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BROOKHAVEN NATIONAL LABORATORY
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ASSOCIATED UNIVERSITIES, INC.
Structural Analysis Division Upton. Long Island, New York 11973 Department of Nuclear Energy Building 129 (516) 282s 2949 FTS 666/
April 10, 1986 Mr. David Jeng Mail Stop P-316 Phillips Building US Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814
Subject:
Comanche Peak Conduit and Conduit Support Program Audit Meeting Trip Report.
Dear Mr. Jeng:
On February 14, 1986, C. Hofmayer and G. DeGrassi of BNL participated in an NRC audit meeting on the Comanche Peak Conduit and Conduit Support Programs.
The meeting was held at EBASCO offices in New York City. An at-tendance list is attached. TUGC0 made two presentations. The first presenta-tion was on the Unit 1 and Common Conduit Support Program.
The second was on the Unit 1 and Common Train C Conduit Program.
The highlights of the presentations are given below.
Conduit Support Program TUGC0 is implementing a two step program to verify the design adequacy of conduit supports in Unit 1 and common areas.
This involves a testing program and a random sample evaluation program.
The testing program includes unistrut testing and clamp testing. The clamp testing program is in progress.
The unistrut testing program has been completed.
Supports which include specific unistrut configurations that were questionable were reviewed on the basis of the test results. Of the 7064 total unistrut supports, 6213 were found acceptable as installed, 298 require capacity reduction and 553 supports need to be reworked.
The random sample evaluation program involves the as-built verification and design evaluation of a random sample of conduit supports. Two subpopula-tions were identified:
1)
Lighting conduits which typically have long runs of single conduits and 2) Power and control conduits which typically have 8610090148 861003 PDR FOIA i
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D. Jeng April 10,1986 have shorter runs of grouped conduits. A random sample of 60 conduit runs from each subpopulation was selected. To date, a total of 43 power and control group runs and 3 lighting group runs have been as-built verified by field inspection. Twenty runs of the power and control group sample containing 69 supports have been evaluated. All twenty supports evaluated thus far were shown acceptable. The highest load to allowable ratio observed was 85%.
The Unit 2 conduit supports are not included in this program.
These supports are being fully engineered by EBASCO in accordance with procedures established to address all external source issues.
Train C Conduit Program-The objective of this program is to verify that Train C (non-seismic) conduit in seismic Category I areas will not have unacceptable seismic interactions with safety related items.
The generic issue of non-seismic support of Train C conduits had been originally addressed through the CPSES Damage Study Program. That study, however, never considered conduits with two inch and under diameter.
In order to address this issue, TUGC0 performed a sample evaluation to demonstrate that two inch and under conduits are adequately supported.
A sample of 257 conduit runs with 2413 supports was seismically analyzed. The results showed that 233 supports and 14 conduit runs failed the strength criteria and additional runs had sways which cause unacceptable interactions.
As a result of the unfavorable sampling program results, TUGC0 has initiated a new program to close out this issue. A walkdown of all two inch and under Train C conduit in Unit 1 and common areas will be conducted. This includes approximately 13,500 runs with 60,000 supports.
Every support will be evaluated against a new eight level screening criteria. The new screening criteria include:
1)
Several levels of seismic evaluation of conduit supports from simple weight checks to detailed seismic system analysis. The evaluation will be based on a refined (less conservative) acceptance criteria.
2)
Interaction potential check.
- 3) Target impact analysis.
4)
Safe shutdown system analysis.
D. Jeng April 10,1986 Supports which fail all eight levels of screening will be reworked.
Three options will be considered:
- 1) Addition of new seismic restraints (aircraft cable),
- 2) Modification of existing supports, or
- 3) Rerouting the conduits.
TUGC0 presented examples and justifications for the screening criteria at the meeting. A criteria document summarizing the details of the Train C conduit program plan will be available in March.
Very truly yours, h_'s _ A L '
Giuliano DeGrassi GD/dvC. Hofmayer v /
cc:
H. Reich l
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Attendance List C.Y. Chiou EBASCO A. Shaaban EBASCO A. Tuhari EBASCO R.D. Ciatto NRC/TES E. Solla NRC/TES C. Mortgat TERA V. Ferrarini NRC/EAS J. Eidinger IMPELL H.A. Harrison TUGC0 D.C. Jeng NRC -
C.H. Hofmayer BNL/NRC G. DeGrassi BNL/NRC S.G. McBee TUGC0 E.L. Bezkor G8H P. Huang G8H P. Chang TUGC0/B&V C.R. Hooton TUGC0 T.P. Desmond IMPELL J.L. McLean R.L. Cloud K.C. Warapius IMPELL J. Padalino EBASCO i
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Audit Plan Comanche Peak Steam Electric Station Train C Conduit Two Inch and Under (ISAP I.c) i Prepared by Date G. DeGrassi Reviewed by Date C. Hofmayer 4
i Approved by Date D. Jeng Brookhaven National Laboratory Associated Universities, Inc.
Upton, NY 11973 i
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1.0 INTRODUCTION
A TRT review of Train C (non-safety related) conduit support installation in seismic Category I areas of the plant revealed that those conduits less than or equal to two inches in diameter were not supported in a manner consis-tent with seismic requirements. According to Regulatory Guide 1.29 and 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 func-tion of safety-related components or cause injury to plant personnel.
In response to this concern, the Comanche Peak Response Team (CPRT) pro-posed a plan to resolve this issue. This program is documented in Appendix C, Civil / Structural Issue-Specific Action Plan (ISAP) I.c of the CPRT Program Plan.
The purpose of this audit plan is to define the methods to be used by NRC staff and its consultants to review the Train C conduit program methodology and implementation.
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l 2.0 PROGRAM DESCRIPTION In order to resolve this issue, TUGC0 conducted a sample evaluation pro-gram to demonstrate that the conduits are adequately supported. A sample of 257 conduit runs was seismically analyzed but there were an unacceptably large number of support failures. As a result, TUGC0 initiated a new program in-volving 100% reevaluation of all two-inch and under Train C conduit in Unit 1 and common areas. This plan was presented to the NRC in a meeting on February 14, 1986.
The new program involves a walkdown and evaluation of all supports versus an eight level screening criteria. The screening levels are as follows:
1.
Conduit weight less than 6 pounds per foot 2.
Support is a " good" support based on sampling study experience 3.
No interaction potential with Category I targets 4.
Seismic capacity check (in field) 5.
Seismic dynamic analysis check (in office) 6.
Target impact analysis 7.
Safe shutdown system check 8.
Adequate existing seismic restraints Supports which meet any one of eight screening level checks will be considered qualified.
Supports failing all levels will be reworked. Options will include addition of aircraft cable seismic restraint, support modifica-tion, or conduit reroute.
Details of the new program were documented in the Train C Conduit Criteria Document which was issued in March 1986.
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f 3.0 AUDIT METHODOLOGY The audits will represent a comprehensive review of the Train C conduit program to ensure compliance with-R.G. 1.29 and S.R.P. 3.7.2.
All primary documents such as design criteria, procedures and reports will be reviewed.
It is anticipated that a large number of secondary documents such as calcula-l tions and walkdown packages will be generated. These documents will be re-viewed on a sampling basis. The following paragraphs describe the audit meth-i j
ods for the various items to be reviewed by NRR staff and its consultants.
I Additional audits by I&E staff are recommended and described in Section 6.0.
3.1 Criteria Document
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The criteria document describes the details of the Train C conduit plan l
and includes justification of the methodology. This document will be reviewed to ensure conformance with licensing commitments and the CPRT program plan.
1 Emphasis will be placed on the basis for each of the eight screening levels, j
analysis methods and acceptance criteria.
i 3.2 Sampling Study Results i
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The sampling study results report will be reviewed. This will provide important data on probable failure modes and on marginal support types. The review will also verify the adequacy of the justification for screening levels i
1 and 2 (weight and " good supports").
Sample calculations will also be re-l viewed if necessary.
l 3.3 Walkdown Procedure i
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The walkdown procedure document will provide detailed instructions for l
implementing the program plan for the TUGC0 walkdown teams. The document will I
be reviewed to assure compliance with the intent of the plan.
- a 3.4 Analysis Procedures Screen levels 4 through 8 will require either seismic analysis, target analysis or safe shutdown system analysis. All procedures for performing these calculations will be reviewed to assure compliance with licensing requirements.
3.5 Walkdown Results Documentation i
Walkdown results documentation packages will be reviewed on a sampling basis. A sample of 60 conduit runs will be selected on a random basis and reviewed to the extent practical within the time allotted for a one-week site audit by three engineers.
If the sample does not include at least one example
.of application of each screening level and one example of support modification, additional conduit runs will be selected.
This phase of the conduit will include a review of selected calculations associated with the sample, a walkdown of selected runs within the sample and
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a review of design modifications.
i 3.6 CPRT Results Report The final CPRT results report will be reviewed to assure compliance with
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licensing commitments and the program plan.
.3.7 Reports The findings associated with the review of items 3.1 to 3.6 will be documented in a ISAP Evaluation Report in accordance with the following format.
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1.0 Introduction 2.0 'CPRT Approach 3.0 Evaluation 3.1 Evaluation of CPRT Approach 3.2: Evaluation of ISAP Implementation
-4.0 Conclusion Trip reports will also be prepared to document all on-site audit activities, findings and recommendations.
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4.0 SCHEDULE The schedule for the performance of the activities described in Section 3.0 is as follows:
Receipt Date of Estimated Completion Activity / Input Submittal from CPRT Date for Review Criteria Document 3/27/86 5/5/86 Sampling Study Results 5/5/86 6/9/86 Walkdown Procedure 5/5/86 6/9/86 Analysis Procedures 5/5/86 6/9/86 Walkdown Results Documentation 7/7/86 7/25/86 CPRT Results Report 7/31/86 (Draft) 9/30/86(Final) 10/14/86 ISAP Evaluation Report 11/4/86 To support the above activities, the following audit meetings at the Comanche Peak site are anticipated.
Activity Dates 1.
Obtain additional information May 5-7, 1986 2.
Audit Walkdown Results Documentation July 7-11, 1986 Since some of the detailed analysis work will be performed in Impell offices, an additional audit may be required to review calculations associated with the walkdown. This audit would be performed at Impell offices following the walkdown results audit at the site.
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t 5.0 _ PERSONNEL The following personnel will assist'in the performance of the audit activities described in Section 3.0:
i G. DeGrassi* - BNL S. Pepper - BNL P. Bezier - BNL V. Ferrarini - EAS E. Solla - TES
- Audit Team Leader 5
6.0 RECOMMENDED I&E AUDIT ACTIVITIES In order to complete the audit program, it is recommended that ongoing 18E inspection activities include the following:
1.
Verification of proper QA procedure implementation in performing the walkdowns.
2.
Verification of personnel training and qualification of walkdown team members.
3.
Verification of use of controlled procedures for support modifications.
4.
ilardware inspection to assure that fabrication and installation of support modifications conform to controlled drawings and procedures.
5.
Verification that quality control inspection ere complete, well-documented and conform to QC procedures.
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O-Audit Plan Comanche Peak Steam Electric Station Seismic /Non-seismic Damage Study Verification (ISAP II.d) i Prepared by Date G. DeGrassi Reviewed by Date C. Hofmayer I
Approved by Date D. Jeng i
Brookhaven National Laboratory Associated Universities, Inc.
Upton, NY 11973 I
1.0 INTRODUCTION
A TRT review of the seismic design of control room ceiling elements re-vealed deficiencies in the design of non-seismic items. According to Regula-tory Guide 1.29 and FSAR Section 3.7B.2.8, 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 opera-tors. For certain architectural features and small diameter conduits, the TRT
.could. find no evidence that the possible effects of failure of these items has been considered.
In addition to the specific control room ceiling findings, the NRC raised concerns regarding the general methods utilized for addressing potential dam-age to safety-related items caused by non-Category I items throughout the plant.
In response to this concern, the Comanche Peak Response Team (CPRT) prepared a damage study verification plan to resolve this issue. The program is documented in Appendix C, Civil / Structural Issue Specific Action Plan (ISAP) II.d of the CPRT program plan.
The purpose of this audit plan is to define the methods to be used by NRC staff and its consultants to review the damage study verification program methodology and implementation.
2.0 PROGRAM DESCRIPTION The original CPSES seismic /non-seismic interaction study which was per-r formed in 1983, involved ~a walkdown of 287 rooms. All potential interactions were evaluated to the acceptance criteria developed for the study. Methods for resolution of potential interactions consisted of analysis, evaluation, use of barriers, administrative controls, addition of seismic supports or restraints. The design of control room ceiling elements was predicated on the position that architectural features with small masses would not adversely affect control room personnel or safety-related equipment. On that basis, the architectural features in question were excluded from the Damage Study pro-gram.
The CPRT proposed to resolve the NRC concerns through a complete review of the original damage study with specific emphasis on identification of areas which were inappropriately excluded from the study. The major activities of the verification program are summarized below.
1.
A project evaluation of architectural specifications and drawings will be conducted to identify non-seismic sources which were not included in the original damage study. All features which are deter-mined to have seismic interaction potential will either be modified or subjected to a damage study assessment.
2.
A third party review of the architectural features evaluation will be 1
performed. This will include the assessment of features, the damage study and the resolution to unacceptable interactions.
3.
A third party review of the damage study procedures and criteria will be performed. This will determine whether there are other generic areas which may have been omitted from the damage study.
It will include a review of selection criteria for non-Category I items, the design criteria for Category II items, the basis used for determining the physical interaction of items, and the criteria for evaluation of consequences of interactions.
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A third party design review of the implementation of the methods for performing the damage study will be conducted.
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A third party independent damage study will be performed on selected rooms to assess the consistency with which the interactions were identified.
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3.0 AUDIT METHODOLOGY The audits will represent a comprehensive review of the Damage Study Verification Program to assure that NRC concerns are fully addressed and resolved. The following paragraphs describe the audit methods for the various aspects of the program to be reviewed by NRR staff and its consultants.
Additional audits by I&E staff are recommended and described in Section 6.0.
3.1 Project Activities Procedures for the project evaluation of architectural features to identify non-seismic sources will be reviewed in detail. The implementation of the evaluation and the disposition of potential seismic interactions will be reviewed on a sampling basis.
3.2 Third Party Activities It is expected that al's third party activities will be documented in a detailed engineering evaluation report. This report will summarize the review of the architectural features evaluation, the review of the damage study procedures and criteria, the design review of the damage study implementation, and the results of the independent damage study walkdown. The evaluation report will be reviewed in detail.
Calculations and other backup documents will be reviewed on a sampling basis.
3.3 Independent Review of Damage Study The NRC audit team will perform an independent audit review of the damage study methodology and implementation. All procedures will be reviewed.
Walkdowns will be performed in selected rooms and the results will be compared
.with TUGC0 damage study results documentation to assure proper implementation.
3.4 CPRT Results Report The final CPRT Results Report will be reviewed to assure compliance with licensing commitments and the program plan.
3.5 Reports The findings associated with the review of items 3.1 to 3.4 will be documented in an ISAP Evaluation Report in accordance with the following format:
1.0 Introduction 2.0 CPRT Approach 3.0 Evaluation 3.1 Evaluation of CPRT Approach 3.2 Evaluation of ISAP Implementation 4.0 Conclusion Trip reports will also be prepared to document all on-site audit activities, findings and recommendations.
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4.0 SCHEDULE The schedule for the performance of the activities described in Section 3.0 is as follows:
Receipt Date of Estimated Completion Activity / Input Submittal from CPRT Date for Re' view Project Activities 7/7/86 7/28/86 Third Party Activities 7/7/86 7/28/86 Independent Review of Damage Study 7/28/86 8/29/86 CPRT Results Report 7/18/86 (Draft) 9/18/86_(Final) 10/2/86 ISAP Evaluation Report 11/5/86 To support the above activities, the following audit meetings at the Comanche Peak site are anticipated.
Activity Dates 1.
Obtain additional information May 5-7, 1986 2.
Audit damage study results including July 28 - August 1, 1986 sampling of project and third party documentation and perform walkdowns
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t 5.0 PERSONNEL The following personnel will assist in the performance of the audit activites described in-Section 3.0:
'G. DeGrassi* - BNL S. Pepper - BNL P. Bezler - BNL J. Rivard - TES E. Solla - TES V. Ferrarini - EAS 4
- Audit Team Leader 4
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6.0 RECOMMENDED I&E AUDIT ACTIVITIES In order to complete the audit program, it is recommended that ongoing I&E inspection activities include the following:
1.
Verification of use of controlled construction specifications, drawings and procedures for any plant modifications resulting from the program.
2.
Hardware inspection to assure that fabrication and installation of modifications conform to controlled drawings and procedures.
3.
Verification that quality control inspections are complete, well-documented and conform to QC procedures.
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IV 3/11/86 SECTION 2.5.7,
2.5.7 Preoperational Testing (III.d) 2.5.7.1 Introduction This ISA.' addresses an NRC concern that the TRT found that systems test engineers were not on controlled distribution for design changes, therefore, there is not reasonable assurance that previously identified (by the NRC) problems in the document control system (DCC) had no adverse effect on testing activities.
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2.5.7.2 CPRT Approach The CPRT will review the applicable procedures to determine the adequacy of the measures that ensure that startup test engineers (STE) and other test personnel are effectively provided with.the current design. documents for use in testing activities.
In addition, a review of the Startup/DCC interface and interviews with STEs will enable a determination of the adequacy of past and present practices in meeting the requirements of testing programs.
An evaluation program will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which resulted in a testing error. Tnis evaluation will be implemented by sampling of design drawing revisions and change documentation for homogeneous populations of prerequisite tests and preoperational tests.
Identified discrepancies will be processed according to Appendix E and any required corrective action will be implemented in accordance with Appendix H.
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IV 2/11/86 SECTION 2.5.7..
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2.5.7.3 Staff Evaluation The staff's evaluation found that the issue was identified correctly and that the plan's methodology is sufficiently broad in scope and depth to address he concern.
The plan appropriately identifies the areas of activity, the procedures, the types of documents that must be reviewed, and the acceptance and decision criteria that are l
necessary to evaluate and resolve the issue.
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The staff's evaluation of the CPRT program sampling methodology is presented in this report, Section 2.5.7.4 Conclusion The staff's evaluation found that the issue is identified correctly,- and under this Plan the CPRT is reviewing the l
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appropriate documentation that may identify deficiencies which will be evaluated to determine the effect of DCC problems on the test'ing program.
Accordingly, the staff. concludes that t'his ISAP is acceptable.
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'o UNITED STATES 8
NUCLEAR REGULATORY COMMISSION n
WASHINGTON, D. C. 20555 0~**...*~,a DCT1g n NOTE T0: Harold Denton Jim Taylor Bob Martin Darrell Eisenhut i
Dick Vollmer Hugh Thompson Brian Grimes Jane Axelrad Dick Denise Ed Christenbury Ed Jordan FROM:
Vincent Noonan
SUBJECT:
COMANCHEPEAKRESPONSETEAM(CPRT) STATUS C. Haughney recently visited the Comanche Peak site to discuss status and progress with various CPRT managers.
I have enclosed a copy of his trip report for your information. Any NRC management action needed will be identified separately.
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Enclosure:
C. Haughney to V. Noonan dated 10/7/8 I
cc:
R. Heishman l
D. Norkin T. Westeman D. Landers l
S. Treby L. Chandler j
L. Shao l
J. Calvo E. Marinos C. Tramell A. Vietti-Cook H. Livemore C. Hale R. Rohrbacher
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