the Hilti bolts in the outriggers and any other anchor bolts. If these bolts are evaluated for loads, large capacity reductions will be required for the spacing provisions in the design.

D. Note 3 on Gibbs & Hill Drawing 2323-S-0910, Sheet G-4a allows substitution of 1" diameter Richmond Inserts for 1" diameter and smaller Hilti-Kwik and Super-Kwik bolts. In general, singly-installed Richmond Inserts have a higher capacity than Hilti-Kwik and Super-Kwik bolts; however, Richmond Inserts in cluster arrangements may have lower capacities. The Gibbs & Hill O designs do not consider or evaluate Richmond Inserts.

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APPENDIX 10 1

CYGNA ISSUE NO. 10: ANCHOR BOLTS (Cont'd)'

O 2.0 UNDERSTANDING OF THE ISSUE ,

A. There is an inconsistency and a lack of justification in addressing prying action.

B. Moments due to shear on anchor bolts were neglected in a specific case (CST-17 Support).

C. . For CA-2a supports, outrigger bolts were assumed. to take no longitudinal load; and Hilti bolt proximity violations were waived.

D. Replacement of Richmond inserts in lieu of Hilti bolts may be unconservative in cluster arrangements. Justification for replacement is. required for these S-0910 supports.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Prying has been addressed in a special calculation file.

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B. Conduit support CST-17, Type 17 does not exist in Train C conduits.

However, Train C tupport types which experience similar moment loading on the andior bolts are evaluated for such moment loading.

C. Minimum spacing check is required for all anchor bolts.

O D. Any replacement of bolts is identified in walkdawns.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Condtit Support Review Questions," 84056.015, dated August 6, 1984.
2. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCO), " Cable Tray / Conduit Support Review Questions," 84056.094, dated October 30, 1985.
3. Gibbs & Hill Calculation 2323-SCS-153C, Set 1, Sheets 32-44.
4. Gibbs & Hill Calculation 2323-SCS-153C, Set 1, Sheets 146-152.

5.0 IMPLEMENTATION OF THE RESOLUTION A. Prying factors applicable to Train C supports have been developed in a special Impell calculation file (Reference 7).

B. Certain Train C support types experience moment loading on the i anchor bolts. The effects of the moment loading on the anchor bolts of these support types will be addressed in Reference 11.

("N C. Minimum spacing between anchor bolts is checked in the walkdown i U process (Part II, Reference 4).

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APPENDIX 10 CYGNA ISSUE NO. 10: ANCHOR BOLTS (Cont'd) 5.0 IMPLEMENTATION OF THE RESOLUTION (Cont'd)

D. Impell bases the qualification of supports on the as-built configuration (Reference 4). Any replacement of bolts will be identified in the walkdowns.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY ~

COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND 8 CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS h

APPENDIX 11 CYGNA ISSUE NO. 11: LONGITUDINAL LOADS ON TRANSVERSE SUPPORTS O

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APPENDIX 11 CYGNA ISSUE NO. 11: LONGITUDINAL LOADS ON TRANSVERSE SUPPORTS O

1.0 BACKrA0VND Some transverse supports have the same order of longitudinal stiffne s as long cantilever multi-directional supports. Since conduit clamps provide restraint in three directions, longitudinal loads, which were not considered in the design, may be imparted to the supports.

Additionally, the displacements due to torsion of longitudinal support beam members may induce some longitudinal loads into transverse supports.

2.0 UNDERSTANDING 0F THE ISSUE Some transverse supports may have same order of longitudinal stiffness as 3-D supports. However, longitudinal loads due to clamps were neglected for these transverse supports.

Torsion of longitudinal members may induce longitudinal loads into the transverse supports.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Longitudinal loads are included in development of the screening criteria and the qualification of supports. Transverse supports will be design verified for longitudinal loads. Torsion in longitudinal support beam O members arising from load eccentricities will be included in the evaluation whenever such load eccentricities occur.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Communications Report between E. Irish (Unistrut) and J. Russ (Cygna), dated 7/25/84.
2. Communications Report between R. Kissinger and S. McBee (TUGCO),

R. Miller (CCL), and D. Leong, J. Russ and N. Williams (Cygna),

I dated 4/9/85.

3. Cygna Generic Conduit Support Review Checklists (to be issued).

l l 5.0 IMPLEMENTATION OF THE RESOLUTION

! Results from the Impell test program (Reference 6) have been used to determine the stiffness of cantilever supports in the longitudinal direction. Impell Project Instructions ( Appendix A, Reference 2) summarize these longitudinal support stiffnesses for cantilever supports. These support stiffnesses, including torsional effects of the support beams have been used to determine longitudinal loads for the design of transverse supports.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONOVIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 12 CYGNA ISSUE NO.12: HILTI-KWIK BOLT SUBSTITUTIONS O

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APPENDIX 12 CYGNA ISSUE NO. 12: HILTI-KWIK BOLT SUBSTITUTIONS O

1.0 BACKGROUND

Note 4 on Gibbs & Hill Drawing 2323-S-0910, Sheet G-4a, allows the substitution of all Hilti-Kwik and Super-Kwik bolts with those of a larger size. A reduction in the allowables for the larger bolts may be necessary since the actual spacing may be smaller than that required.

Thus, a situation may occur where the replacement bolts have a lower capacity than the bolts in the original design.

Examples of Cygna's concern are described below:

CSM-18c: 1/2" Hilti-Kwik bolts at 5" spacing were used in the original design. If all 1/2" bolts are substituted with 3/4 or 1" bolts, the tensile allowable for the replacement bolts will be less than the design tensile allowable of 3012 lbs. (2750 lbs for 3/4" bolts and 2930 lbs. for 1" bolts).

CSM-42 1" Hilti Super-Kwik bolts at 7.5" spacing were used in Type III: the original design (allowable tension = 12452 lbs, allowable shear = 6884 lbs). If all l bolts are replaced by 1-1/4" bolts of equal embedment, the bolt capacity is significantly reduced (allowable tension =

6405 lbs, allowable shear = 6221 lbs).

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2.0 UNDERSTANDING OF THE ISSUE Gibbs and Hill drawing allows substitution of all Hilti and Super-Kwik bolts with those of larger size. Reduction in allowables due to smaller spacing may result in lower capacity.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Any substitutions will be identified in as-built walkdowns, and qualified using appropriate capacities.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA None. -

5.0 IMPLEMENTATION OF THE RESOLUTION Impell bases the qualification of supports on the as-built configuration (Reference 4). Any anchor bolt modification utilizing larger bolt substitutions will be identified in the walkdowns and their capacities calculated accordingly.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 13 CYGNA ISSUE NO.13: SUBSTITUTION OF SMALLER CONDUITS ON CA-TYPE SUPPORTS i

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APPENDIX 13 g CYGNA ISSUE NO. 13: SUBSTITUTION OF SMALLER CONDUITS ON CA-TYPE SUPPORTS

1.0 BACKGROUND

CA-type supports are designed using ZPA for large (>2") diameter conduits while peak accelerations are used for small diameter conduits (<2"). For CA-type supports where capacities are tabulated on the drawings, small diameter conduits may be installed unless specifically prohibited on the drawings. Although the deadweight load of the small diameter conduits must be less than the capacity, the seismic load of the small diameter conduits may exceed the equivalent seismic load of the large diameter conduits considered in the original design.

As an example, support type CA-15 was designed for two 3" conduits with a deadweight capacity of 156 lbs. However, five 1-1/2" conduits can be installed on a CA-15 support, giving higher seismic loads than designed for. The rigid span loads for two 3" conduits are 343 lbs. and 109 lbs.

for the vertical and horizontal directions, respectively. The flexible span loads for five 1-1/2" conduits are 504 lbs. and 450 lbs. for the vertical and horizontal directions, respectively.

This item possibly affects support types CA-6, CA-7, CA-12, CA-14 Series, and CA-16a.

2.0 UNDERSTANDING OF THE ISSUE Large diameter (7 2") conduit loads are based on ZPA. Small diameter (4 2") conduit loads are based on peak accelerations. Substitution with smaller size conduit may result in larger load on CA-type supports.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Evaluation is based on as-built configurations.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Communications Report between S. McBee (TUGCO) and J. Russ (Cygna),

dated 3/7/85.

5.0 IMPLEMENTATION OF THE RESOLUTION Impell bases the qualification of supports on the as-built configuration l (Reference 4). Any substitutions will be identified in the walkdowns, and qualified using the as-built configurations.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY 4 COMANCHE PEAK STEM ELECTRIC STATION i GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS i

APPENDIX 14 CYGNA ISSUE NO.14: USE OF CA-TYPE SUPPORTS IN LS SPANS O

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APPENDIX 14 CYGNA ISSUE NO.14: USE OF CA-TYPE SUPPORTS IN LS SPANS O

1.0 BACKGROUND

CA-type supports are used to support LA spans, which are limited to a 6' length. CST-type and CSM-type supports are used to support LS spans, which can be up to 12' for transverse spans and 24' for longitudinal spans. In field installations, when conduits run from walls to equipment in the middle of a room, a transition is made between LA spans and LS spans. lhe concerns are discussed below.

For CA-type supports, ZPA was used to determine the design load for large diameter conduits ( 2" diameter.) Since the conduits are field-run, CA-type supports may be installed adjacent to multi-directional supports. The span between the two supports is considered to be an LA-span, since the span length must not exceed that specified by the design of the CA-type support. The rigidity of the span can no longer be assumed, due to the flexibility of the multi-directional support and the effect of the flexible spans past the multi-directional support. Peak acceleration should then be used to determine the design load for that span.

There is evidence that decreased support capacity is considered for the fire protected supports (see TUGC0 Instruction CP-EI-4.0-49), since support capacities are given for both LA spans and LS spans. For g unprotected lines, there is no indication that this was considered.

2.0 UNDERSTANDING OF THE ISSUE Transition regions between LA and LS spans may not have been conserva-tively designed. Some of these supports have been designed for ZPA, when they should have been designed for spectral peak accelerations.

3.0 ACTION PLAN TO RESOLVE THE ISSUE l

Span allowables are defined by Impell for the Train C work. For cases where the frequencies of the conduit support spans are not calculated, spectral peak accelerations in combination with the appropriate PNFs are conservatively used to develop these span allowables. Al ternatively, actual support stiffnesses are used to calculate the frequencies of the conduit support spans and the corresponding inertial loading. Support qualification is based on as-built walkdowns.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Communications Report between M. Warner, et al . (TUGCO) and W. Horstman, et al. (Cygna), dated 2/20/85.

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APPENDIX 14 CYGNA ISSUE NO. 14: USE OF CA-TYPE SUPPORTS IN LS SPANS (Cont'd)

O Communications Report between M. Warner (TUGCO) and N. Williams, 2.

et al . (C' ma), dated 2/27/85.

5.0 IMPLEMENTATION OF THE RESOLUTION Impell bases the qualification of supports on the as-built configuration. Allowable spans are defined by Impell in Reference 4.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES i

AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 15 CYGNA ISSUE NO.15: STRESSES IN CABLE TRAYS DUE TO ATTACHED CONDUIT SUPPORTS l

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APPENDIX 15 CYGNA ISSUE N0.15: STRESSES IN CABLE TRAYS DUE TO ATTACHED CONDUIT SUPPORTS O

1.0 BACKGROUND

This item applies to CSD-16 in the Cygna review scope and to any similar details. Cable tray spans are ostensibly designed to the capacity of the tray. The addition of CSD-16 to the tray rails adds loads above the capacity of the cable tray. Therefore, a generic stress check for the trays is not possible, and all tray spans with these conduit supports should be individually checked.

Additionally, in the design of the CSD-16 support, peak acceleration was used to determine loads due to the flexible conduit section, and zero period acceleration (ZPA) was used to determine loads due to the rigid conduit attacned to the cable tray. Since the support is attached to the flexible tray span, there will be additional amplification of input acceleration on the CSD-16 support. As a minimum, peak acceleration should be used for all conduit segments. An additional dynamic amplification factor (DAF) may be required.

2.0 UNDERSTANDING OF THE ISSUE Some conduits are attached to tray side rails. These tray spans should be checked for added loads.

For support evaluation, peak acceleration times DAF should be used to O eveiuete coaduit ioeds siace tras is riexibie-3.0 ACTION PLAN TO RESOLVE THE ISSUE The cable tray qualification is performed under a separate program.

Trays with attached conduit supports are individually qualified with due consideration of the added conduit weights. Walkdowns will screen out any conduit supports attached to cable trays. The qualification of these conduit supports will account for the effect of cable tray flexibility.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Cygna Generic Conduit Support Review Checklists (to be issued).
2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1, Sheets 101-104, 5.0 IMPLEMENTATION OF THE RESOLUTION i Impell Project Instructions (Section 3.2.3e, Reference 10) require the consideration of attached conduits in cable tray qualification.

Impell Project Instructions (Section 4.1.1, Reference 2) require the consideration of added tray flexibility to evaluate conduit supports attached to cable trays. Appropriate DAFs will be used in evaluating support loads.

O A15-2 ll66a/9-19-86/

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 16 CYGNA ISSUE NO.16: INCREASES IN ALLOWABLE SPAN LENGTHS O

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O A16-1 1167a/9-19-86/

APPENDIX 16 CYGNA ISSUE NO. 16: INCREASES IN ALLOWABLE SPAN LENGTHS

1.0 BACKGROUND

In the revised Gibbs & Hill Drawing 2323-S-0910 package, LA span lengths were increased by a ratio of the refined to the unrefined spectra. Gibbs

& Hill provided a calculation to show that the above changes are correct with respect to the spectral ratios and that rigid spans remain rigid

~

(diameters 2"). This is adequate for support designs, since support loads are proportional to span lengths. However, an evaluation of the conduit stress is required, since conduit bending stress is proportional to the square of the span length.

2.0 UNDERSTANDING 0F THE ISSUE Span lengths for LA spans were increased by ratio of refined to unrefined spectra. This is adequate for support loads but unconservative for conduit stresses (which are proportional to square of span length).

3.0 ACTION PLAN TO RESOLVE THE ISSUE Refined spectra are being used for Train C evaluation. No action is required.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

, 1. Comunications Report between P. Huang (Gibbs & Hill) and D. Leong and J. Russ (Cygna), dated 12/27/84.

l 2. Gibbs & Hill Calculation 2323-SCE-18"C, Set 1, Sheets 15-24.

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3. Communications Report between R. Kissinger and S. McBee (TUGCo),

P. Huang (Gibbs & Hill), R. Miller and R. Yow (CCL), and D. Leong

! and J. Russ (Cygna), dated 4/10/85.

5.0 IMPLEMENTATION OF THE RESOLUTION No action is required.

O A16-2 1167a/8-20-86/

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 17 CYGNA ISSUE NO.17: SUBSTITUTION OF NEXT HEAVIER STRUCTURAL MEMBER O

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l A17-1 1168a/9-19-86 l

APPENDIX 17 CYGNA ISSUE NO. 17: SUBSTITUTION OF NEXT HEAVIER STRUCTURAL MEMBER

1.0 BACKGROUND

This item refers to Note 5 on Gibbs & Hill Drawing 2323-S-0910, Sheet G-la. Most supports are designed to the allowable load limits for the Hilti-Kwik bolts. Since support self weight has not been properly considered in some designs (see Review Issue 7), Hilti-Kwit bolts may be overstressed in generic designs using structural steel.

2.0 UNDERSTANDING OF THE ISSUE Supports have been designed to allowable load limit for Hilti-Kwik bol ts. If self-weight is not considered properly, or if heavier member is substituted, bolts will be overstressed.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Impell evaluations of conduit supports are based on as-built configuration and consider support self-weight.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA None.

5.0 IMPLEMENTATION OF THE RESOLUTION ,

Impell bases the qualification of supports, including proper consideration of self-weight effects, on the as-built configuration (Reference 4). Any substitutions will be identified in the walkdowns, and qualified using the as-built configurations.

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A17-2 1168a/8-20-86

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION l

GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 18 CYGNA ISSUE NO.18: CLAMP USAGE

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! A18-1 1169a/9-19-86 1

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APPENDIX 18 CYGNA ISSUE NO. 18: CLAMP USAGE

1.0 BACKGROUND

A. In the following two Gibbs & Hill designs in Cygna's review scope, P2558 clamps may be reamed to accomodate larger bolts. As a result, the minimum edge distance requirements are violated.

For CA-Sa supports, clamps for small diameter conduits ( < 2") must be reamed to accomodate 3/8" Hilti-Kwik bolts. The washers for 3/8" Hilti-Kwik bolts will not fit properly on the clamps. The washer is an integral part of the bolt, and justification for its omission, alteration, or distortion during installation is required.

For the IN-CSM-15a support, clamps for the 5-inch diameter flexible conduit are reamed to accomodate 1/2" Nelson studs.

In response to Reference 1 TUGCo/Gibbs & Hill provided Reference 6 to justify reaming of clamps for conduits larger than 2" diameter.

This calculation addresses the clamps for the IN-CSM-15a support, but does not address the clamps for the small diameter conduits for the CA-Sa supports.

B. C708-S clamps for conduits can be modified by cutting off the end portion of the clamp ears. This modification removes two of the four bolt holes from the clamp. Justification for this modification pd is required. Also see Review Issue 9 for discussion of clamp allowables.

C. In the Cygna walkdown, clamp distortion was noted for the following supports:

Support ID Support Type C12G03528-8 CSM-18f Cl2002935-4 CA-Sa Cl2G03126-18 CSM-42 C12G02851-6 CA-Sa In response to Reference 1, TUGCo/Gibbs & Hill provided Reference 8 to justify clamp distortion.

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l O l A18-2 l 1169a/8-20-86

APPENDIX 18 CYGNA ISSUE NO. 18: CLAMP USAGE (Cont'd)

O 2.0 UNDERSTANDING OF THE ISSUE A. Clamps were reamed to accommodate larger size bolts. Minimum edge distance is violated.

B. Clamp ears were modified (2 of 4 holes were cut off). Justification is required.

C. Clamp distortions were noted for specific supports.

3.0 ACTION PLAN TO RESOLVE THE ISSUE A. The Clamp Test program (References 12 and 13) has considered the effect of edge distance violation due to oversize bolt holes on clamps. These test results will be used to justify reaming of the clamps.

B,C Any deficiencies are identified through as-built walkdowns. Each deficiency is either qualified or modified for acceptance.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) letter to J.B. George (TUGCo), " Cable Tray and Conduit Support Review Questions" 84056.015, dated August 6,1984, O auestiaa ^4-
2. N.H. Williams (Cygna) letter to J.B. George (TUGCo), " Conduit Support Walkdown Questions," 84056.020, dated August 13, 1984, question 3.
3. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCo), " Cable Tray / Conduit Support Review Questions," 84056.094, dated October 30, 1985.

( 4. Communications Report between E. Irish (Unistrut) and J. Russ (Cygna) dated 7/25/84.

5. Communications Report between T. Keiss, et al . (TUGCo), B. Bhujang, et al. (Gibbs & Hill), and W. Horstman, et al. (Cygna), dated 10/9/84.
6. Communications Report between R. Miller and R. Yow (CCL), E. Bezkor and P. Huang (Gibbs & Hill), C. Mortgat (TERA), R. Kissinger and S. McBee (TUGCo), and N. Williams and J. Russ (Cygna), dated 3/29/85.
7. Gibbs & Hill Calculation 2323-SCS-1005, Set 1, Sheets 9-13, regarding clamp reaming.
8. Gibbs & Hill Calculation 2323-SCS-1005, Set 1, Sheets 7-8, regarding clamp distortion.
9. Cygna Generic Conduit Support Review Checklists (to be issued).

A18-3 1169a/8-20-86

APPENDIX 18 CYGNA ISSUE NO.18: CLAMP USAGE (Cont'd)

O 10. Cygna Conduit Support Walkdown Checklists (to be issued).

5.0 IMPLEMENTATION OF THE RESOLUTION A. Reaming of the clamps will be justified by test results (References 12 and 13) or by calculations.

B,C Impe11 bases the qualification of supports on the as-built configuration (Reference 4). Any support deficiencies will be identified in the walkdowns, and evaluated on a case-by-case basis.

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A18-4 1169a/8-20-86

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 19 CYGNA ISSUE NO.19: DOCUMENTATION DEVIATIONS BETWEEN INSPECTION REPORTS, CMCs and IN-FP DRAWINGS O

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APPENDIX 19 CYGNA ISSUE NO. 19: DOCUMENTATION DEVIATIONS BETWEEN INSPECTION RLPUKid, LPILs and IN-FP DRAWING 5

1.0 BACKGROUND

A. For each conduit line, an inspection is performed and documented on an inspection report (IR). All CMCs and applicable IN-FP drawings should be reflected on the IR. Examples of Cygna's concerns are discussed below:

1. Line C11003395, IRME-18120F, Support -1: On the IR, the support is listed as CSM-18f, Revision 4. On CMC 62903, the support is listed as CSM-18b, Revision 14. Based on the CMC information, the IR is in error.
2. Line C12G05087, IRME-16817F, Support -4: On the IR, the support is listed as CSM-18c, Revision 13. On CMC 62905, Revision 0, the support is listed as Revision 9. On CMC 62905, Revision 1, the support is listed as Revision 12. Five such discrepancies occur for supports in Cygna's review scope.
3. Line C12004695, IRME-16089F, IN-FP-216 and IN-FP-226: There are discrepancies between the IR and both IN-FP drawings for support types CA-la and CA-2a. There is no structural difference in the supports, but a documentation inconsistency exists. Nine such discrepancies occur for supports in Cygna's review scope.
4. All applicable CMCs and their revision numbers should be listed on the inspection reports. In Cygna's review scope, three CMCs were not listed on the appropriate IR. CMCs 59701, 09387, and 68272 should be listed on IRME-20073F. Revision numbers were not provided for the following five CMCs: On IRME-18120F, CMCs 67042 and 62903; on IRME-0143F, CMCs 68276 and 75090; and on IRME-17398F, CMC 68438.

l B. Additionally, the Cygna walkdown identified deviations between the final inspection reports and installed configurations for two conduit lines.

1. Conduit line Cl2002935 appears to have been rerouted. The final inspection report IRME-16236F lists four supports on the line.

There are three supports on the line in the field. Support C12002935-3 has been removed, and support C12002935-2 has been re-marked Cl2002935-5. An updated IR was not found.

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l A19-2 1170a/8-20-86

APPENDIX 19 CYGNA ISSUE NO. 19: DOCUMENTATION DEVIATIONS BETWEEN INSPECTION REPORT 5, CML's and IN-FP DRAWINGS (Cont'd)

2. Support IN-CSM-15b is not listed on the inspection report IRME-14684F. It is present in the field.

2.0 UNDERSTANDING 0F THE ISSUE A. Documentation deviations exist between inspection reports, CMCs and In-FP drawings.

B. Deviations exist between final inspection reports and installed configurations.

3.0 ACTION PLAN TO RESOLVE THE ISSUE This issue does not apply to the Train C conduit program since as-built support drawings do not exist. The Train C conduit support qualification is based on as-built configurations.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCo), " Cable Tray / Conduit Support Review Questions", 84056.094, dated October 30, 1985.
2. Comunications Report between P. Patel (TUGCo) and D. Leong and J.

Russ (Cygna), dated 2/18/85.

3. Cygna Individual Conduit Review Checklists (to be issued).

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4. Cygan Conduit Walkdown Checklists (to be issued).

5.0 IMPLEMENTATION OF THE RESOLUTION No action is required.

! O i A19-3 1 1170a/8-20-86 l

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O TEXAS UTILITIES UTILITIES GENERATING CO W ANY COMANCHE PEAK STEM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 20 CYGNA ISSUE NO. 20: NELSON STUDS O

O A20-1 1171a/9-19-86

APPENDIX 20 CYGNA ISSUE N0. 20: NELSON STUDS O

1.0 BACKGROUND

In the original conduit support design calculations, Gibbs & Hill did not check Nelson studs for conformance with vendor specifications and allowables . Subsequently, Gibbs & Hill supplied Cygna with Nelson stud qualification calculations to determine the adequacy of the installed stud configurations. Cygna has the following comments on the calculations provided:

- Reference 3 provides evaluation of the stud stresses. A pretensioning force was assumed to relieve applied loads to the studs. The calculation did not account for the flexibility of the clamp and shim plate or relaxation of the preload.

- The allowable Nelson stud forces reported by TRW/ Nelson are based on shear applied at the weld location. In the conduit support designs, the studs are loaded at the clamp, which produces a moment in the stud. This additional moment was not considered in the Reference 3 calculation.

- Reference 2 (Sheets 151 through 160) provides evaluation of the shim plate attaching the Nelson studs to the structural member. The stress distribution assumed for the weld connecting the shim plate to the member is not realistic, as it introduces an infinite stress at the bottom of the plate. The assumption affects the results of O the yield line analysis performed to check the adequacy of the shim pl ate.

Weld underrun was not considdred in the Reference 2 calculation.

2.0 UNDERSTANDING OF THE ISSUE l

Gibbs & Hill evaluation of Nelson studs Train A & B is not adequate.

3.0 ACTION PLAN TO RESOLVE THE ISSUE To date, Unit 1 Train C conduit supports with Nelson stud application have not been identified. Nelson studs are expected to exist in Unit 2 Train C conduit supports. A method of evaluation will be developed based on a survey of the various support configurations with Nelson stud application.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Comunications Report between P. Huang and R. Sanders (Gibbs & Hill) l and J. Russ (Cygna), dated August 7,1984.

O A20-2 1171a/9-19-86

APPENDIX 20 CYGNA ISSUE NO. 20: NELSON STUDS (Cont'd)

O 2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1, Sheets 131-160.

3. Gibbs & Hill Calculation 2323-SCS-109C, Set 1 Sheets 164-184.

5.0 IMPLEMENTATION OF THE RESOLUTION A method of evaluation will be developed for the various support types l

with Nelson stud application in the Train C conduit system.

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O A20-3 1171a/9-19-86

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION

, GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION l OF CYGNA TRAIN A AND B CONDUIT ISSUES I AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 21 CYGNA ISSUE NO. 21: CONDUIT FIRE PROTECTION CALCULATIONS O

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A21-1 ll72a/9 1wt;

APPENDIX 21 CYGNA ISSUE NO. 21: CONDUIT FIRE PROTECTION CALCULATIONS q

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1.0 BACKGROUND

All calculations providing evaluation of fire-protected conduits and conduit supports were obtained from Gibbs & Hill prior to the completion of the design review for those calculations. The comments made in this review issue may have been resolved due to design review efforts.

A. All of the Gibbs & Hill fire protection calculations consider a round configuration of Thermo-Lag material around conduits. The Thermo-Lag weight on the spans was calculated based on this configuration. The Cygna walkdown and discussions with TUGC0 indicate that a square configuration was also used in the field installations. Documentation of the specific configuration installed was not maintained.

B. Reference 5 calculates the capacities of CA-la supports for various plant elevations using both LA- and LS- spans. The analysis model used in the calculation supported one conduit and had two sets of outriggers. Reference 4 provides tables of the capacities for use in determining the adequacy of CA-la supports with fire protection; however, the tables do not specify that the capacities given are limited to the support configuration used in the analyses.

C. Capacities for CA-2a supports are given in Table 24 of Reference 4.

Reference 6 contains calculations which determine support capacities s for CA-la and CA-2a supports with multiple conduit installations.

Reference 6 states that CA-la capacities should be used for CA-2a supports, since CA-2a supports are "similar to and stronger" than CA-la supports. The allowable capacity for LA-spans calculated in the referenced calculation is 185 lbs. Table 24 of Reference 4 gives the allowable as 385 lbs. The tabulated capacities for CA-2a appear to be in error, when compared with the CA-la capacities in Tables 25 and 26 of the same reference.

D. In the review of IN-FP calculations, Cygna has three concerns regarding detailed calculations used to demonstrate support adequacy.

1. The IN-FP drawings generally contain information on span length, support location on the conduit run, and type of support (such as Type 17d or 17e for a CSM-18c support). In some cases, the mounting surface will be indicated (such as ceiling-mounted or wall-mounted), as well as key dimensions for a support (such as cantilever length). Cygna has noted that orientation of the support on the mounting surface is almost never given, yet the IN-FP calculations assume a configuration for the detailed analysis. Two supports in Cygna s review scope which are qualified based on such assumed configurations are Cl2G03126-1 and Cl2G03126-11.

. O A21 -2 1172a/8-20-86

APPENDIX 21 CYGNA ISSUE NO. 21: CONDUIT FIRE PROTECTION CALCULATIONS (Cont'd)

2. Cygna has noted that some detailed calculations do not include the effects of CMCs when analyzing the supports for the effects of fire protection. Three supports in Cygna's review scope which neglect CMCs are C12G05087-4, C12G03126-2, and C11003395-2.
3. Cygna has noted that the support capacities used for the qualification of fire protected supports were taken from the drawing revisions which were current when the IN-FP calculations were performed, although the supports were originally installed and inspected to earlier revisions.

Justification for using these capacities was not provided.

Four supports in Cygna's review scope which are qualified to later drawing revisions are C12004695-5, C12G05087-4, C12G03126-2, and C11003395-2.

2.0 UNDERSTANDING OF THE ISSUE A,B,D. For some conduit supports with fire protection, the as-built configurations differ from the as-designed configurations.

Evaluation of the as-built configuration is required.

C. Apparent error exists in the tabulated capacities for support type CA-2a.

3.0 ACTION PLAN TO RESOLVE THE ISSUE The as-built walkdowns will identify the presence of any fire protection material . The additional weight will be considered for support evaluation. The Gibbs & Hill tabulated capacities for support type CA-2a i

have not been used by Impell.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) letter to W.G. Counsil (TUGCO), " Cable Tray / Conduit Support Review Questions," 84056.094, dated October 30, 1985.

l 2. Comunications Report between T. Keiss (TUGCO) and W. Horstman, et al . (Cygna), dated 10/16/84.

l l 3. Communications Report between S. McBee (TUGCO) and D. Leong (Cygna) dated 4/18/85.

4. TUGC0 Instruction CP-EI-4.0-49.

l S. Gibbs & Hill Calculation 2323-SCS-1017, Set 2, Sheets 8-11.

6. Gibbs & Hill Calculation 2323-SCS-152C, Set 1, Sheet 39.

l l \ 7. Gibbs & Hill Calculation for Drawing 2323-S-0910, Sheet IN-FP-213a.

A21 -3 1172a/8-20-86

APPENDIX 21 CYGNA ISSUE NO. 21: CONDUIT FIRE PROTECTION CALCULATIONS (Cont'd)

O 8. Gibbs & Hill Calculation for Drawing 2323-S-0910, Sheet IN-FP-212.

9. Gibbs & Hill Calculation for Drawing 2323-S-0910, Sheet IN-FP-214.
10. Gibbs & Hill Calculation 2323-SCS-233C, Set 1, Sheets 62-67 for Drawing 2323-S-0910, Sheet IN-FP-226.

5.0 IMPLEMENTATION OF THE RESOLUTION Impell Project Instructions (Part II, Reference 4) specify that the additional weight due to the presence of fire protection material must be considered in the support evaluation. Actual configuration of fire-protected conduits will be identified by walkdowns and used in the calculation.

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A21 -4 ll72a/9-19-86

O N TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION -

OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 22

,CYGNA ISSUE N0. 22: SPAN INCREASE FOR FIRE PROTECTED SPANS O

O A22-1 1173a/9-19-86

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APPENDIX 22 CYGNA ISSUE NO. 22: SPAN INCREASE FOR FIRE PROTECTED SPANS

1.0 BACKGROUND

TUGCo Instruction CP-EI-4.0-49 (Reference 7) gives allowable conduit spans for fire-protected runs. Cygna notes that, in most cases, the fire-protected spans exceed the allowable spans for unprotected conduit spans documented in the 2323-S-0910 drawing package (References 8 and 9).

Cygna reviewed the design calculations for the fire-protected spans (Reference 10) and concluded that the increase in length for the fire-protected spans could be attributed to the removal of conservatisms from the analysis, such as using the refined rather than the unrefined spectra. In general, Cygna agrees with the analysis method used in the span design; however, Cygna does not agree with the conduit stress allowables used in the analysis.

To obtain allowable stress values for the conduits, Gibbs & Hill used test data supplied by the vendor to obtain yield stress values. Cygna has two major comments on the derivation of the allowables:

- The allowable stress values vary with conduit nominal size. The vendor test data consists of three to four tests for specimens of each conduit size. Gibbs & Hill used the lowest tested yield stress for each conduit size or an imposed minimum yield stress value of 33 ksi to obtain allowables for that particular conduit size.

, Justification for the imposed minimum yield stress value was not provided. Cygna feels that it is not appropriate to specify different allowable stresses for each conduit size.

- Gibbs & Hill did not provide documentation to justify the applicability of the vendor test data to the conduits installed at CPSES. Cygna understands that electrical conduit is fabricated in accordance with the ANSI C80.1, which does not contain requirements for material conformance.

Cygna spoke to Triangle PWC, the conduit supplier for CPSES, regarding the test data provided to Gibbs & Hill (Reference 4).

Triangle PWC informed Cygna that as a rule, no certification test l

l reports are provided with the product and that any test data in the public domain represented a general sample of conduit they have l produced. They also stated that Triangle PWC is a processor and does not manufacture the steel used for the conduits. There are not ASTN standards applicable to conduits.

i The items discussed above concerning the conduit allowable stress apply to all conduit span calculations performed by Gibbs & Hill.

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A22-2 ll73a/8-20-86 l . - -

APPENDIX 22 CYGNA ISSUE NO. 22: SPAN INCREASE FOR FIRE PROTECTED SPANS (Cont'd)

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Cygna has one comment on the method used for the calculation of conduit stress. A dynamic amplification factor (DAF) of 1.0 was used in the conduit stress evaluation without justification. Review Issue 2 discusses the reanalysis efforts by Gibbs & Hill to address this concern. Results of those reanalyses should be applied to the conduit stress analyses described here.

2.0 UNDERSTANDING 0F THE ISSUE Varying allowable stresses for different conduit sizes (based on testing) is not appropriate.

No documentation is available to justify applicability of vendor test data to CPSES conduits. Vendor has no certification test reports for material .

3.0 ACTION PLAN TO RESOLVE THE ISSUE The above coment is specific to Train A and B conduit work.

Conduit stress qualification is not required for Train C conduit.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA O 1- co-uatcettoas aePort betweea T xeiss (Tucco) eaa w. worst ea. et al . (Cygna), dated 10/16/84.

2. Comunications Report between T. Keiss (TUGCO) and J. Russ and N.

Williams (Cygna), dated 10/27/84.

3. Comunications Report between S. McBee (TUGC0) and D. Leong (Cygna),

dated 4/16/85.

4. Comunications Report between W. Zehe (Triangle PWC) and D. Leong

! and J. Russ (Cygna), dated 4/17/85.

1 l 5. Comunications Report between S. McBee (TUGCO) and D. Leong (Cygna),

! dated 4/18/85.

l 6. Comunications Report between S. McBee (TUGCO) and J. Russ (Cygna),

dated 5/7/85.

7. TUGC0 Instruction CP-EI-4.0-49.
8. Gibbs & Hill Drawing 2323-S-0910, LA Series.

O A22-3 l 1173a/8-20-86 l

APPENDIX 22 CYGNA ISSUE NO. 22: SPAN INCREASE FOR FIRE PROTECTED SPANS (Cont'd)

O 9. Gibbs & Hill Drawing 2323-S-0910, LS Series.

10. Gibbs & Hill Calculation 2323-SCS-1017, Set 1.

5.0 IMPLEMENTATION OF THE RESOLUTION No action is required.

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A22-4 1173a/8-20-86

O

! TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS i APPENDIX 23 CYGNA ISSUE NO. 23: GROUTED PENETRATIONS l

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APPENDIX 23 CYGNA ISSUE NO. 23: GROUTED PENETRATIONS

1.0 BACKGROUND

For conduit runs embedded in walls and floors, longitudinal conduit

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supports are not required if there are no bends in the run. The grouted penetrations are assumed to carry the entire longitudinal load for such a conduit run. Additionally, all grouted penetrations are assumed to be multi-directional supports, sharing cc..duit load with the supports closest to the penetration. Calculations were not performed to assure the capability of the penetration to carry the required loads. Other supports on the conduit run may also be affected depending on run configuration and relative stiffness of the supports.

2.0 UNDERSTANDING OF THE ISSUE Grouted penetrations are used as supports. However no qualification is provided.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Grouted penetrations will be evaluated when used as a support for a Train C conduit run.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA pJ 1. Comunications Report between R. Kissinger and S. McBee (TUGCO), P.

Huang (Gibbs & Hill), R. Miller and R. Yow (CCL), and D. Leong and J. Russ (Cygna), dated 4/10/85.

l 5.0 IMPLEMENTATION OF THE RESOLUTION Impell's Project Instructions (Appendix F, Reference 2) specify the procedure to evaluate grouted penetrations.

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O A23 S 1174a/8-20-86

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 24 CYGNA ISSUE N0. 24: RIGIDITY OF CA-TYPE SUPPORTS 4

O A24-1 1175a/9-19-86

APPENDIX 24 CYGNA ISSUE N0. 24: RIGIDITY OF CA-TYPE SUPPORTS o

U l.0 BACKGROUND In the design of CA-type supports, the rigidity of the conduit spans was checked to justify the use of ZPA in calculating the design loads for the supports. In determining the rigidity of the conduit spans, Gibbs & Hill assumed that the CA-type supports were rigid. The frequencies of the conduit systems were due to the span flexure between rigid supports only . The design calculations for the CA-type supports did not include stiffness evaluations to validate the assumptions.

2.0 UNDERSTANDING OF THE ISSUE Conduit loads were obtained using ZPA by showing conduit spans to be ri gid. However, support stiffness was not included in the rigidity verification.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Support stiffnesses are included in determining frequencies for Train C conduit systems.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA Cygna Generic Conduit Support Checklists (not yet issued).

5.0 IMPLEMENTATION OF THE RESOLUTION Impell Project Instructions (Appendix D Reference 2) provide procedures to determine combined conduit / support frequencies. The effect of support stiffnesses are explicitly included.

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O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 25 CYGNA ISSUE N0. 25: ENVELOPING CONFIGURATIONS FOR DESIGN O

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APPENDIX 25

- CYGNA ISSUE NO. 25: ENVELOPING CONFIGURATIONS FOR DESIGN l 1

1.0 BACKGROUND

Since the Gibbs & Hill generic supports have numerous design parameters and tolerances for installation, the design must be evaluated for the worst case configuration allowed by the drawing. Cygna has noted several cases where the model used in the design evaluation did not reflect the most critic 61 support configuration. Additionally, the models used to check the perceived critical component were used to check other components whose forces were not maximized in the design model. The following supports are affected:

CA-l a CA-2a CA-Sa i -

CSM-18f CSM-42 CST-3 CST-17 IN-CSM-15a The maximum load eccentricities and installation tolerances are also not considered in the Gibbs & Hill designs. The following generic supports are affected:

CA-l a CA-2a CA-Sa CSM-6b CSM-18b CSM-18c CSM-18d CSM-18f CSM-42 CST-3 CST-17 JA-1 The following individual supports are affected:

IN-CSM-15a C12G03126-1 C12703126-11 O

A25-2 ll76a/8-20-86

APPENDIX 25 CYGNA ISSUE NO. 25: ENVELOPING CONFIGURATIONS FOR DESIGN (Cont'd)

O Component substitutions and any related tolerances should also be considered. See Review Issues 4, 5,10,12,13,17, and 18 for substitutions and tolerances allowed generically. This review issue is similar to concerns regarding enveloping configurations for the Unistrut testing scope discussed in Review Issue 9.

2.0 UNDERSTANDING OF THE ISSUE hodel used in generic design evaluations does not always represent most critical support configuration.

Maximum load eccentricities and installation tolerances should be considered.

Component substitutions should also be evaluated.

3.0 ACTION PLAN TO RESOLVE THE ISSUE Evaluations are based on as-built walkdowns. Qualification by walkdown is performed by ensuring that the support meets all the limitations provided in the project instructions.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA O 1. Cygna Generic Conduit Support Review Checklists (to be issued).

2. Cygna Individual Conduit Support Review Checklists (to be issued).

5.0 IMPLENENTATION OF THE RESOLUTION Impell's walkdown Project Instructions (Part II, Reference 4) describes the screening criteria for qualifying as-built Train C conduit support configurations. If the prescribed limitations are not met, the support will be modified or screened out for further evaluation.

O A25-3 ll76a/9-19-86

O TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 26 CYGNA ISSUE NO. 26: DESIGN DRAWING DISCREPANCIES l

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O A26-1 1177a/9-19-86

APPENDIX 26 CYGNA ISSUE NO. 26: DESIGN DRAWING DISCREPANCIES

1.0 BACKGROUND

In the review of ge.neric conduit support designs, Cygna has compared the design drawings with the assumptions and models used in the support evaluations. The following discrepancies or inconsistencies were noted in the design drawings.

The baseplate size on detail drawing CSD-2, Revision 1 was not given.

- For CSM-6b, Revision 3, the capacity table restricts the conduit size to 1" diameter or less. The drawing has a note specifying that C-708 S clamps must be used for conduits greater than or equal to 2" in diameter. This note is superfluous, considering the size limitation on the capacity table.

- The clamp type was not noted on the support drawings for CSM-18b, CSM-18c, CSM-18d, and CSM-18f.

No edge distance for the clamp bolts is provided for the angle bracket in IN-CSM-15a.

The design drawing for CSM-18c has no conduit size tables, but there is a superfluous note on the drawing regarding the nonexistent table.

2.0 UNDERSTANDING OF THE ISSUE Design drawings have missing infonnation (e.g., baseplate size, clamp type, edge distance).

3.0 ACTION PLAN TO RESOLVE THE ISSUE Since Impe11's Train C conduit program is based on using the as-built configurations, this issue is not applicable.

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APPENDIX 26 CYGNA ISSUE NO. 26: DESIGN DRAWING DISCREPANCIES (Cont'd) 4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA Gibbs & Hill Drawing 2323-S-0910, Sheets and Revisions noted below:

- CSD-2, Revision 1

- CSM-6b, Revision 3

- CSM-18b, Revision 16

- CSM-18c, Revisions 12, 13, 14

- CSM-18d, Revision 9

- CSM-18f, Revisions 3, 4, 5

- IN-CSM-15a, Revision 6.

5.0 IMPLEMENTATION OF THE RESOLUTION No action is required.

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l A26-3 ll77a/8-20-86

e ,L. 4 _.a_ . . - .r e ,.w_. .e -. -- # m O

TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 27 CYGNA ISSUE NO. 27: WALKDOWN DISCREPANCIES i

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APPENDIX 27 CYGNA ISSUE N0. 27: WALKDOWN DISCREPANCIES bc

1.0 BACKGROUND

The Cygna walkdown noted a number of conduit support discrepancies discussed below.

A. Clamp Installation

1. Clamp distortion was noted in four supports. This is discussed in Review Issue 18.
2. Gaps between Clamps and Shims The maximum gap allowed between the ears of a P2558 clamp and the shim plate is 1/8". Cygna noted two supports with gaps in excess of the 1/8". These supports are:

C13G02851-1 C12002935-1 B. Anchor Bolt Installation

1. Hilti Expansion Anchor Proximity Violation -

'N There are five occurrences of Hilti proximity violations where CJ the spacing in the field between the support and Hilti expansion anchors in adjacent supports is less than the minimum distance used in the design. The affected supports are:

Cl3G03528-1 C12G03126-21 (two occurrences)

C12G05087-1 l -

C12605087-2 l

2. Hilti Expansion Anchor Placement Violation Cygna has noted three supports with field installations of Hilti bolts which differ from the installations in the design drawings and/or CMCs. The affected supports are:

IN-CSM-15a C12G05254-1 C12G03126-16 The placement violation for one Hilti-Kwik bolt on support IN-CSM-15a results in a concrete edge distance violation.

3. Richmond Insert Installation Cygna noted that both Richmond Inserts on support C12G03126-12 O were aot ProPerir seateo. such taet they were aot beertasr iet against the base angles.

A27-2 1178a/8-20-86

APPENDIX 27 CYGNA ISSUE N0. 27: WALKDOWN DISCREPANCIES (Cont'd)

4. The base angles for IN-CSM-15a were installed such that the angle legs do not bear flat against the concrete. There is a gap of 1/4" between the angle and the concrete near the tube, which decreases to zero at the toe of the angles.

C. Installation of Structural Steel

1. Installation Tolerance Cygna noted two supports with installation tolerances in excess of those provided on the design drawing:
a. For support Cl3G03528-3, the tolerance for attaching the tube steel to the base plate was exceeded,
b. For IN-CSM-15b, the brace member work points are not coincident with the tube steel workpoints as shown on the design drawing.
2. Member Size For IN-CSM-15b, the baseplate for the horizontal brace is 19-3/4" long. The maximum size allowed on the design drawing is 18".

L D. Installation of Unistrut

1. Seating of Unistrut Nuts One nut in C12G03126-13 and four nuts in C12G03126-12 were not properly seated in the Unistrut channels.
2. Member Substitution P5000 members we;e used as header members in C12002935 instead of P1001 members, as specified in the design drawing.
3. Member Rotation The brace member is C12G03126-14 was rotated 180' about its own axis from the orientation shown on the design drawing.
4. CSD-1 Connection Installation Cygna noted installation discrepancies for the CSD-1 connections in supports C12G03126-12 and C12G03126-13.
a. Five connections were skewed, such that the header and base angle were not square relative to one another.

A27-3 1178a/8-20-86

APPENDIX 27 CYGNA ISSUE NO. 27: WALKDOWN DISCREPANCIES (Cont'd)

b. Four connections had gaps between the header and base angle in excess of the 1/4" allowed by the design drawing.
5. The outriggers in Cl3G02851-4 are skewed with respect to the header. The outriggers should be perpendicular to the header.

E. Conduit / Pipe Interferences Five pipes or conduits not supported by the support in question are in contact with the following conduit supports:

C12G03126-21 C12G03126-18 (3 occurrences)

C12G03126-19.

F. Conduit Placement

1. Spacing Violation The minimum distance between the flexible conduits is given as 10-1/2" on the design drawing. The conduits on one tube are 10" away from the conduits on the other tube.
2. Rotation of Conduit Attachments The three conduits attached to the TS6x3 member on IN-CSM-15b are shown to be perpendicular to the tube steel on the design drawing. The conduits are skewed with respect to the tube steel in the field installation.

2.0 UNDERSTANDING OF THE ISSUE A. Clamp distortion and excessive gaps between clamps and shims were noted.

B. Anchor bolt placement, proximity and seating violations were noted.

C. Structural steel installation tolerances were violated. Al so ,

'as-installed' and ' designed' baseplate sizes are different.

D. Discrepancies in Unistrut installation were noted (e.g., seating, member substitution, member rotation, connection installation).

E. Interferences were identified.

F. Conduit spacing criteria were violated.

O A27-4 ll78a/8-20-86

APPENDIX 27 CYGNA ISSUE NO. 27: WALKDOWN DISCREPANCIES (Cont'd)

O 3.0 ACTION PLAN TO RESOLVE THE ISSUE Impell will perform as-built walkdowns and identify construction deficiencies. Each identified deficiency will either be qualified using the as-built configuration or be modified to an acceptable configuration.

4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. Cygna Conduit Walkdown Checklists (to be issued).
2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Conduit Support Walkdown Questions," 84056.020, dated August 13, 1984.
3. L.M. Popplewell (TUGCO) letter to N. Williams (Cygna), transmitting calculations in response to Cygna questions, dated August 31, 1984.
4. L.M. Popplewell (TUGCO) letter to N. Williams (Cygna), transmitting calculations in response to Cygna questions, dated September 11, 1984.
5. L.M. Popplewell (TUGCO) letter to N. Williams (Cygna), transmitting calculations in response to Cygna questions, dated September 18, 1984.

" " wi' iia s (cys"a) ietter to w o couasii (tucco). cad'e O 6-Tray / Conduit Support Review Questions," 84056.094, dated October 30, i

1985.

5.0 IMPLEMENTATION OF THE RESOLUTION

( Impell's Project Instructions (Part II, Reference 4) specify that support deficiencies, spacing and edge distances between bolts will be checked during the walkdown process. Construction deficiencies will be identified for corrective action by project.

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l TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION l

GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION OF CYGNA TRAIN A AND B CONDUIT ISSUES

, AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS APPENDIX 28 l

l CYGNA ISSUE NO. 28: SYSTEMS CONCEPT l

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O A28-1 ll79a/9-19-86

,.,,,------.,we----- m-. ,,, rw.-,,,v,-- - - , , , _ . - , ,,-,n---- ,, - - - . , _m --c---- - - -- - - -

APPENDIX 28 CYGNA ISSUE NO. 28: SYSTEMS CONCEPT

1.0 BACKGROUND

For the majority of supports in the 2323-S-0910 package, the design evaluations are performed for individual supports with applied point loads representing the conduit. Loads from all restrained directions and tributary spans are applied to the support model. However, for the design evaluation of CA-Sa supports and the CSD-la detail (Z-clip), the interaction between supports on a conduit run or between the support and the conduit is used to validate use of reduced loads on the support or connection.

In References 2 and 3, Gibbs & Hill uses a load couple between adjacent CA-Sa supports to resist longitudinal loads. The rigidity of the conduit to provide transfer of longitudinal load to tensile load on the adjacent clamps was not shown. The use of this configuration requires specific field installation of supports (CA-Sa supports in series on a straight run). Its generic application in conjunction with other support types and in conduit runs with bends and offsets was not considered.

In Reference 1, Cygna asked Gibbs & Hill to consider the impact of the eccentricities for the design of CSD-la details. TUGC0/Gibbs & Hill submitted Reference 4 in response to Reference 1. In the response calculations, Gibbs & Hill assumed that the conduit attached to the support provided bracing for the support in the longitudinal direction, preventing rotation of the support and CSD-la detail .

Q l

The calculation in Reference 4 makes generalized configurational and load assumptions for both the support and conduit systan. The applicability l

of the calculation to all supports using this detail, for both 1

multi-directional and transverse supports should be demonstrated. This affects supports CSM-6b, CST-3, an CST-17 in Cygna's review scope.

2.0 UNDERSTANDING OF THE ISSUE Gibbs & Hill has used system concept to justify load transfers between supports. The assumptions made may not be valid for all different configurations in the field.

3.0 ACTION PLAN TO RESOLVE THE ISSUE The above referenced Gibbs & Hill calculations on the S-0910 supports have not been used by Impell on the Train C work. A system concept is being used by Impell to perform rigorous computer analyses of selected conduit systems. Results from these system analyses will provide additional justification for some of the screening criteria.

Applicability of these criteria is strictly limited to support types considered by the system analyses.

Load eccentricity effects are considered in both testing and anaylyses.

O l A28-2 1179a/9-19-86

APPENDIX 28 CYGNA ISSUE NO. 28: SYSTEMS CONCEPT (Cont'd)

O 4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions" 84056.015, dated August 6,1984.
2. Gibbs & Hill Calculation 2323-SCS-153C, Set 1, Sheets 153-160.
3. Gibbs & Hill Calculation 2323-SCS-152C, Set 1, Sheet 38.
4. Gibbs & Hill Calculation 2323-SCS-102C, Set 2, Sheets 255-258 (Revision 2).

5.0 IMPLEMENTATION OF THE RESOLUTION Impell's Project Instructions (Reference 8) provide procedures to perform rigorous analyses of conduit systems.

Load eccentricity effects are considered by replicating actual field configuration in testing (Reference 6). Appendix B of Reference 2 specifies that torsional effects due to load eccentricities are to be determined.

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TEXAS UTILITIES UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION

GENERIC TECHNICAL ISSUES REPORT - EVALUATION AND RESOLUTION i 0F CYGNA TRAIN A AND B CONDUIT ISSUES AS APPLICABLE TO TRAIN C CONDUIT SUPPORTS i

APPENDIX 29 f

l CYGNA ISSUE NO. 29: ClMULATIVE EFFECT OF REVIEW ISSUES O

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O ll80a/9-19-86

APPENDIX 29 CYGNA ISSUE N0. 29: CtNULATIVE EFFECT OF REVIEW ISSUES O

1.0 BACKGROUND

In this Review Issues List, a number of the issues cited may lead to small unconservatisms when occuring singly in a support design and can ususally be neglected. However, since several of these issues pertain to all conduit support designs on a generic basis, their effect can be cumulative, such that many small unconservatisms may be significant.

Therefore, any reevaluation of support designs should consider the cumulative effect of fii pertinent Review Issues.

2.0 UNDERSTANDING OF THE ISSUE Small unconservatisms resulting fron separate issues may have significant cumulative effect for supports impacted by more than one issue.

3.0 ACTION PLAN TO RESOLVE THE ISSUE This issue is inherently addressed by the comprehensive engineering approach to the design verification of the Train C conduit supports and by the implementation of extensive plant int.pection, analysis, qualification, and test activities.

As discussed in the introduction, all the generic technical conduit issues fall into three categories: deviations between the "as-designed" and "as-built" conduit systems, analysis assumptions and methods, and

(]'

design assumptions and methods.

The "as-built" vs "as-designed" issues are addressed cumulatively via the comprehensive qualification by inspection procedure. 100 percent of all accessible conduit supports have been inspected. Inaccessible supports are evaluated for the worst effect in design verification. In addition, this program has resolved instances of improper installation and poor construction quality.

All analytical issues (analysis assumptions and methods) and design l issues (design criteria and assumptions) have been simultaneously addressed by the development of procedures and instructions, supported by studies, which have systematically considered each issue. By virtue of the overall approach which has been implemented, the cumulative effect of these issues have been addressed directly.

l In summary, the overall design verification approach has fully addressed and resolved each of the generic technical issues both individually and collectively, and provided 100% field qualification of the conduit system designs including resolution of improper installation or construction.

This ensures that the margin of safety in the Train C conduit systems is acceptable.

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A29-2 ll80a/9-19-86

l APPENDIX 29 >

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j s CYGNA ISSUE NO. 29: CUMULATIVE EFFECT OF REVIEW ISSUES (Cont'd)

!O i 4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY CYGNA i

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101 Cantorrua Street. Swte 1000. San Francisco. CA 941115894 415/397-5500 November 26,1985 S4056.095

) -

4 Mr. W.C. Counsil Executive Vice President j Texas Utilities Generating Company Skyway Tower.

400 North Olive Street, L.B. 81 l Dolics, Texas 75201

Subject:

Review issues List (RIL)

Texas Utilities Generating Company <

. Comanche Peck Steam Electric Station I Independent Assessment Program - All Phases l

References:

See Attachment A l J

Dear Mr. Council:

Enclosed are revisions to the mechanical systems, electricol/l&C, cable troy supports, conduit supports, pipe supports, and design control Review issues Lists (RILs). All significant changes are noted by c revision bor in the right margin. Most of the revisions were made to provide changes in accordance with informction requests moce in the open j items letters (References 2, 3, 5, and 6) and questions or comments on the CPRT picn (References I and 4). The cable trov supports RIL was also revised to provide clarification r . and expansion of existing issues. A similar revision is in progress for the pipe stress RlL.

1 The current revisions to each discipline RlL cre os follows:

Discipline Revisions Cyano letter reference Pipe Stress I 84056.093 Pipe Supports 2 84056.092 Mechonical Systems 3 84056.088

, Electrical /l&C 3 84056.090 Ccble Troy Supports 12 84056.094 Concuit Supports 3 84056.094 Design Control 2 84056.085 561 8 ancisco Besten San Diego Cauca:;o Rcmanc

$0Y ,

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Mr. W.G. Counsil Noven-ber 26,1985 Page 2 if there are any questions please call at your conv.enience.

Very truly yours, e ,

N.H. Williams Project Manager Attachments cc: Mr. V. Noonan (USNRC) w/ottochments Ms. A. Vietti-Cook (USNRC) w/ottochments Mr. S. Treby (USNRC) w/ottochments Mr. W. Horin (Bishop, Liberman, et al.) w/ottochments l

Mr. J. Redding (TUGCO) w/ottochments i Mr. J. Finneron (TUCCO) w/ottochments O Mrs. J. Ellis (CASE) w/ottc6ments Mr. D. Pigott (Orrick, Her. mgton & Sutclif fe) w/ottochments i-Mr. F. Dougherty (TENERA) w/ottochments Mr. R. Ballard (Gibbs & Hill) w/ottochments Mr. R. Kissinger (TUGCO) w/ottochments Mr. J. Beck (TUGCO) w/ottochments l .

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h _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ .

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889MCIS Mr. W.G. Counsil November 26,1985 ATTACHMENT A

l. N.H. Williams (Cygno) letter to W.C. Counsil (TUGCO), "Cygno Questions / Comments on the CPRT Plon,84056.085, dated October 6,1985.
2. N.H. Williams (Cygno) letter to W.G. Counsil (TUGCO), " Mechanical Systems Review Questions-," 84056.088, dated October 16,1985.
3. N.H. Williams (Cygno) letter to W.G. Counsil (TUGCO), " Electrical Systems Review Questions," 84056.090, dated October 16,1985.
4. N.H. Williams (Cygno) letter to W.C. Counsil (TUCCO), " Additional Cygno Guestions/ Comments on the CPRT Plan," 84056.091, dated October 21,1985.

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5. N.H. Williams (Cygno) letter to W.G. Counsil (TUGCO), " Pipe Support Review Questions," 84056.092, dated October 30, 1985.
6. N.H. Williams (Cygno) letter to W.G. Counsil (TUGCO), "Coble Troy / Conduit Support Review Questions," 84056.094, dated October 30,1985.

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