ML20236P577
| ML20236P577 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/11/1987 |
| From: | Desmond T ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| To: | |
| Shared Package | |
| ML20236P558 | List: |
| References | |
| PROC-871111, TAC-R00281, TAC-R281, NUDOCS 8711180051 | |
| Download: ML20236P577 (63) | |
Text
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COMANCHE PEAK STE AM ELECTRIC STATION UNIT 1 and COMMON
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CORRECTIVE ACTION PROGRAM 1
l PROJECT STATUS REPORT CONDUIT SUPPORTS TRAIN C 2 INCH DIAMETER AND LESS
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TU ELECTRIC COMANCHE PEAK STEAM ELECTRIC STATION I
.l UNIT 1 AND COMMON' l
IMPELL CORPORATION
~ PROJECT STATUS REPORT l
CONDUIT. SUPPORTS TRAIN C.THO-INCH DIAMETER AND LESS j
O, n-Thomas 4. Desmond l
Section Manager l
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TABLE.0F-CONTENTS-l
'. Section Title Eagg-EXECUTIVE
SUMMARY
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- ABBREVIATIONS AND ACRONYMS'
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1.0 INTRODUCTION
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1 Figure 1-1 Train C Two-Inch Diameter And Less Conduit And Conduit Supports Corrective Action Program (CAP) 2.0 PURPOSE 2-1 3.0' SCOPE 3-1 4.0.
SPECIFIC ISSUES 4-1 5.0-CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS 5-1 5.1 METHODOLOGY AND MORK PERFORMED 5-1 l
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5.1.1.
Licensing Commitments,' Design Criteria and Procedures 5-1 5.1.1.1 Verification of Design Criteria, Procedures and 5-1 Resolution of Issues 5.1. 2..
Design Validation Process 5-4 i
s 5.1.2.1.
Validation Method 1--No Interaction Potential
.5.1.2.2 Validation Method 2--Acceptable Interaction
. 5 5-5 5.1.2.3 Validation Method 3--Structural Integrity 5 5.1.2.4 Modification Methods 5-7 5.1.2.5 Cygna Independent Assessment Program (IAP) Issue Review 5 5.1.2.6
~ Technical Interfaces with Other Organizations 5-7 5.1.2.7 Final Reconciliation Process 5-8 5.1.3 Post Construction Hardware Validation Program (PCHVP) 5-8 5.2 RESULTS 5-13 5.2.1 Conduit Design Validation Results 5-13 5.2.2 Post Construction Hardware Validation Program (PCHVP) Results 5-13 5.3 QUALITY ASSURANCE (QA) PROGRAM 5-14 5.3.1 Impe11 Quality Assurance (QA) Audits 5-16 5.3.2 TU Electric Technical Audit Program (TAP) Audits 5-17 i
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Section Title g
5.4 CORRECTIVE AND PREVENTIVE ACTIONS 5-18 Figure 5-1 Design Validation Process j
Figure 5-2 Examples of Tested Components Figure 5-3 Corrective Action Program (CAP) Technical Interfaces, Train C Two-inch' Diameter and Less Conduit and Conduit Supports Figure 5-4 Typical Interaction Zones l
Figure 5-5 Post Construction Hardware Validation Program (PCHVP)
Figure 5-6 Correlation of Project Instructions with Design Validation Process Table 5-1 List of Project' Instructions Table 5-2 Post Construction Hardware Validation Program (PCHVF)
Train C Conduit Attribute Matrix i
Table 5-3 Summary of TU Electric Technical Audit Program (TAP) Audits
6.0 REFERENCES
6-1 APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL ISSUES A-1 ii
k EXECUTIVE
SUMMARY
This' Project Status Report (PSR) summarizes the systematic validation process for the Train C two-inch' diameter.and less conduit and conduit support Corrective Action ~ Program (CAP) implemented by Impell Corporation (Impell) at Comanche Peak Steam Electric Station (CPSES) Unit I and Common.'
It presents 'the results of the design validation and describes the Post Construction Hardware' Validation Program (PCHVP).
Impell activities are governed by the TU Electric Corrective Action Program (CAP) which requires Impell to:
1.
Establish consistent CPSES Train C two-inch diameter and less conduit and conduit support design criteria that complies with the CPSES licensing commitments; 2.
Produce design' control procedures that assure compliance with design criteria; 3.- Evaluate systems. structures, and components, and direct the corrective actions recommended by the Comanche Peak Response Team (CPRT) and those determined.by. Corrective Action Program (CAP) investigations to be necessary to demonstrate that systems, structures, and components are in conformance with the design; 4.
Assure that the validation resolves the Train C two-inch diameter and less conduit and conduit support design and hardware issues identified by the Comanche Peak Response Team (CPRT)2. external i
Q sources 3, and the Corrective Action Program (CAP);
I Common refers to areas in CPSES that contain both Unit I and Unit 2 systems, structures, and components.
2 Comanche Peak Response Team (CPRT) Issues are identified by the following:
CPRT Design Adequ'acy Program (DAP)
CPRT Quality of Construction Program (QOC) 3 External Issues are identified by the following:
NRC Staff Special Review Team (S'T-NRC)
R NRC Staff Special Inspection Team (SIT)
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NRC Staff Construction Appraisal Team (CAT)
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Citizens Association for Sound Energy (CASE)
Atomic Safety and Licensing Board (ASLB)
NRC Region IV Inspection Reports NRC Staff Technical Review Team (TRT) [SSERs 7-11]
CYGNA Independent Assessment Program (IAP)
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- 5. ' Validate'that the design of_ Train C two-inch diameter and less~-
h conduit and conduit support's are in conformance with the licensing n
commitments and that the. installed hardware is in conformance with ~
the validated design;'
- 6. LProduce consistent-and validated design documentation.
c Consistent ' design criteria and methodologies for CPSES Train C two-inch diameter and less conduit'and conduit supports have been' developed and used.by 1
Impe11 for the design validation process.
These design criteria and methodologies: conform with-the CPSES, licensing-commitments and have been independently and extensively reviewed and accepted by the Comanche Peak Response Team.(CPRT).
-Impe11 developed design control procedures:to implement the design criteria and. methodologies described below, and to govern work flow and technical o
interfaces with other disciplines for'both the design and hardware' validation processes. These procedures specify the processes (such as, the. validation of conduit support input, checklists, documentation control and final reconciliation for Train C two-inch diameter and less conduit and conduit supports) which have been implemented throughout the Train C two-inch diameter and less conduit and conduit support Corrective Action Program (CAP).
Impe11 performed tests,. analyses and evaluations to develop documented acceptance criteria for the design validation methods.- These acceptance
. criteria.were used to validate the design of all CPSES Train C two-inch
, O diameter and less conduit and conduit supports in Unit 1 and Common,d The
-(DVPs) which contain validation for approximately 105,000 conduit supports.
The as-built hardware for these conduit supports is being validated to the design by'the Post Construction Hardware Validation Program (PCHVP).
.The conduit and conduit support related design and hardware issues identified
- by the Comanche Peak Response Team (CPRT), external sources, and-the Corrective Action Program (CAP) have been resolved by incorporation of methodologies and' design criteria into the Impell design validation procedures
'and the Post Construction Hardware Validation Program (PCHVP.) implementation procedures.~ Consequently, the validated design of the CPSES Train C two-inch diameter and less conduit and conduit supports has resolved these issues.
The Post Construction Hardware Validation Program (PCHVP) assures that the Train C two-inch diameter and less conduit and conduit supports are installed in conformance with the validated design.
Impell has reviewed and revised the CPSES Train C two-inch diameter and less conduit and conduit support installation specification, construction procedure, and field verification f
procedures to assure that the validated design requirements are implemented.
The Post Construction Hardware Validation Program (PCHVP) for Train C two-inch diameter and less conduit and conduit supports, including field verifications and engineering evaluations, implements the corrective actions recommended by i
the Comanche Peak Response Team (CPRT), as well as those required by the Corrective Action Program'(CAP) investigations.
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7'T Impell will provide TV Electric the validated design documentation for CPSES V
Train C two-inch' diameter and less conduit and conduit supports, including the calculations, drawings, design changes and discipline interface transmittals.
This documentation, in conjunction with the. updated specification and procedure, can provide the basis for CPSES configuration contro14 to facilitate maintenance and operation throughout the life of the plant.
In-depth quality and technical audits performed by Impell Quality Assurance and TU Electric Technical Audit Program (TAP) verified that implementation of the validation program was in conformance with 10CFR50, Appendix B quality assurance requirements.
In addition, the Third Party overview performed by TENERA, L.P. (TERA) for the Comanche Peak Response Team (CPRT) verified that the Impe11 procedures and the established design criteria complied with the licensing commitments.
1 The Unit 1 and Common Train C two-inch diameter and less conduit and conduit support Corrective Action Program (CAP) validates that the:
Design of the conduit and conduit supports complies with the CPSES licensing commitments; As-built conduit and conduit support hardware complies with the validated design.
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Configuration controi is a system to assure tnat the design and nardware remain in compliance with the licensing commitments throughout the life of the plant.
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'ASUM A
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'ANCO Anco Engineers. Inc.
ANSI-American National Standards Institute y
ASLB-
~ Atomic Safety and Licensing Board j
. Corrective Action Program 4
. CAR Corrective Action Request CASE Citizens-Association for Sound Energy l
L CAT Construction Assessment Team
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i CCL Corporate Consulting Development Company, Ltd.
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CFR-Code of Federal. Regulations
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CPE Comanche Peak Engineering-(TU Electric)
CPRT Comanche Peak Response Team (TV Electric)
CPSES Comanche Peak Steam Electric Station 1
CYGNA CYGNA Energy Services J
DAP Design Adequacy Program (CPRT)
DBCP Design Basis Consolidation Program DBD Design Basis Document DCA Design Change Authorization DIR Discrepancy Issue Report (CPRT-DAP)
DR Deviation Report DVP Design Validation Package EBASCO Ebasco Services Incorporated FCR Field Change Request 1
FSAR Final Safety Analysis Report FVM Field Verification Method n
IAP Independent Assessment Program (CYGNA)
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.V IMPELL Impe11 Corporation ISA-Intermediate Storage Area l
ISAP
' Issue Specific Action Plan (CPRT)
MHF Multi-Mode Factor NRC United States Nuclear Regulatory Commission NCR Nonconformance Report NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Commission Report OBE Operating Basis Earthquake PCHVP Post Construction Hardware Validation Program PSR.
Project Status Report QA Quality Assurance 00C Quality of Construction RG Regulatory Guide RIL Review Issues List SDAR Significant Deficiency Analysis Report (TV Electric)
SER Safety Evaluation Report (NRC, NUREG-0797)
SIT Special Inspection Team (NRC Staff)
SRP Standard Review Plan (NUREG-0800)
SRSS Square-Root-of-the-Sum-of-the-Squares l
SRT Senior Review Team (CPRT) l SRT-NRC Special Review Team (NRC)
SSE Safe Shutdown Earthquake SSER Supplemental Safety Evaluation Report (NRC, NUREG-0797)
SHEC Stone & Hebster Engineering Corporation vi 4
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ABBREVIATIONS AND ACRONYMS
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SHEC-PSAS Stone & Webster Engineering Corporation-Pipe Stress and Support Project (SHEC)
TAP Technical Audit Program (TU Electric) l TERA TENERA, L.P.
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TRT Technical Review Team (NRC Staff, SSERs 7-11) l 1
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1.0. INTRODUCTION In October 1984, TU Electric established the Comanche Peak Response Team (CPRT) to evaluate the issues that have been raised at CPSES and to prepare a plan for resolving those issues. The CPRT program plan was developed and submitted to the NRC.
In mid-1986, TV Electric performed a qualitative and quantitative review of the preliminary results of the Comanche Peak Response Team (CPRT) (References
.32 and 33). This review identified that the Comanche Peak Response Team (CPRT) findings were broad in scope and included each discipline.
TU Electric decided that the appropriate method to correct the issues raised and to identify and correct any other issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue.
TU Electric decided to initiate a comprehensive Corrective Act:on Program (CAP) to validate the entirety of CPSES safety-related designs, 2, The scope of the CAP has the following objectives:
Demonstrate that the design of safety-related systems, structures and components ccmplies with licensing commitments.
Demonstrate that the existing systems, structures and components are in compliance with the design or develop modifications which will bring systems, structures and components into compliance with design.
Develop procedures, an organizational plan, and documentation to maintain compliance with licensing commitments throughout the life of O.
cests-The Corrective Action Program (CAP) is thus a comprehensive program to validate both the design and the hardware at CPSES, including resolution of specific Comanche Peak Response Team (CPRT) and external issues.
I Portions of selected non-safety-related systems, structures and components are included in the Corrective Action Program (CAP).
These are Seismic Category II systems, structures and components, and Fire Protection Systems.
2 NSSS design and vendor hardware design and their respective QA/QC programs are reviewed by the NRC independently of CPSES and are not included in the Corrective Action Program (CAP) as noted in SSER 13; however, the design interface is validated by the CAP.
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1 TV Electric contracted and provided overall management to Stone & Hebster c)
Engineering Corporation (SHEC), Ebasco Services Incorporated (Ebasco), and l
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Impe11 Corporation (Impe11) to implement the Corrective Action Program (CAP),
and divided the CAP into eleven disciplines as follows:
Responsible Discioline Contractor Mechanical SHEC
- Systems Interaction Ebasco
- Fire Protection Impe11 Civil / Structural SHEC f
Electrical SHEC Instrumentation and Control SHEC l
Large Bore Piping and Pipe Supports SHEC-PSAS Cable Tray and Cable Tray Hangers Ebasco/Impell l
ConduitSupportsTrainsA,B.&C>2" Ebasco Conduit Supports Train C 12" Impell Small Bore Piping and Pipe Supports SHEC-PSAS HVAC Ebasco i
Equipment Qualification Impe11 l
1 A Design Basis Consolidation Program (DBCP) (Reference 2) was developed to define the methodology by which Impe11 performed the design and hardware validation.
The approach of this Design Basis Consolidation Program (DBCP) is i
consistent with other contractors' efforts and products.
O The design v lidation portion of the Corrective Action Program (CAP) identified the design-related licensing commitments. The design criteria were established from the licensing commitments and consolidated in the Design Basis Document (DBD) (Reference 3).
The DBD identifies the design criteria I
for the design validation effort.
If the existing design did not satisfy the 1
design criteria, it was modified to satisfy the criteria.
The design validation effort for the eleven Corrective Action Program (CAP) disciplines is documented in Design Validation Packages (DVPs).
The DVPs provide the documented assurance (e.g., calculations and drawings) that the validated design meets the licensing commitments, including resolution of all Comanche l
Peak Response Team (CPRT) and external issues.
l The design validation effort revised the installation specification to reflect the validated design requirements.
The validated installation specification also contains the field verification requirements necessary to assure that the as-built hardware complies with the validated design.
l The hardware validation portion of the Corrective Action ' rogram (CAP) is P
l being implemented by the Post Construction Hardware Validation Program l
(PCHVP), which demonstrates that existing systems, structures, and components l
are in compliance with the installation specification (validated design), or l
l identifies modifications that are necessary to bring the hardware into compliance with the validated design.
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h The results of the performance of the Corrective Action Program (CAP) for each-discipline are described in a Project Status Report (PSR). This PSR describes i
the results for the Train C two-inch diameter and less conduit CAP.
Impe11 was contracted'by TU Electric in 1985 to evaluate.the Train C two-inch
' diameter and less. conduit and conduit supports. When the Corrective Action Program (CAP) was created in 1986, it incorporated and expanded upon Impe11's existing program., The CAP for Train C'two-inch diameter and less conduit and conduit supports consists of, activities performed by Impe11 and is shown schematically in Figure 1-1._'Impe11 has performed a comprehensive validation of Train C two-inch diameter and less conduit and conduit supports for CPSES Unit 1 and Common to demonstrate that the design complies with licensing-commitments. The validation process was conducted in accordance with the Impe11 Design Basis Consolidation Program (DBCP)'(Reference 2), which' controls implementation of the Train C two-inch diameter and less conduit and conduit support portion of the TU Electric Corrective Action Program (CAP).- The design basis for Train'C two-inch diameter and less conduit and. conduit supports portion of the CAP is contained within its Design Basis Document (DBD).
- The CPSES Train C two-inch diameter and less conduit and conduit supports were validated by evaluation of the conduit and conduit supports' structural integrity.or their potential interaction with Seismic Category I systems, structures or components. Results and methodology used in implementing both the design and hardware-related validations for Train C two-inch diameter and less conduit and conduit-supports in Unit I and Common are presented in this-Project Status Report (PSR).
This Project Status Report (PSR) describes the validation effort from design criteria establishment thr;; ugh development and implementation of design and design contro1~ procedures.
This PSR describes the updating of the installation specification and construction procedure, the implementation of
'the Post Construction Hardware Validation Program (PCHVP), and the incorporation of the Train C two-inch diameter and less conduit and conduit i
supports evaluation into Design Validation Packages (DVPs).
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FIGURE 1-1
/\\U TRAIN C THO-INCH DIAMETER AND LESS CONDUIT AND CONDUIT SUPPORTS CORRECTIVE ACTION PROGRAM (CAP)
- DENTIFY LICENSING I
FSAR COMMITMENTS g
- CTNER LICENSING DOCUMENTS DEVELOP DESIGN SAS13 DOCUMENTS (DSDel PERFORM DESIGN I
- CPRT(DAP S 00C) ISSUES VALIDATION I
EXTERNAL ISSUES.
NRC(SRT Si?. TRT CAT)
CYGNA (IAP)
. CASE
.ASLS NRC (NSPECTION REPORTS MOOlFICATIOg
.YES OESNBN REculRED r
MODIFICAT10NS T
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u POST CONSTRUCTION NARDWARE VALIDATION %
SUILD/ INSPECT PROGRAM (PCNVP)
MODimCATION FINAL DESIGN RECDMCILIATION IS YES A00ffl0NAL VALIDATION REQUIRED T
NO FINAL DOCUMENTAflON (DESIGN VAtl0AflON PACKAGES)
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2.0 PURPOSE This Project Status Report (PSR) demonstrates that the Train C two-inch diameter.and less conduit and conduit support design in Unit 1 and Common is-in conformance with the CPSES licensing commitments and satisfy the design criteria.
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3.0 SCOPE The scope of the Corrective Action Program (CAP) implemented for CPSES Unit 1 and Commpn includes all Train C two-inch diameter and less conduit and conduit 2
supports'.
Train C is neither safety-related nor Seismic Cateogory I,
Train C is not required to remain fun'ctional during or after a Safe Shutdown Earthquake (SSE) and is comprised of non-safety-related Seismic Category II3 and non-safety-related non-seismic 4 two-inch diameter and less conduit and conduit supports.
The Train C Corrective Action Program (CAP) contains a design validation portion and a hardware validation portion to assure that the design documentation is consistent with the as-built hardware.
This Project Status Report (PSR) describes the Train C Corrective Action Program (CAP) as implemented by linpell for Unit 1 and Common.
The features of the Train C CAP include:
1.
Establishment of conduit and conduit support design criteria which comply with licensing commitments; 2.
Development of the Design Basis Document (DBD) for CPSES Train C which contains the design criteria.
This Design Basis Document (DBD) can provide assurance that the licensing commitments are complied-with throughout the life of the plant; O
i wereinarter. Train C two-incn diameter and ies, conduit and conduit supports will be referred to as Train C.
2 Structures, systems, and components that are designed and constructed to withstand the effects of the Safe Shutdown Earthquake (SSE) and remain functional are designated as Seismic Category I in accordance with the requirements of NRC Regulatory Guide 1.29 (Reference 5).
3 Those portions of structures, systems, or components whose continued function is not required, but whose failure could reduce the functioning of any Seismic Category I structure, system or component required to satisfy the requirements of Regulatory Guide 1.29 to an unacceptable 1
safety level or could result in incapacitating injury to occupants of the control room, are designated Seismic Category II and are designed and constructed so that the Safe Shutdown Earthquake (SSE) would not cause such failure.
4 Those portions of structures, systems, or components whose continued function is not required, and whose failure will not reduce the functioning of any Seismic Category I system or component required to satisfy the requirements of Regulatory Guide 1.29 to an unacceptable l
safety level and will not result in incapacitating injury to occupants of the control room, are designated as non-seismic.
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Implementation of design and hardware validation consisting of f}
analyses, identification and implementation of necessary l
N modifications, as well as field verifications as identified in the Post Construction Hardware Validation Program (PCHVP).
The as-built design of Train C is validated by field verifications and engineering evaluations.
Evaluation results are documented in one Unit 1 and Common Train C Design Validation Package.(DVP). The other DVP contains validated design criteria; 1
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Resolution of the design and hardware-related issues of CPSES Train C and implementation of a Corrective Action Program (CAP) for closure of these issues.
These issues include external issues and Comanche Peak Response Team (CPRT) issues; q
5.
Developmer.t of the validated design documentation to form the basis for configuration control of CPSES Train C.
The validated design documentation and the updated procedure / specification will be i
provided to TV Electric to facilitate operation, maintenance, and i
future modifications following issuance of an operating license.
l Section 5.0 addresses the program methodology and results for the Train C Corrective Action Program (CAP). A summary is given below.
1 Section 5.1 describes the methodology and work performed.
It addresses licensing commitments, design criteria and procedures.
It addresses the design validation processes and the Post Construction Hardware Validation Program (PCHVP).
Section 5.2 describes the Train C Corrective Action Program (CAP) results.
It addresses design validation results and the Post Construction Hardware j
Validation Program (PCHVP) results.
Section 5.3 describes the Quality Assurance (QA) program.
It addresses the.
-l Impe11 QA audits and TU Electric Technical Audit Program (TAP) audits.
Section 5.4 describes corrective and preventive actions.
Appendix A describes the resolution of Comanche Peak Response Team (CPRT) and external issues.
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4.0' SPECIFIC ISSUES The Train C Corrective Action Program (CAP) resolved all the related Comanche Peak Response Team (CPRT) and external issues.
This'section. lists all Train C' related issues addressed in this Project Status Report (PSR);n Technical review,. resolution and corrective action of all external and Comanche. Peak Response Team (CPRT) issues-are ' described in Appendix A.
The' Comanche'PeakResponseTeam(CPRT)contractedTENERA,i..P.(TERA)to perform a Third Party overview. TERA reviewed the completeness and adequacy.
of.these issues /re.;olutions. The results 'of the Third Party overview are.
I presented by-TERA in the Issue Specific Action Plan (ISAP) Results.Reporti (Reference 1).
The' Comanche Peak Response Team (CPRT) and external issue is given below.
s (issue number corresponds to subappendix number in Appendix A).
f-Issue No.
Issue Title Al-Train C Conduit and Supports O
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5.0 CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS l
This section of the Project Status Report (PSR) addresses the methodology and work performed for the Train C portion of the Corrective Action Program
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(CAP). This section addresses the establishment of design criteria in J
conformance with CPSES licensing commitments, the development of procedures and the implementation of the design validation process and the Post j
Construction Hardware Validation Program (PCHVP). This section describes the i
results of the Corrective Action Program (CAP), Quality Assurance program (QA) and the corrective and the preventive actions identified by the CAP.
y 5.1 METHODOLOGY AND HORK PERFORMED The methodology and work performed by Impell in implementing the Corrective Action Program (CAP) for Train C are discussed in the following sections.
5.1.1 Licensing Commitments, Design Criteria and Procedures Licensing commitments for the Train C were identified by Impe11 through a review of CPSES licensing documentation (such as the FSAR, NRC Regulatory Guides, NRC Inspection and Enforcement Bulletins and NRC/TU Electric correspondence). Based on these licensing commitments, design criteria were established which set forth requirements for validation of Train C.
The design criteria are docurented in the Design Basis Document (DBD).
Impe11 then developed design procedures (Table 5-1) which were based on the fc11owing:
Design Criteria i
Resolution of Comatche Peak Response Team (CPRT) and external issues Impe11 experience gained through the seismic evaluation of components designed for other United States commercial nuclear power plants Regulatory guides and professional engineering societies' codes and standards (Reference 13 for cold-formed steel components and Reference 14 for hot-rolled steel components), and the NRC Standard Review Plan In addition, Significant Deficiency Analysis Reports (SDARs) (10CFR50.55(e)) and Corrective Action Reports (CARS) pertaining to Train C were reviewed. All technical issues identified were resolved and included in the Train C Corrective Action Program (CAP) procedures.
Impe11's design procedures used a multi validation method approach based on the NRC Standard Review Plan (SRP) 3.7.2 (Reference 6).
This multi validation method approach is described in Section 5.1.2 of this PSR.
5.1.1.1 Verification of Design Criteria, Procedures, and Resolution of Issues Tests, engineering studies, technical audits, and i. Third Party overview were performed to assure that the design criteria and procedures embodied the Train C 1
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11c'ensing' commitments and the resolution of all Comanche Peak Response Team.
'(CPRT)'and external issues.
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Tests Tests were used to establish load capacities and to confirm seismic behavior.
of.-Train'C conduit and conduit support components.
Based on these test results, design criteria were established.
The tests are described below.
1 The majority of the Train C conduit supports are' constructed from Unistrut 4
components.
Corporate Consulting and Development Co.,~Ltd. (CCL) performed.
tests (References 24,~25, and 26) for Various Unistrut components, including welded foot-hangers. (Figure 5-2(a)) and.a; variety of clamps and fittings (examples.are shown:in Figure 5-2(b)).
Both static load-defection and cyclic
-. tests were performed.
For the static. tests, a.monotonically increasing load was applied to develop a load deflection curve.
For the cyclic. tests, a load was cycle'd at a prescribed displacement to obtain an ultimate capacity.
In addition, other tests (References 29 and-30) were used to= establish,
- respectively: (a), load capacities for one-bolt conduit finger clamps. (Figure
.5-2(c)); and'(b) fatigue capacities for Unistrut members (Figure 5-2(d)) and threaded rod components (Figure 5-2(e)).
Impe11 used these test results to j
establish component allowable loads which were incorporated into the design
- cri teria.
Tests performed by Corporate Consulting and Development Co., Ltd. (CCL)-
(Reference 8) and other industry tests (Reference 9) were used by Impell to establish allowable loads for Hilti Kwik bolt concrete anchorages.
6 Reference 9 summarizes these tests, which included.over 800 static tests and V
45 cyclic tests. Some static tests were in-situ tests performed at CPSES, and others were laboratory tests' performed with concrete mix properties representative of those used at CPSES. Cyclic tests showed that~
earthquake-type loading does not. affect the ultimate strength of Hilti bolt i
installations, when compared to the ultimate strength obtained from static tests.
s ANCO Engineers, Inc.-(ANCO) performed dynamic shake-table tests (Reference 10) to confirm the use of seven percent of critical damping for the dynamic analysis of Train C.
The test configuration was representative of Train C conduit and conduit support structures installed at CPSES.
It was mounted to the shake table and subjected to simulated seismic motions.
The dynamic response was monitored and recorded. The response from the test was compared l
to analytically-predicted responses computed at various damping values.
The analyses used in the comparison were based on an analytical model of the i
tested structure.' The com the validation process.
parisons confirmed the seven percent damping used in Enaineerina Studies Engineering studies were used to confirm Train C component behavior, establish Train C conduit support load capacities, and develop Train C design criteria.
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l Examples of such studies are:-
Computer analyses,of conduit support baseplates to determine prying-factors to be used for anchor bolt analysis l.
Computer analyses of conduit and conduit structural systems to l
-(a) verify design criteria for certain support types, and (b) validate L
. support structural integrity for the supports within the systems-analyzed.-
l TU Electric Technical Audit Proaram L
The TU Electric Technical Audit Program (TAP) is auditing the Corrective j
Action. Program (CAP) to assure that the design criteria are in compliance with the licensing commitments.
Third Party Overview Results TENERA, L.P. (TERA), the lead contractor for the Comanche Peak Response Team l
(CPRT) Design Adequacy Program (DAP), conducted the Third Party overview to I
assure that all CPRT and external issues were clearly identified and resolved in accordance with the CPRT Issue Specific Action Plan I.c (ISAP I.c).
The
~ cope of..the Third Party overview included:
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external source issue identification design criteria / commitment identification walkdown procedures review seismic analysis procedures review s
special studies review test programs review issue resolution review During. the performance of the CPRT-DAP, TENERA, L.P. (TERA) identified and documented discrepancies in Discrepancy Issue Reports (DIRs).
Impell has responded to and closed all 51 DIRs. received from TERA.
TENERA, L. P. (TERA) has completed the Third Party overview and has presented
.the results in the Issue Specific Action Plan (ISAP) Results Report for Train C (Reference 1). TERA states in'Section 6.0 of Reference 1 that:
"The third party has concluded that Impell's Train C conduit / supports seismic qualification program is comprehensive and capable of meeting the FSAR and licensing commitments and resolving known technical issues."
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5.1.2 Design Validation Process Train C conduit and conduit supports are neither safety-related nor Seismic Category I;'therefore, they are not required to remain functional during and after the Safe Shutdown Earthquake (SSE).- The failure (that is, not maintain structural integrity) of Train C has no safety significance provided its failure does not (a) reduce the functioning of any Seismic Category I system, structure, or component to an unacceptable safety level or (b) result in an incapacitating injury to occupants of the Control Room.
To assure that licensing commitments for Train C were met, three design validation methods were used.
Validation Method 1--No Interaction Potential. Validated that Train C conduit and conduit supports if they were to collapse would not strike Seismic Category I systems, structures, or components.
Validation Method 2--Accentable Interaction. Validated that Train C conduit and conduit supports if they were to collapse would not reduce the functioning of any Seismic Category I system, structure or component.
Validation Method 3--Structural Intearity. Validated that Train C conduit and conduit supports were evaluated and designed to prevent failure under Safe Shutdown Earthquake (SSE) conditions.
Design modifications were made when Train C could not be design validated O
using the three validation methods described above.
Three design modification methods were used.
Modification Method 1--Modify Suonort. The Train C conduit support was structurally modified to assure structural integrity, or else additional j
Train C conduit supports were designed to further support the conduit.
Modification Method 2--Provide Seismic Restraint Cable. Restraint cables i
were used to restrain the conduit and provide conduit supports if they were postulated to fail.
Modification Method 3--Reroute Conduit. The conduit was rerouted and supported by new conduit supports. The conduit and new supports were evaluated and designed to prevent failure under the Safe Shutdown Earthquake (SSE) conditions.
The design validation process starts with one of the above validation methods.
Examples where each validation method would be used first in the design validation process are described below. Validation Method I was used if Train C was located in a non-Seismic Category I building or area, where there are no Seismic Category I systems, structures, and components.
Validation Method 2 was used if Train C was postulated to fail and impact a Seismic Category I system, structure or component. Validation Method 3 was used for Train C located in areas of the Control Room where structural integrity was required to prevent incapacitating injury to occupants of the Control Room.
5-4
Figure'5-1 is a' flow chart showing the design validation process.. The process n
includes the three design validation methods and three design modification U
methods' described above..All design modification methods assured that Train C conduit and conduit supports would not fail in such a manner to adversely affect Seismic Category I systems, structures, or components, and therfore, design validated the support.
The design validation process for Train C is described in more detail in the following sections. Corrective Action Program (CAP) personnel, trained to the r
Impe11 technical instructions listed in. Table 5-1, obtained all required as-built information by field walkdown as per Reference 31.
5.1.2.1 Validation Method 1--No Interaction Potential This validation method was used to validate Train C conduit and conduit supports that were postulated to fail but would not impact Seismic Category I systems, structures or components. To assess whether or not Train C would impact a Seismic Category I. system, structure or component, calculations were' performed to develop an interaction zone.for (a) free-falling Train C, and (b) swinging or pendulum-type seismic motion of Train C.
Figure 5-4 shows typical interaction zones.
If the Seismic Category I system, structure or component (target) was.not contained in the interaction zone of Train C (source), then the portion of Train C under evaluation was validated.
The steps taken by engineers performing field verification to validate Train C using this method were as follows:
1.
Identification of Seismic Category I systems, structures, and O
components (targets) 2.
Determination of Train C (sources) which would not interact with these targets 3.
Documentation of work performed.
5.1.2.2 Validation Method 2--Acceptable Interaction This validation method was used to validate Train C conduit and conduit supports that were postulated to impact Seismic Category I systems, structures or components, but would not adversely affect or cause a reduction in the function of those Seismic Category I systems, structures, or components.
(An interaction between a Train C conduit or conduit support and a Seismic Category I system, structure or component is hereinafter referred to as a source-target interaction.)
Source-target interaction evaluation by engineers performing field verification consisted of:
O 5-5
1.
Identification of Seismic. Category I systems, structures, and components (targets) 2.
Determination of Train C (sources) which could interact with'these targets 3.
Assessment of whether or not a postulated source failure could adversely affect or cause a reduction in the function of these. targets 4.
Documentation of work performed.
The ability of a Seismic Category I system, structure or component to withstand impact depends on (a) features of the Seismic Category I system, structure, or component, such as size, mass, the material and type of construction, (b) features of the Train C conduit and conduit' supports, such as size, mass, material and type of construction, and (c) the drop height or lateral swing distance of the Train C conduit and/or conduit supports to the target. Procedures (Tables 5-1) for evaluating _ impacts.during source-target-i interaction were provided in the project technical. instructions.
5.1.2.3 Validation Method 3--Structural Integrity Hhere structural integrity of Train C. conduit supports was required, the as-built information (design attributes) was obtained by field verification conducted by Corrective Action Program (CAP) personnel trained in accordance with the appropriate project procedures (Table 5-1).
Examples of as-built information obtained are conduit diameter, conduit spans between supports,
.A support characteristics, support location, and adjacent support
.V configuration.
The results of these field verifications were used as design input for structural integrity evaluations.
For certain frequently used support types, engineering calculations were performed to obtain capacities prior to field verification of these supports.
Structural integrity of such supports was then validated by field verification to assure that the as-built attributes were consistent with those attributes used in the engineering calculations.
For other supports, structural integrity was validated by performing engineering evaluations on a case-by-case basis.
Existing Seismic Category II restraints (also known as cable restraints) which had been previously designed and installed for other Seismic Category II components were checked to assure that they would sustain the additional incremental loads due to postulated failures of Train C.
L To calculate the stresses or loads for a conduit support, the Equivalent
' Static Method or the Response Spectrum Method was used.
These are described below.
The Equivalent Static Method calculated stresses or loads for components of the support.
In the two horizontal orthogonal directions, the equivalent static load consisted of the Safe Shutdown Earthquake (SSE) seismic load.
In the vertical direction, the equivalent static load consisted of the SSE seismic load absolute summed (ASUM) with the gravity load.
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a
The equivalent static SSE load was obtained by determining the condult/ support fundamental frequency, obtaining the acceleration from the seismic response
- spectrum corresponding to the fundamental frequency, and multiplying this acceleration by the mass of-the conduit run and the support self-weight.
The acceleration was multiplied by a multi-mode factor (Reference 27) to account for the analytical representation of a conduit / support'as a single degree of freedom system.
Alternatively, equivalent static-SSE loads could be -
determined by multiplying the peak acceleration with an appropriate multi-mode factor. Using the peak acceleration eliminates the need for calculation of the fundamental system frequency.
Both are consistent-with the FSAR, regulatory guidances,'and licensing commitments.
The Response Spectrum Method is another method for calculating seismic loads.-
In this method, the conduit and conduit supports were analytically modeled and subjected to gravity and Safe Shutdown Earthquake (SSE) loads.
Vibration modes up to 33 Hertz (or the rigid cut-off frequency) were included. High frequency (greater than 33 Hertz) mass participation was included in determining the load.
The stresses or loads that were predicted using the Equivalent Static or Response Spectrum Methods were then compared with the allowable stresses or loads defined by the acceptance criteria. To design validate the support, it
'l was assured that the allowable stresses or loads exceeded those predicted by the Equivalent Static or Response Spectrum Methods.
5.1.2.4 Modification Methods O
Nhen Train C could not be validated by using one of the design validation methods, one of the three design modification methods described previously in Section 5.1.2 was used. As-built information was obtained to determine the appropriate design modification. This information was used to develop the design modification which assured structural integrity and design validated the support. After the modification was installed, Corrective Action Program (CAP) personnel performed a field verification to document and verify that the installation was in accordance with the validated design drawing.
5.1.2.5 Cygna Independent Assessment Program (IAP) Issue Review Impell also performed an extensive review (Reference 23) of issues identified by the Cygna Independent Assessment Program (IAP) on the Trains A and B conduit and conduit supports (Reference 22). All applicable issues were reviewed to determine their impact on the Train C program.
Impe11 resolved all applicable issues by incorporating the necessary preventive and corrective j
actions into the Train C Corrective Action Program (CAP).
5.1.2.6 Technical Interfaces With Other Organizations The technical interfaces between Impe11 and other organizations for Train C conduit'and conduit supports are shown schematically in Figure 5-3.
Procedures have been established (References 20 and 21) which control the interface activities between Impell and other organizations.
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l Conduit support loads at attachments to other commodities were provided for 7.
(V acceptance to SWEC Civil Structrual Group, SHEC-PSAS Group, Ebasco/Impell Cable Tray and Cable Tray Hanger Group, Ebasco HVAC Supports Group, Impe11 Equipment Qualification Group, and Ebasco Conduit Supports Group (Trains A and B and Train C larger than two-inch diameter).
Conduit displacements of mixed conduit junction boxes (i.e., junction boxes to which both Train C two-inch diameter and less conduit and Train C larger than two-inch diameter conduit were attached) were provided to Ebasco Conduit Supports Group (Trains A and B and Train C larger than two-inch diameter) for acceptance.
5.1.2.7 Final Reconciliation Process The purpose of the final reconciliation process is to consolidate design validation analyses, hardware modification, and field verification documentation to assure consistency of the Train C design.
The final reconciliation of Train C incorporates the following:
The Post Construction Hardware Validation Program (PCHVP) results Resolution of the Train C related Comanche Peak Response Team (CPRT) and external issues.
Final reconciliation also includes confirmation that the interfacing organizations have accepted the Train C results as compatible with their validated design.
Interfacing organizations received results as described in Figure 5-3.
In addition, open items, observations, and deviations related to Train C that were identified by TU Electric Technical Audit Program (TAP) and Impell Quality Assurance (QA) are resolved prior to the completion of this reconciliation phase. Open items from TU Electric Significant Deficiency i
Analysis Reports (SDARs) (10CFR50.55(e)) are also resolved during the final reconciliation.
At the conclusion of final reconciliation, the Unit 1 and Common Design Validation Packages (DVPs), as described in Section 5.4, are compiled.
5.1.3 Post Construction Hardware Validation Program (PCHVP)
The Post Construction Hardware Validation Program (PCHVP) (Reference 34) is the portion of TV Electric's Corrective Action Program (CAP) which validates the matrix of final acceptance attributes. The Post Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 5-5.
The input to the Post Construction Hardware Validation Program (PCHVP) is contained in the installation specification.
The installation specification (Reference 15) implements the licensing commitments and design criteria of the Design Basis Document (DBD).
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l
'I Final acceptance inspection requirements identified in the-validated bq installation. specification.were used to develop the Post Construction Hardware Validation Program (PCHVP) attribute matrix.
This matrix is a complete set of final acceptance attributes identifed for installation hardware (Table 5-2).
.The Post Construction Hardware Validation Program (PCHVP), by either physical validations or through an engineering evaluation methodology, assures that each of the attributes defined in the attribute matrix is validated.
Physical validation of an. attribute is performed by engineering walkdown (field verification) for accessible components.
Engineering walkdowns are controlled by the Field Verification Method (FVM) procedure (Reference 31).
The Post Construction Hardware Validation Program (PCHVP) engineering
.evaluatibn depicted in Figure 5-5 is procedurally controlled to guide the Corrective Action Program (CAP) responsible engineer through the evaluation of each item on the attribute matrix to be dispositioned by the engineering evaluation method. Disposition of each attribute is clearly documented.
If.
the technical disposition of the final acceptance attribute is "not acceptable" or, the attribute cannot be dispositioned based on available information, an alternate plan consisting of additional evaluations, testing, field verifications or modifications as necessary will be developed to
, demonstrate and document the acceptability of the attribute. Modifications are made through the process described in Section 5.1.2.4.
The Post Construction Hardware Validation Program (PCHVP) assures that
' Comanche Peak Response Team (CPRT) recommendations are properly dispositioned.
h Figure 5-5 illustrates that during the evaluation of a given attribute from the Post Construction Hardware Validation Program (PCHVP) attribute matrix, the initial task of the Corrective Action Program (CAP) responsible engineer 1s to determine'if any of the following statements are true:
l a.
The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT);
b.
Design validation resulted in a change to design or to a hardware final acceptance attribute that is more stringent than the original acceptance attribute or the Comanche Peak Response Team (CPRT) did l
not inspect the attribute; c.
Design validation resulted in new work, including modification to existing hardware.
(
If the Comanche Peak Response Team (CPRT) had no recommendations and items b or c.above do not apply, the attribute under. consideration will be accepted.
i This conclusion is justified by the comprehensive coverage of the Comanche Peak Response Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective.
The attribute matrix was then updated to indicate that engineering walkdown of the attribute is not necessary. A completed evaluation package is prepared and forwarded to the Comanche Peak Engineering O
L l
5-9
-(CPE) organization for. concurrence. The evaluation package became-part of the
(
Design Validation Package (DVP) after Comanche Peak Engineering (CPE)
I' concurrence was obtained.
If any of the three statements above.are true,'it is assumed that the final acceptance attribute must be further evaluated as follows:
Determine Attribute Accessibility
-The Corrective Action Program'(CAP) personnel will determine if the attribute
.is accessible.
If the attribute is accessible, a field validation of the item's acceptability will be performed and documented in accordance with an approved Field Verification Method (FVM).
.If the Corrective Action Program (CAP) personnel conclude that the attribute ~'
is inaccessible, an engineering evaluation will be conducted by technical disposition of available information.
' After completing the attribute accessibility review,- the Corrective Action Program.(CAP) responsible engineer will update the attribute matrix as necessary'to reflect the results of that review.
Technical Disposition
-The Corrective Action Program (CAP) responsible engineer identifies the data to be considered during the subsequent technical disposition process.
Examples of such items used in this disposition may include, but are not limited to:
Historical documents (e.g., specifications, procedures, inspection results)
Comanche Peak Response Team (CPRT) and external issues resolution Construction practices Quality records Test results Audit reports Surveillance reports NCRs, DRs, SDARs, and CARS Field verifications conducted to date I
Results of Third Party reviews l
Purchasing documents O
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' Construction packages
~
O
. Hardware. receipt inspections After compiling the data identified as pertinent to the attribute, the.
technical-disposition will be performed. The actual steps and sequence of
'l actions required for each technical disposition will differ; however, the
~j tangible results.from_each technical disposition.will be consistent.
These' results will include as a minimum-l A written description of the attribute;.
1 A' written justification by the Corrective Action Program (CAP) responsible engineer for acceptance of the attribute;
{
A written explanation of the logic utilized to conclude that the l
attribute need not be' field validated;
~
A chronology demonstrating that the attribute has not been significantly altered by redesign; All documents reviewed to support the disposition; and Concurrence of the acceptance of the attribute's validity by Comanche Peak Engineering (CPE).
If the Corrective Action Program (CAP) responsible engineer concludes that the Q
data evaluated represents-evidence of the attribute's acceptability, the conclusion will be documented.
The documentation will be reviewed and approved by Comanche Peak Engineering (CPE) and filed in the Design Validation Package (DVP).
If the Corrective Action Program (CAP) responsible engineer determines that the data-reviewed does.not provide evidence of the attribute's acceptability, the documentation will exp1hin why the attribute cannot be accepted and recommend an alternate course of action.
The alternate course of action may take various forms such as making the attribute accessible and inspecting it, or testing to support the attribute's acceptability. This alternate plan, after approval by Comanche Peak Engineering (CPE), will be implemented to validate the-attribute.
In summary, the Post Construction Hardware Validation Program (PCHVP) is a process by which each attribute in the PCHVP attribute matrix is validated to the validated design.
The TV Electric Technical Audit Program (TAP) will audit the Post Construction Hardware Validation Program (PCHVP).
The Post Construction Hardware Validation Program (PCHVP) provides additional assurance that the validated design has been implemented for safety-related hardware and Train C hardware.
To provide assurance that the as-built hardware complies with the validated design, the Impe11 Post Construction Hardware Validation Program (PCHVP) for Train C conduit developed a matrix of final acceptance attributes (Table 5-2) based on the validated installation specification.
The Field Verification 5-11
Hethod (FVM) which has been developed to provide as-built input into tho l
tO V
design validation process was reviewed to determine whether all final acceptance attributes were included.
This review concluded that all final acceptance attributes were included in the FVM.
The FVH developed by Impell is identified below:
I CPE-IM-FVM-CS-095 As-Built Field Verification Method for Train C Conduit Program The Post Construction Hardware Validation Program (PCHVP) is being implemented in accordance with the above FVM to validate all attributes in the attribute matrix. A majority of the attributes in the attribute matrix have been validated for PCHVP during the design validation process.
The remaining attributes will be design validated by the Post Construction Hardware Validation Program (PCHVP).
i 1
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L____________._______._
5.2 RESULTS.
nU This. section discusses the results of the Train C Corrective Action Program (CAP).
5.2.1 Conduit Design Validation Results The Train C Corrective Action Program (CAP) design validated approximately 105,000 conduit supports in Unit 1 and Common. Design validation identified approximately 600 support modifications.
These modifications have been designed and are being installed to correct one or more of the following:
member and component overstresses weld overstresses I
anchor bolt capacity exceedance clamp capacity exceedance adverse impact on Seismic Category I systems, structures or components 5.2.2 Post Construction Hardware Validation Program (PCHVP) Results l
The Post Construction Hardware Validation Program (PCHVP)'is being implemented j
through the validation of the final acceptance attributes for Train C in Unit I and Common as discussed in Section 5.1.3.
Approximately 77,000 O
supports have had their final acceptance attributes validated through the Post Construction Hardware Validation Program (PCHVP).
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i 5.3 QUALITY ASSURANCE (QA) PROGRAM
'All activities of the Unit I and Common Train C Corrective Action Program
'i (CAP) were performed in accordance with Impell's Quality Assurance (QA) program.
The program assures adherence to' administrative quality requirements and engineering / technical quality ~ requirements.
Nuclear safety-related work at Impe11 is performed in accordance with the Impe11 Quality Assurance Program,-which complies with 10CFR50, Appendix B, ANSI.N45.2 (Reference 16), and with appropriate ANSI daughter standards.
Impell's Corporate Quality Assurance. Program was reviewed and approved by the TU Electric Quality Assurance organization.
Impe11's QA' program has also been' inspected by the Nuclear Regulatory Commission on several occasions.
Prior to initiation of work to implement the Train C Corrective Action Program (CAP) a Train C Project Quality Plan was developed in accordance with the Impe11 Corporate Quality Assurance Program.
The Project Quality Plan serves-to control all Impell work performed to.
l validate the design of the CPSES Train C.
The Project Quality Plan includes i
specific CPSES Train C instructions and procedures to supplement the Impell i
Corporate Quality Assurance Manual. The. instructions were issued to direct i
the organization and format for design validation calculations and to assure that-documentation is.provided in a standard and complete manner.
These project instructions are prepared in sufficient detail to obtain consistent quality standards. To provide additional assurance in the technical adequacy of design calculations, the Impe11 Corporate Quality Assurance Program has-i established a Technical Quality Review program (conducted internally).
The O
Technical Quality Review consists of a detailed technical assessment, 1
conducted by Impe11 engineers not involved in Train C activities, of the I
assumptions, methodologies, and reasonableness of the technical work performed. The program has been implemented in all Impe11 offices involved in Train C related work. Technical Quality Reviews are documented and are made
]
part of the project records.
In accordance with Impe11's Quality Assurance (QA) program, Impe11 developed a Design Basis Document (DBD), detailed procedures, and a project specific QA plan covering the essentials of.the Train C validation program. These documents were distributed to Impe11 supervisory engineers and were readily available to Train C Corrective Action Program (CAP) personnel.
The issuance of design criteria, design procedures, and design control procedures were followed with training for the applicable personnel.
In addition, appropriate technical personnel assigned to Train C activities have received documented training of Impe11 Quality Assurance (QA) requirements.
Included in the QA i
training are requirements for 10CFR21 and 10CFR50.55(e) reporting. Also, j
Project Engineers and lead project personnel who have responsibilities for reviewing and approving QA documents, have received Impe11's Project Engineer QA Training.
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s 1
An-Impell Project Quality Assurance (QA) Manager experienced in both auditing i
- h.
and QA program procedure development for engineering activities monitored the i
U project throughout.
Impell's Quality Assurance Manager reports directly to the Western Region.Vice President.- This reporting responsibilities assures independence of the Quality Assurance'(QA) Functions. QA personnel provide assurance that the QA program properly addresses all project activities and assist project personnel in properly implementing the QA program.
To date, approximately 50,000 man-hours have.been expended by Impe11 in
-activities directly related to the overall project Quality Assurance (QA) l progam (i.e., training, procedure development, auditing, and the project QA supervisory staff).
]
The adequacy and implementation of the Train C program were extensively audited by Impe11's Quality Assurance Department, and by the TU Electric i
Technical Audit Program (TAP). A total of 17 audits and-surveillance were
- performed'by these organizations from January 1986 to date for both Unit I and-Common as follows:
Impell Audit Group 7 audits 1
1 surveillance TU Electric - TAPI 6 audits 3 surveillance In addition, TENERA, L.P. (TERA) has overviewed Impell's Train C validation process regularly between April 1986 and September 1987. ' TERA was contracted O.
.by the Comanche Peak Response Tecm (CPRT) as the Third Party reviewer, to-overview the adequacy of Impell's Train C design methodology as discussed in Section 5.1.1.1.
TERA concluded that the Train C validation program was comprehensive and capable of resolving Comanche Peak Review Team (CPRT) and external ist.ues.
This Third Party overview provides additional assurance that the CPSES Train C meets the licensing commitments.
Impe11's Quality Assurance (QA) Program requires.that QA audits of project activities be performed periodically.
Summaries of the audit details for the Impe11 Quality Assurance (QA) Program are provided in Section 5.3.1.
TU Electric conducted technical audits as part of the TU Electric Technical Audit Program (TAP).
The details of calculations, drawings, procedural compliance and technical interface were evaluated.
These technical audits j
have resulted in enhancements to the procedures and methods, and thus,
)
contributed to the overall quality of the CPSES Train C design.
I The TU Electric Technical Audit Program (TAP) has been in effect since January 1987.
Prior to this the TU Electric Quality Assurance Department performed audits of selected engineering service contractors using technical specialists as part of its vendor audit program.
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l The audits described above represent detailed assessment of the-following:
Adequacy of the Quality Assurance program Implementation of the Quality Assurance program i
Technical adequacy of the design criteria and procedures
. Implementation of the design criteria and procedures In some cases these audits identified items in design criteria, procedures, calculations, project documentation and training for-which action was required to clarify or improve the design validation process.. Each item identified through the audit process'was reviewed by Impe11 to determine the extent of the condition,.the cause of the condition and any' corrective or preventive u
action required. Complete responses were provided for each item identified.
Subsequent audits have verified that appropriate corrective and preventive
. actions were implemented to address the previously identified audit. items.
In summary, an appropriate level of attention has been given to the quality of all Corrective Action Program (CAP) activities; the Quality Assurance (QA) program is comprehensive for the scope of work; project performance has been demonstrated to be in compliance with the QA program; and appropriate corrective and preventive actions have been taken when required..
5.3.1 Impell Quality. Assurance (QA) Audits pd To date, Impe11 Quality Assurance (QA)-has performed 7 audits and 1 3
surveillance of the Impe11 Train C design validation program. The following l
list of audit subjects describes the auditing that has been performed:
1.
Adequacy of the Design Procedures 2.
Adequacy of the Project Procedures 3.
Calculations - Documentation 4.
Compliance with Project Procedures 5.
Design Control 6.
Document Control 7.
Indoctrination and Training 8.
Records Maintenance 9.
Maintenance of Project Procedure Manuals i
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5.3.2 - TU Electric Technical Audit Program (TAP)
In addition to the Impell Quality Assurance (QA) audits, Impell was audited by the TV Electric Technical Audit Program (TAP).
To date,:TU Electric Technical Audit Program has performed 6 audits and 3 surveillance. A tabulation of the TU Electric Technical Audit Program (TAP) audits is presented in Table 5-3.
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I 5.4 CORRECTIVE AND PREVENTIVE ACTIONS O
Impell has developed the technical and design control procedures (Table 5-1) and updated the installation specification and construction procedure to implement the corrective actions resulting from the Train C Corrective Action Program (CAP).
These procedures are identified within the Design Basis Datument (DBD) (Reference 3), which contains the design criteria for validating Train.C in Unit 1 and Common.
Impe11 implemented the following corrective and preventive actions to assure adequate. hardware installations:
The installation specification (Reference 15) was revised, and a new construction procedure (Reference 17) was developed, to meet the requirements of the Train C validated design. Drawings were issued for modifications / replacements of Train C conduit supports.
i New field verification procedures (References 18 and 31) were developed to provide acceptance criteria for field verification of Train C conduit supports.
Imme11' developed a procedure (Reference 19) to monitor construction activities and identify effects on previous Train C validated design and installation.
This preventive action assures that the appropriate design documentation will be updated, as required, to reflect plant configuration changes.
Procedures were also established (References 20 and 21) to control the interface activities between Impe11 and other interfacing organizations (see Section 5.1.2).
This action assures that controlled interface is conducted between Impe11 and other interfacing organizations involved in the Corrective Action Program (CAP).
The validation is documented in the drawings, calculations and specification, which form a part of the Design Validation Packages (DVPs). This validated design documentation will be provided to TU Electric at the completion of the Corrective Action Program (CAP). Impe11 procedures used for validation will be provided to Comanche Peak Engineering (CPE). The validated design documentation and procedures can provide the basis for configuration control of CPSES Train C Conduit and can be utilized by TV Electric to facilitate operation, maintenance, and future modifications following issuance of an operating license. Utilization of this documentation and these procedures by TU Electric Comanche Peak Engineering (CPE) will assure that future CPSES Train C design is performed in accordance with the licensing commitments.
Training for Comanche Peak Engineering (CPE) personnel will be provided by Impe11. The training will cover background assumptions and the methodology used in the validation of Train C.
TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from t
Impell to CPE. The program provides for the identification of those tasks presently being performed by Impell which are to be transferred to CPE and the O
5-18
1 l
l identification of all procedures, programs, training, and staffing
.c lj requirements. The program is based upon three prerequisites:
(a) the Corrective Action Program (CAP) effort to support plant' completion is finished for the particular task; (b) the Train C conduit Design Validation Packages (DVPs) are completed; and (c) any required preventive action taken, as discussed in Appendix A,-is completed.,
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FIGURE 5-1
('
DESIGN VALIDATION PROCESS UNIT 1 AND C4NMON TRAIN C 2* OIA A@
LESSCOMUT AND CONDUIT SUPPORTS i P VALIDATION 2
METHOO 1 NO NTERACTION POTENTML m
METHOD 2 ACCEMA8LE 6
l rW1 hsNT i f VALCATED VMD METHOO3 STRUCTUFML g
NTEGRffY rwinsyt ALDATED 00CLMNT l
t i
if i t if MOOiFICATICP4 MOOtFICATION MOO 4FICATION METHOD 1 METHOD 2 METHOO 3 MCOFY PROVDE SESMC PEROUTE SUPPORT RESTMANT CABLE COOurf rw1 0
i FIGURE 5-2 EXAMPLES OF TESTED COMPONENTS 3
/
r,-
q/
\\.
l Y
4
)
i f
(a) UNISTRUT WELDED (b) TYPICAL UNISTRUT FOOT HANGER FITTINGS l
n e i
HILTI BOLTS P1000 CHANNEL h
DNE-BOLT
\\
CONDUIT FINGER CLAMP y\\
.s s
P1001 CHANNEL 1
(c) ONE-BOLT CONDUIT (d) TYPICAL UNISTRUT FINGER CLAMP SUPPORT MEMBERS HILTI BOLTS f
v
\\ //
//
//
//
//
// /
ll ll EADED UNISTRUT TMEMBER
. "_ _ _ _ _ _ _ _ _ _= L O
(e) TYPICAL ROD HANGER SUPPORT
l-L i
FIGURE 5-3 l
i O CORRECTIVE ACTION PROGRAM (CAP) TECHNICAL INTERFACES TRAIN C THO-INCH DIAMETER AND LESS CONDUIT AND CONDUIT SUPPORTS Ii I
.j l
_TU ELECTRC l
l' ENGNEERNo(C PE)
IMPELL i
MANAGEhENT OF EOUPMENT OUALIFICAfg CORRECTNE ACTON eLOADS ON kOUPMENT PROGRAM (CAP)
SUPPORTS j.
CA8tE TRAYS AND CA8t,E i
I TRAY HANGEf%
i NN e LOADS ON CA8LE TRAY RESPONSE TEAM (CPRT)
HANGERS FRE PROTECTON e OVEfWEWlE80LLm0N I
e WEGHT OF FIFE OF TECHNCAL RAI SE PROTECTION MATERIAL o 04RWWOF PELL ON TRAIN C PROGDLPES
[ VALCATON OF )
TRAN C TVM>NCH '
DIAETEROOW Uff APO C080UIT SUPPORTS i
O N
SWECPSAS a
CA8LE TRAYS AND CA8LE e LOADS ON PPE TRAY HAPGERS SUPPORTS
' I N TRAY
- SNEC HANGERS
- O Cfv0 STRUCTURAL MOMN
- LOAD 6 ON &TRUCTL7ES N
- AMPLFED E8POfM TRAINS A & 8 AND TRAN O m
fLARGER THAN TWGNCH eCONGETE ANOCRAGE DI AMETER) *ONDulT SEPARATION e LOADS ON TRANS A & 5 gg e AND TRAN C LARGER
,couygogy m THAN TWC>NCH DWAETER CONOUfT SUPPORTS j
i
- CON 0utT DSPLACEh4ENTS
- AT WlXED CO#00ff JUNCTION DOXES i
SYSTEMS NTERACTION e NTERACTON WITH f
SAFETY-REALTED f
COMPOPENTS i
O
. (~g FIGURE 5-4
'q)
TYPICAL INTERACTION ZONES SOURCE TRAIN C CONDUIT AND/OR CONDUIT SUPPORTS C
-!NTERACTION ZONE FOR FREE FALLING
^
I TARGET REFERENCE ELEVATION U
///////// //////////.
ELEVATION
///////////
iE INTERACTION ZONE I
FOR PENDULUM HANGER uj INTERACTION ZONE FOR SOURCE CONDUIT 2
4/
'70.;
i i
SOURCE TRAIN C CONDUIT P RTS ELEVATION Notes:
(1) The interaction zones are three-dimensional zones; although they are shown here as two-dimensional.
(2) Zones are not drawn to scale.
kI IA k..
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FIGURE 5-5 f
POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)'
1.
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g FIGURE 5'-6 CORRELATION OF PROJECT INSTRUCTIONS WITH DESIGN VALIDATION PROCESS UNIT 1 ANDCOWAON PRCUECTINSTRUCTIONS CArTERIADEVELOPMENT g
AND ADMIN!SMATIVE s
PI-0210 052 02 PI-0210 052 07 Pl 0210 052 09 Pl.0210 05211 Pl.0210 053 01 PI 0210 05311 Pl.0210 05314 VAUDATION VALIDATION VAUDATION MODIFICATION METHOD 1 METHOO 2 METHOD 3 METHOOS 1,2 AND 3 Pl.0210 052 05 Pl.0210 052 05 Pl.0210 052 03 Pl.0210 052 03 Pl.0210-053 01 Pl.0210 053 01 PI-0210 052 04 Pl.0210 052 04 PI 0210 053-13 Pl.0210 05313 PI 0210 052 06 Pl.0210 052-08 PI-0210 05210 Pl.0210 053 01 Pl.0210 05212 Pl.0210-053 04 Pl.0210 053 01 Pl.0210 053 05 PI 0210 053 02 PI 0210 053 05 Pl.0210 053 03 PI-0210-053 08 PI 0210 053 07 Pl.0210-053 09 Pl 0210 053-10 Pl.0210 053-12
TABLE 5-1 LIST OF= PROJECT. INSTRUCTIONS -
Number Ti t1e -
PI-0210-052-02 Verification of Existing Train C Conduit:Halkdowns' L
-PI-0210-052-03 Seismic ~ Evaluation of Train C Conduit Supports l
PI-0210-052-04 Train C Conduit As-Bui1t.Walkdown PI-0210-052-05 Procedures for Implementing Screen Level 6 PI-0210-052-06 Rigorous Analysis of Train C Electric Conduits PI-0210-052-07 Calculation Numbering and Cross-Reference System
-PI-0210-052-08 Procedure for Implementing Rework Option 2 - Seismic Restraints by Aircraft Cable PI-0210-052-09 Processing of Discrepancy / Issue Resolution Reports d
PI-0210-052-10 Procedure for Implementing Screen Level 8 PI-0210-052-11 Procedure for Utilizing Test Data on Train C Conduit Support Components O
PI-0210-052-12 Enhanced Level 2 Screening Criteria for Simple Supports, Train C Conduit (Two inch and Under)
PI-0210-053-01 Multi-Level Screening ~ Criteria for Train C Conduit (Two Inch and Under) at Comanche Peak Steam Electric Station PI-0210-053-02 Level 4 Screening Criteria for Type 1 Supports, Train C Conduit (Two Inch and Under) at Comanche Peak Steam Electric Station PI-0210-053-03 Level 4 Screening Criteria for Type 2 Supports, Train C Conduit (Two Inch and Under) at Comanche Peak Steam Electric j
Station PI-0210-053-04 Procedures for Implementation of Design Change Authorization Forms (DCA) for Train C Conduit Supports PI-0210-053-05 Procedure for Implementation of Nonconformance Report (NCR)
Resolution for Train C Conduit PI-021CLO53-06 Engineering Evaluation of Separation Violation (EESV)
Between Two Hilti Bolts or Between a Hilti Bolt and a Richmond Anchor O
TABLE 5-1 (Continued)
(
Number Title PI-0210-053-07 Level'4 Screening Criteria for Type 7-S-17 Supports,' Train C Conduit, Two Inch and Under (Including Reclassified Lighting Systems)
PI-0210-053-08 Procedure for Dispositioning and Reviewing Deficiency Reports (DR's) l PI-0210-053-09 Engineering Inspection Procedure PI-0210-053-10 Review and Resolution of Field Change Requests. (FCRs)
PI-0210-053-11 Train C Conduit (two-inch and less) Record Turnover Program l
PI-0210-053 Procedure for Dispositioning Corrective Action Requests for.
1 Train C Conduit (two-inch and less)
PI-0210-053-13 Train C Conduit Program Maintenance PI-0210-053-14 Procedure for the Control of Train C's Intermediate Storage Area (ISA) i l
4 i O 3
2 I
\\
.v._
TABLE 5. _ -.
POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)-
-TRAIN C CONDUIT ATTRIBUTE MATRIX' Construction.
Final Acceptance PCHVP Attribute
+
Work Catecory.:
Attribute-
. Validation Method Train'C Two-Inch-Conduit / Junction CPE-IM-FVM-CS-095 Diameter-and Less.
Box = Component.
.(Reference 31)-
Conduit and Conduit Identification Supports-Conduit / Junction Box CPE-IM-F % CS-095 Support Identification-1 Typical Support
~CPE-IM-FVM-CS-095 Identification 4
Support Restraint CPE-IM-FVM-CS-095 Directions Reference Location of CPE-IN-FVM-CS-095 Support Conduit Span' Length CPE-IM-F % CS-095-Conduit Diameter / Junction CPE-IN-F%CS-095:
Box Dimensions Conduit Configuration CPE-IN-FVM-CS-095 Gap Between Clamp and CPE-IM-F 4 CS-095 Conduit Clamp Type and Size CPE-IM-F E CS-095 Presence of Friction CPE-IM-F % CS-095
]
Type Beam Clamp Presence of Reamed Clamp CPE-IM-FVM-CS-095 I
Presence of Distorted CPE-IM-FVM-CS-095 Clamp j
Presence of Fire CPE-IM-FVM-CS-095 Protection Material Member Length CPE-IM-FVM-CS-095 l
o e
1
_=_-
t.
TABLE 5-2 (Continued)
, -O Cons ruction Final Acceptance
'PCHVP Attribute Mork Cateaorv Attribute Validation Method Train C Two-Inch-Member Shape, Type, CPE-IS FVM-CS-095 Diameter and Less Size,-Configuration Conduit and Conduit.
Supports Structural Bolt Size CPE-ISFVM-CS-095 L
Structural Bolt Type CPE-IM-FVM-CS-095 Structural Bolt Oversize CPE-IN-FVM-CS-095 Hole,on the Base Metal s-Structural Bolt Thread /
CPE-IM-FVM-CS-095.
Nut Engagement Structural Bolt Torque CPE-IM-FVM-CS-095 Distance of Bolt Hole CPE-IM-FVM-CS-095 to Edge of Member Cable Restraint Slack CPE-ISFVSCS-095 Threaded Rod Coupler CPE-IS FVSCS-095 l
Thread Engagement
'O-Gap Between Baseplate CPE-IM-FVM-CS-095 and Concrete Gap Between Base Angle
.CPE-IM-FVM-CS-095 j
and Concrete f
l Gap Between Unistrut CPE-IM-FVSCS-095
}
Header and Concrete i
Size of Nelson Stud Held CPE-IM-FVM-CS-095 Meld Type (Fillet, CPE-ISFVM-CS-095 l
Partial Penetration) l Meld Length CPE-IM-FVM-CS-095 l
l Meld Size CPE-IM-FVM-CS-095 Meld Pattern CPE-IM-FVM-CS-095 1
Concrete Anchorage CPE-IM-FVM-CS-095' Spacing j
O i
1 2
]
1
TABLE 5-2 (Continued)
Construction.
Final' Acceptance PCHVP Attribute Work Cateaorv Attribute Validation Method Train C Two-Inch Concrete Anchorage CPE-IM-FVM-CS-095 Diameter and Less' Conduit and Conduit.
Edge Distance Supports-Hiiti Bolt Type CPE-IM-FVM-CS-095 Hilti Bolt Projection CPE-IM-FVM-CS-095 Length Hilti Bolt Nut / Thread CPE-IM-FVM-CS-095 Engagement HiIti Bolt Torque CPE-1M-FVM-CS-095 Richmond Insert CPE-IM-F % CS-095 Tightness Hilti Bolt Orientation CPE-IM-F E CS-095 l
Baseplate Dimensions CPE-IN-FVM-CS-095 Presence of Baseplate CPE-IM-F % CS-095 Oversize Hole Gross Deficiencies CPE-IM-F E CS-095 f
i O
i l
l L
3 l
fu TABLE 5-3 g
SUMMARY
OF.TU ELECTRIC TECHNICAL AUDIT PROGRAM (TAP) AUDITS O
Au'dit No.
Comoleted Date.
TEN August 26, 1986-TEN-8/S December 12, 1986 ATP-87-018 Februa'ry 17, 1987-TEN-9/FH March 6, 1987-ATP-87-05 March 25, 1987 ATP-87-26 July 31, 1987 l
l O
i O
l I
i
6.0 REFERENCES
l O 1.
TENERA, L'.P., "Results Report - ISAP I.c -- Train C Conduit and Conduit L
Supports," Revision 1, October 28, 1987, Berkeley, CA.
2.
Impell Report No. 09-0210-093 for TV Electric Comanche Peak Steam l
Electric Station Units 1 and 2 "CPSES Design Basis Consolidation Program Plan", Revision 0, May 22, 1987.
3.
Impell Design Basis Document DBD-CS-093, " Seismic Adequacy of Train C Conduits (Two Inch Diameter and Less)", Rev. 1, November 1987.
l 4.
Comanche Peak Steam Electric Station, Final Safety Analysis Report, Current as Amended, Texas Utilities Electric Company, Dallas, Texas.
5.
NRC Regulatory Guide 1.29, " Seismic Design Classification," Revision 2, U.S. Nuclear Regulatory Commission, Hashington DC, 1976.
6.
NRC Standard Review Plan 3.7.2, NUREG-0800, " Seismic System Analysis",
Revision 1, U.S. Nuclear Regulatory Commission. Hashington DC, July 1981.
7.
Not Used.
8.
Corporate Consulting and Development Co., Ltd. (CCL) Test Report No.
A-736-86, Revision 0, " Tensile and Shear Strength Testing of Hilti Kwik Bolts for Train C Conduit Supports for CPSES", October 1986.
I 9.
Impe11 Report No. 01-0210-1483, Revision 2, "Hilti Kwik Bolt Concrete d
Expansion Anchors - Justification of Factor of Safety", July 1987.
10.
Impe11 Report No. 01-0210-1527, Revision 1, "CPSES Train C Conduit, Justification of Damping Value", December 1986.
11.
Impe11 Report No. 01-0210-1624, Revision 1, " Enhanced Level 2 for Train C Conduit (Two Inch Diameter and Less) Program", October 1987.
12.
Impell Report No. 01-0210-1562, " Justification for Screen Level 6, I
Conduit Systems Having Lightly Loaded Supports", Rev. O, June 1987.
j
- 13. American Iron and Steel Institute, " Specification for the Design of Cold-formed Steel Structural Members", Washington DC, September 3, 1980.
1 1
- 14. American Institute of Steel Construction, " Manual of Steel Construction", 7th Edition.
- 15. Design Change Authorization (DCA) No. 60313, Rev. O, November 1987, for CPSES Unit 1 and 2 Specification for Structural Steel / Miscellaneous Steel (Category I and II) 2323-SS-16B, Appendix F,Section I and II, Rev.l.
t
/
6-1
-16.- American National Standards Institute, Quality Assurance. Requirement for -
Q
, Nuclear Facilities, Section N45.2, American Society of Mechanical U
Engineers, 1977.
17.
Procedure ~ No. ECP-198, " Installation of New, Hodified, and Relocated-Train C Conduit Supports for Two Inches'and Under Conduits", Revision 2.
18, ~Impe11 Project Instruction, " Engineering Inspection Procedure". Project Instruction No. PI-0210-053-009, Revision 0, Job No. 0210-053-1355, May
-1987.
19.
Impe11 Project Instruction, " Train C Conduit Program Maintenance",
Project Instruction PI-0210-053-013, Revision 0, August 1987.
l
' 20.'
Impe11 Interface Control-Instructions, Job Nos. 0210-052, 054, 056 and 058, Revision 9, September 1987.
21.
Impe11 Interface Control Instructions, Job Nos. 0210-053, 055 and 057 Revision 8. September 1967,
- 22. Letter No. 84056-095 "fteview Issue List (RIL). Texas Utilities-Generating Company, CPSES Independent Assessment Program - All Phases",
from N.H. Williams (Cygna) to H.G. Counsil-(TUGCO) dated November 26, 1985.
23.
Impe11' Calculation No. ROTC-75, Revision 1. " Evaluation and Resolution of Cygna Train A and 8 Conduit Issues as Applicable to Train C Conduit Supports", September 1987.
- 24. CCL Test Report No. A-720-86, Project No. 85-1903.23/24, " Test Report for Static Testing of Train C Beam Clamps and Unistrut Hangers for CPSES",
j July 1986.
.25.
CCL. Test Report No. A-711-86, "CCL Test Report for Static Testing of Train C Conduit Support Components for Comanche Peak Steam Electric Station",
April 4,1986.
- 26. CCL Test Report No. A-707-86, "CCL Test Report for Static and Cyclic Testing of Train C Conduit Support Components, Hilti Bolt Test and Unistrut P2543 Helded Foot Hanger Test", February 14,'1986.
27.
Impe11 Calculation No. ROTC-06, " Multi-Mode Factor Evaluation for Train C Conduit Supports", Rev. 1, Job No. 0210-052-1355, September 1986.
- 28. TU Electric Engineering and Construction Procedure, ECE-9.04-5, Revision 0, " Post Construction Hardware Validation Program-Engineering Evaluation", September 1987.
l O
i 6-2 l
L____-________-_
.I o
- 29..Impell Report No'. 01-0310-1469, " Static and Dynamic Tests of One-Bolt l
Conduit Clamps", prepared for Southern California Edison Co.,' Impe11' e
Corp.,. November 1985.
- 30. 'URS/BLUME Report No. 8050, " Analytical Techniques, Models.and Seismit.
Evaluation of Electrical Raceway System", Revision 0,' prepared for SEP' Owner's Group,-URS/BLUME, San Francisco, CA, August 26, 1983.
- 31., TV Electric Engineering Procedure CPE-IM-FVM-CS-095, " Field Verification Method, Train C Conduit Program", Rev 0, August 1987.
- 32. -TV Electric. Letter No. TXX 6500, H.G. Counsil 'to US Nuclear Regulatory Commission, Comanche Peak Programs, June 25, 1987.
33.
TU Electric Letter No..TXX 663), H.G. Counsil to US Nuclear Regulatory.
Commission, Comanche Peak Programs, August 20., 1987.
34.
TU Electric Engineering and Construction Procedure EC-9.04, " Post Construction Hardware Validation Program", July 1987.
4 I
.O.
l l
l l
l.
1 l
l 6-3
{
f
.a L
t 3
APPENDIX A'
- j COMANCHE PEAK RESPONSE-TEAM (CPRT) AND EXTERNAL ISSUES
1.0 INTRODUCTION
This appendix contains a comprehensive summary of the Impe11 evaluation.
-l resolution and corrective and preventive action for all Comanche Peak Response 1
Team (CPRT) and' external-issues which are related to the Train C conduit 1
-system design.. Specific reference to the criteria, procedures, engineering l
studies, and. tests which'have resolved the issue is provided.
^1
~
To report the resolution'of the Comanche Peak Response Team (CPRT) and
_i external issue, an individual Subappendix-was developed for the issue. The.
Subappendix includes: a definition of;the issue; issue resolution; corrective and preventive action. References identified in Section 4.0 are current as of the date of this report.
An inspection of the Train C conduit system was conducted as part of the Technical ~ Review Team (TRT) activity in 1984.
The inspection identified an issue (TRT Issue I.c documented in Supplemental Safety Evaluation Reports
'(SSERs) No.7 (Reference 4.2 in Subappendix A1) and No.~ 8 (Reference 4.3 in Subappendix A1)) that the support installation for non-safety-related conduit 1
less than or equal-to two inches in diameter may be unsatisfactory.
In response to TRT Issue-I.c the Comanche Peak Response Team (CPRT) developed Issue Specific Action Plan (ISAP) I.c to address this issue and to assure
.?
~
compliance with regulatory requirements and licensing commitments.
- The' preventive action is embodied in the procedures and Design. Basis Document (DBD) developed and used in the Train C Corrective Action Program (CAP).
These procedures and Design Basis Document (DBD) resolve all Comanche Peak Response Team (CPRT) and external-issues.
Implementation of these preventive actions will assure that the design and hardware for CPSES Unit 1 and Common Train C will continue to comply with the licensing commitments through out the life of the plant, as de cribed in Section 5.4.
s Impe11 has reviewed the SER and its supplements (SSERs) and determined that the Train C design criteria, deisgn procedures, and validated hardware are consistent with the NRC staff positions stated in the SER and its supplements (SSERs).
-The Comanche Peak Response Team and the external issue contained in Appendix A is given below.
Issue No.
Issue Title Al Train C Conduit and Supports O
A-1
l SUBAPPENDIX Al TRAIN C CONDUIT AND SUPPORTS 1.0 ' Definit' ion of the Issue'
-The issue was that the installation for non-safety-related conduits two-inch diameter and less was not adequate for seismic loading. According to Regulatory Guide 1.29 (Reference 4.4) and the CPSES~FSAR, the nonseismic items should be designed in such a way that their failure would.not adversely affect the function of Seismic Category I systems,. structures, or components, or l
cause incapacitating' injury to occupants of the Control Room.
1 2.0 Issue Resolution-The Corrective Action Program (CAP) for Train C as described in this report, i
l>
assures compliance with the licensing commitments'for the support of Train C conduits and conduit supports. This CAP assures that Train C is designed such 1
L
.that its failure would not adversely affect the function of Seismic-Category I systems, structures, or components, or cause incapacitating injury to occupants of the Control Room.
'3.0 Corrective and Preventive Action No additional issues have been identified to date during the review and resolution of this issue.
This issue was determined to be reportable under the provisions of O
10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR)' CP-85-36 in letter number TXX 6928, dated November 5, 1987, from TU Electric to the NRC.
3.1 Corrective Action The Train C conduit and conduit support systems have been design validated.for seismic loading (Reference'4.1) and the design validation is based on as-built data, in accordance with the design validation procedures (Table 5-1).
3.2 Preventive Action The design criteria requiring consideration of the effects of seismic. loads on the Unit 1 and Common Train C and the use of the as-built data for design input have been established and documented in the Train C Design Basis Document (Reference 4.1).
These requirements are included in the Train C 1
two-inch diameter and less conduit and conduit supports design validation i
procedures (Table 5-1).
4 l
O Al-1
l l
4.0 Referer.rJti 4.1 Impe11 Train C Conduit (Two Inch Diameter and Less) Program, Design Basis Document, DBD-CS-093, Rev. 1, November 1987.
4.2 " Safety Evaluation Report Related to the Operation of CPSES, Units 1 and 2 " USNRC, NUREG-0797, Supplement No. 7, Attachment 3, Current as Amended.
4.3 " Safety Evaluation Report Related to the Operation of CPSES, Units I and 2, "USNRC,-NUREG-0797, Supplement No. 8, Attachment 3 Current as Amended.
4.4 NRC Regulatory Guide 1.29, " Seismic Design Classification", Revision
- 2. U. S. Nuclear Regulatory Commission Hashington DC,1976.
O O
I Al-2 h
!