ML20236P591
| ML20236P591 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/21/1987 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20236P529 | List: |
| References | |
| NUDOCS 8711180058 | |
| Download: ML20236P591 (59) | |
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COMANCHE PEAK RESPONSl!. TEAM RESULTS REPORT ISAP:
II.d
Title:
Seismic Design of Control Room Ceiling Elements REVISION 1 l
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('j RESULTS REPORT NJ ISAP II d Seismic Design of Control Room Ceiling Elements L
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1.0 DESCRIPTION
OF-ISSUE IDENTIFIED BY NRC Technical issues and' certain allegations with potential safety implications were identified and communicated by the NRC to TU Electric.
It was alleged that the field run conduit, the drywall, and the lighting installed in the area above the ceiling panel in the control room were classified as non-sef.smic and supported'only by wires and might fall as a result of a seismic event. The following excerpts from the assessment of the allegation were taken from pages K-83, -84, and -85 of SSER 8 (Reference 9.1):
" General Design Criteria No. 19 requires that safe occupancy of the control room during abnormal conditions be provided for in its design. The Comanche Peak Steam Electric Station (CPSES) control room is in a seismic Category I structure, with certain seismic Category II and nonseismic components located in the ceiling.
Seismic Category I refers to those systems or components which must remain functional in the event of an earthquake. Seismic Category
. g) 11 refers to those systems or components whose continued functioning is not required, but whose failure could reduce the
d functioning of any seismic Category I system or ernponent (as defined in Regulatory Guide 1.29) to an unacceptable level or could result in an incapacitating injury to occupants of the control Seismic Category II systems or components are, therefore, room.
designed and constructed so that a Safe Shutdown Earthquake (SSE) will not cause such failure or injury.
"In assessing this allegati
, the TRT reviewed the CPSES nonsafety-related conduit,r'ighting fixtures, and the suspended ceilings installed in the control room. Three types of suspended ceiling exist in the control room: drywall, louvered, and acoustical. The following list designates those ceiling elements present in the control room and their seismic category designation:
1.
Heating, Ventilating and Air Conditioning -Seismic Category I 2.
Safety-related Conduits
-Seismic Category I 3.
Nonsafety-related Conduits
-Seismic Category II 4.
Lighting Fixtures
-Seismic Category II 5.
Sloping Suspended Drywall Ceiling
-Nonseismic 6.
Acoustical Suspended Ceiling
-Nonseismic 1
7.
Louvered Suspended Ceiling
-Nonseismic" "The TRT determined that none of the suspended ceiling elements were considered to be either seismic Category I or II; however, q
TUEC had modified the sloping suspended drywall to add more
{f support. G&H could not provide backup calculations to support this modification, nor could TUEC provide justification for their
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1 Page 2 of 58 RESULTS REPORT ISAP II.d (Cont'd)
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (Cont'd) position that the remaining suspended ceiling elements (i.e., the louvered and acoustic elements) would not fall and cause an incapacitating injury to operating personnel. This would indicate failure of the quality assurance program to ensure that applicable provisions of Regulatory Guide 1.29 were fully met."
"The TRT found that nonsafety-related conduits that were less than or equal to 2 inches in diameter were not supported by redundant seismic Category II cable restraints. The TRT also verified the adequacy of calculations for the nonsafety-related conduits larger than 2 inches in diameter.
"The TRT found that not all items in the Control Room ceiling fall under the seismic Category I or II designation. Specifically, these items are the suspended drywall, acoustical, and louvered ceilings. These components, designated as nonseismic, do not satisfy the provisions of Regulatory Guide 1.29, since they were not designed to accommodate seismic effects. Nonsafety-related conduits that are 2 inches in diameter and less also were not designed to accommodate seismic effects "
"The TRT concludes that calculations supporting the seismic Category II lighting fixtures do not adequately reflect the rotational interaction with the nonseismic items.
In addition, the fundamental frequencies of the supported masses were not calculated to determine the influence of the seismic response spectrum at the control room ceiling elevation."
2.0 ACTION IDENTIFIED BY NRC The NRC (in Reference 9.1, Page K-85) identified that the f ollowing action should be taken on this issue:
"TUEC shall provide:
1.
The results of seismic analysis which demonstrate that tne nonseismic items in the control room (other than the sloping suspended drywall ceiling) satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.
2.
An evaluation of seismic design adequacy of support systems for the lighting fixtures (seismic Category :'
and the suspended drywall ceiling (nonseismic item w::-
modification) which accounts for pertinent floor response characteristics of the systems.
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'RESULTS REPORT QJ '
ISAP II.d (Cont'd).
2.0 ACTION IDENTIFIED BY NRC (Cont'd) 3.
Verification that those items in the control room ceiling not installed in accordance with the requirements of Regulatory Guide 1.29 satisfy applicable design requirements.
4.
The results of an analysis that justify the adequacy of the nonsafety-related conduit support system in the control room for conduit whose diameter is 2 inches or less.
5.
The results of an analysis which demonstrate that the foregoing problems are not applicable to other Category,
II and nonseismic structures, systems and components elsewhere in the plant."
3.0 BACKGROUND
Seismic requirements for non-Seismic Category I commodities are
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defined in NRC Regulatory Guide 1.29, NRC Standard Review Plan Section 3.7.2, and CPSES FSAR Section 3.7B.2.8.
Regulatory Guide 1,29 (Reference 9.2) states, Those portions of structures, systems, or components whose continued function is not required but whose failure could reduce the functioning of any plant feature included in Items 1.a through 1.q* above to an unacceptable safety level should be designed and constructed so that the SSE would not cause such failure." Specifically Item 1.n states, "The control room, including its associated vital equipment, cooling systems for vital equipment, and life support systems, and any structures or equipment inside or outside of the control room whose failure could result in incapacitating injury to the occupants of the control room."
3.1 Specific Control Room Ceiling Issue The specific issue identified by the TRT involved the ability of the control room ceiling and other non-safety-related ceiling elements, i.e., conduits and lighting fixtures, to remain in place during a seismic event, thus avoiding the potential of disabling operators or affecting equipment due to its failure. Portions of the initial ceiling were non-seismic, non-safety-related and did not have provisions of Seismic Category II (see definition 'n Appendix 1) installations which are seismically supported or restrained.
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Items 1.a through 1.q identify plant structures, systems and components that must remain functional during and after an SSE.
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RESULTS REPORT QJ ISAF II.d 1
(Cont'd)
3.0 BACKGROUND
.(Cont'd)
.In reviewing'the design of the control l room ceiling, the TRT request'ed that analyses be provided that demonstrate that the.
. provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8 have been satisfied"for all non-safety-related. items.- 'This request encompassed the. architectural ceiling system (other than the sloping 1 suspended: drywall ceiling))and GL non-safety related conduit whose diameter is two (2)' inches or
. lass.
The:TRT also requested that, seismic calculations for the e
support. systems of the lighting fixtures and the sloping suspended drywall ceiling in'the control room reflect all
' loading conditions that would be experienced due:to'a seismic In; addition, an analysis was requested by.the TRT to event.
- show that the' design of the attachment of the' drywall to.its frame would ensure that separation would not occur during a seismic event.
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l 3.2. Description of Initial ceilina and ceilina Elements The control room' ceiling elements initially investigated by
.the TRT have been replaced by a new ceiling system. 'The
-following provides a brief,descr1ption of the original ceiling
.and the other ceiling elements.
The control room ceiling at the location of the control board area proper was comprised of three (3) ceiling systems (refer to Figure.1). The ceiling systems adjacent to the control boards and above the center of the control room were both comprised of suspended horizontal unistrut frames, lighting fixtures and louvered panels. The louvered panels were at elevations 839'-6" and 847'-2" respectively. The third ceiling system closed the gap between these two levels by incorporating a sloping, frame-supported gypsum wall (drywall) extending from the lower elevation (839'-6") to the underside of the floor above the upper ceiling system.
All lighting fixtures in the control room complex were seismically restrained in accordance with the restraint details shown on Gibbs & Hill drawing 2323-El-1704-01. For the lighting fixtures located in the control board area discussed above, the unistrut frames to which the lighting fixtures are attached had seismic restraints consisting of O
stainless steel cable attached to the frame and connected to the underside of the floor above (see Figure 1).
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RESULTS REPORT N'
l ISAP II.d (Cont'd) l
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3.0 BACKGROUND
(Cont'd) d 3.3 Action Plan Approach
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TU Electric reviewed the issue raised by the TRT, and a decision was made to remove and replace the control room j
ceiling in the interest of pursuing an expeditious resolution.
1 An assessment by the Project of the original ceiling design indicated that the structural integrity of the three systems could probably have been demonstrated. Details of such qualification would involve modeling assumptions.or test I
configurations for which it was anticipated that the required technical consensus would be time-consuming to achieve. Since I
such details were not likely to be discussed in published
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literature or regulatory communications, the resolution could j
delay closure of the issue. The approach selected was to
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establish a design that could readily be qualified seismically and to subject the design to a third party review. This' course of action was adopted by the Project in June of 1985.
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(j ISAP I.c, " Evaluation of Two-inch and Under Conduit".
addresses the other specific technical issue. Train C (non-safety-related) conduit two inches and less in diameter.
As stated in Item 5 in Section 2.0, the NRC requested that TU Electric address the generic implications stemming from the specific technical issues. TU Electric's program for addressing the seismic /non-seismic interaction issue was part of its Damage Study Program. This program also addressed potential comuodity interactions associated with postulated high-energy pipe breaks and moderate-energy pipe cracks: pipe whip, jet impingement, flooding, etc.
The purpose of the seismic interaction portion of the Damage Study Program (DSP*), initially established via TNE j
Instruction CP-EI-4.0-36 (Reference 9.3) in November, 1982, J
was to demonstrate that the failure of adjacent non-seismic l
commodities due to an SSE would not impair the function of j
Seismic Category I commodities or affect the safety of control room equipment or occupants, as defined in Regulatory Guide
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1.29 and FSAR Section 3.7B.2.8.
The DSP, Refer to Glossary of Terms (Appendix 1) for how "DSP" is used throughout this report. Note that the program is currently
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referred to as the " Systems Interaction Program". Ongoing
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activities of this program associated with ISAP II.d are discussed in Section 5.6.
A Chronology of events is presented in Appendix 2.
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1 Pcg2 6 of 58 RESULTS REPORT
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IS AP II.d (Cont'd) i
3.0 BACKGROUND
(Cont'd) which was implemented primarily in 1983, involved numerous walkdowns to evaluate all potential interactions using acceptance criteria developed for the study. Methods of resolution of potential interactions consisted of analysis, evaluation, use of barriers, application of administrative controls, or addition of seismic supports or restraints (e.g.,
aircraft cables). Each of the activities included pertinent requirements of the CPSES QA program. Maintenance of the DSP was performed in accordsnee with TNE Instruction CP-EI-4.0-53 (Reference 9.4).
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As identified by the TRT, the DSP had not produced a l
1 calculational basis that supported TU Electric's position that i
the original control room ceiling system and Train C conduit two inches and less in diameter met applicable requirements.
The DSP had not produced calculations for the ceiling because l
it was lumped into a large class of plant features labeled
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architectural features, most of which had been implicitly f--
assumed to be sufficiently well attached to rigid structures
(' 's) or so light in weight that their potential failure in a seismic event need not be addressed. The implications of the TRT finding were two-fold.
First, non-Category I items
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labeled as plant architectural features needed to be explicitly addressed through an extension of the DSP. Second, the DSP needed to address the interaction potential of other non-Category I items adequately. Therefore TU Electric committed to have the CPRT address these generic implications in ISAP II.d along with the specific control room ceiling issue. The additional DSP activities indicated above (those not dealing with seismic interaction), were not included for review within this ISAP because these other activities have been addressed within applicable Discipline Specific Action Plans (DSAPs) that comprise the Design Adequacy Program (DAP).
The ISAP I.c Results Report makes specific reference to large-diameter (greater than two inches) Train C conduit being addressed in the ISAP II.d Results Report. This large diameter conduit had been explicitly addressed in the DSP by the Project. The treatment of such conduit within the overall DSP was reviewed by the third party along with other potential source commodities during implementation of this ISAP.
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1 Page 7 of 58 fw RESULTS REPORT I
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ISAP II.d (Cont'd) l l
i 4.0 CPRT ACTION PLAN The objectives of this ISAP are as follows:
Assure that the control room ceiling, including equipment and fixtures attached to or located in the space above the ceiling, satisfies the seismic interaction provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8;
- Assure that the seismic interaction provisions of Regulatory Guide 1.29 have been properly implen.ented for other Category 11 and non-seismic structures, systems and components elsewhere in the plant.
These objectives encompass,the actions identified by the NRC and were implemented as three ralated but distinct taska:
Design of a new control room ceiling system to resolve the seismic interaction concerns, j
()N Verification of seismic damage assumptions for Train C conduit i.-
two inches and less in diameter, and Verification of the Damage Study Program methods and implementation and extension of the program to treat architectural features.
4.1 Scope and Methodology The first task consisted of a technical resolution of the specific issue identified by the TRT regarding the seismic interaction potential of the control room ceiling. The second task was incorporated in its entirety within ISAP I.c.
J For the third task, generic implications regarding the DSP that were raised by issues associated with the first two tasks were evaluated through a joint effort involving the Project and the third party. This effort involved expansion by the Project of the original DSP, third-party overview of these expanded activities, and a review by the third party of the original DSP.
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V' ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l l
4.1.1 Control Room Ceiling System Design The original design of the ceiling systems-was based on the premise chat the failure of architectural features with small masses would not be adverse to the equipment in or occupants of the control room. Althoupb a preliminary design assessment by the Project wncluded i
that the design complied with Regulatory. Guide 1.29, the conclusion relied on that same design premise.
In lieu of efforts directed at developing further confirmatory analysis to support the position and to finalize the structural evaluation TU Electric elected:
to remove and replace the ceiling in order to preclude unacceptable seismic interactions.
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The existing ceiling structure was removed and a new ceiling system that could be readily qualified seismically was designed and installed. The seismic p
design of the new ceiling structure, including attached Q
architectural features, was reviewed by the third party. The process for evaluation of potential seismic interactions among components above the new control room ceiling or between these components and' i
the ceiling structure was also reviewed by the j
third party, i
4.1.2 Train C Conduit Two Inches and Less in Diameter This topic is addressed in the Results Report for ISAP 1.c.
4.1.3 Damage Study Program Verification The third task assigned to this ISAP was to address the generic implications of the TRT issues associated with the control room ceiling and Train C conduit. This task involved an expansion of the DSP to address other architectural features and a review of the already-completed parts of the DSP to verify that it had been performed adequately.
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a["j RESULTS REPORT YV ISAP'II.d
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4.0 CPRT~ ACTION PLAN (Cont'd)'
Because thel design of the ceiling systems-in the control room was predicated on the, position that failureJof architectural features with~small masses would not adversely affect safety-related commodities in or occupants'of the control room, the civil / structural discipline of TNE had advised the Damage Study' Group that the control room architectural features in question should not be evaluated as part of the original DSP. Therefore, these features were not evaluated by the Damage Study Group.. Potential exclusion of other areas of evaluation due to similar inputs and assumptions was one focal point used by the third party for the original DSP verification.
The specific activities included in this. task, extension of the DSP to treat architectural features and verification of the adequacy of the original DSP, are described in more detail'in the paragraphs below.
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. Treatment of Architectural Features
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In order to extend the-original DSP to treat architectural' features, the Project performed an R
evaluation of architectural specifications and drawings to identify non-seismic sources to be evaluated in l
accordance with Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.
Architectural features in Units 1 and 2 that were determined.to have a potential for seismic interaction have been or will be modified or shown not to result in unacceptable seismic interactions with-safety-related commodities. The resolution of some of these interactions is ongoing.
1 The third party performed a review of the Project's I
architectural features evaluation. This review addressed the following aspects of the Project evaluation:
The assessment that was performed by the Project to determine which architectural features have a potential for seismic interaction,
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<-^3 RESULTS REPORT
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IS AP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l The damage study of architectural features i
that have the potential to result in unacceptable seismic interactions with safety-related commodities, and Resolution of unacceptable interactions.
Specific Project implementation activities reviewed by.
the third party in this area are presented in flow-chart form in Figure 2.
Review of Dame.ge Study Program j
The third party reviewed the procedures and methods used by the Project in the already-completed portions of the DSP as the first step in verifying adequacy of the DSP. This third-party effort included a review of
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interfaces between the Damage Study Group and the other
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disciplines that either provided input for the evaluation or acted upon the Damage Study Group's recommendations. This evaluation examined whether there were other generic areas in addition to the architectural features that may have been omitted.
Selection criteria had been used by the Project to identify the set of all non-Category I systems, structures and components that were considered for seismic interaction with safety-related items. One of these criteria was that Category II items were excluded because they were supported or restrained to preclude seismic interaction. The third party reviewed the design criteria for Category II items and all other selection criteria used by the Project. The detailed Category II design criteria were compared with Category I design criteria and methodology as well as the more general Category II FSAR commitments. Where the Category II criteria were not the same as Category I or were less detailed, their acceptability was assessed by the third party based on engineering principles applicable to the specific methodology.
The third party also reviewed the basis used in the original DSP for determining the nature of the physical 1
g-ss interactions between the non-Category I items
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identified as described above and Category I items.
The criteria used to evaluate the consequences of these j
interactions were reviewed as well, 1
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1 Page 11 of 58 7 -K
~ RESULTS REPORT ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The third party conducted an overview of Project documentation that was produced during implementation of the DSP. This overview included an engineering walkdown of selected interactions and an assessment of the adequacy of the documentation and the validity of the conclusions reached. Specific cases were selected for review so that implementation of each of the methods for analyzing interactions was reviewed.
A comparative interaction assessment was performed by the third party in selected rooms to assess the consistency with which-interactions were identified.
This was done by identifying potential interactions and comparing the results with those obtained by the DSP for the same rooms. The rooms were chosen based on selection criteria that considered the following aspects:
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Functional and physical aspects of the
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systems and components within the space, Importance of components and systems to
- safety, Representativeness of the room from the standpoint of physical proximity of potentially interactive items, and Balance of types of non-seismic items, i.e.,
arch 1tectural, conduit piping, equipment.
Specific Project activities applicable to DSP implementation prior to the identification of TRT concerns that were reviewed by the third party are presented in Figure 3.
4.2 Participants Roles and Responsibilities The following organizations and personnel participated in this effort:
4.2.1 TUGC0 Nuclear Engineering (TNE) and Gibbs & Hill, Inc.
(G6H)
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4.2.1.1 Scope Designed new control room ceiling
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RESULTS REPORT y-
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ISAP II.d j
(Cont'd).
1 4.0~ CPRT ACTION PLAN (Cont'd) 4 Performed architectural features evaluation Recommended design modifications to resolve issues resulting from architectural features evaluation or third-party verification of DSP 1
4.2.1.2 Personnel Mr. C. R. Hooton TNE Civil / Structural-4 Discipline f
Supervisor Mr. M. Wells Engineering Specialist Mr. D. A. West Damage Study' Group Supervisor (prior to Ebasco involvement) i Mr. J. Eichler Gibbs & Hill, i
Manager of Civil / Structural Department Mr. E. Bezkor Gibbs & Hill, l
Structural Job Engineer Mr. M. Pope Gibbs & Hill, Structural' Engineer 4.2.2 Ebasco Services Incorporated 4.2.2.1 Scope Performed seismic interaction evaluation portion of architectural features evaluation 1
4.2.2.2 Personnel Mr. C. Levine Systems Interaction Group Supervisor
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1 Page 13 of 58 RESULTS REPORT ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l l
4.2.3 Stone & Webster Engineering Corporation (SWEC) 4.2.3.1 Scope Performed calculations to verify the G&H control room ceiling redesign (ongoing)
Recommended and implemented design modifications to resolve issues resulting from architectural l
features evaluation and third-party 1
review of DSP (ongoing) 4.2.3.2 Personnel Mr. N. Kennedy Engineering Support Group Assistant Manager Mr. G. Dean Site Supervisor, Structural Mr. R. Murray Structural Engineer 4.2.4 Brown & Root, Inc.
4.2.4.1 Scope Installed new control room ceiling Provided as-built data on architectural features Performed testing of handrails as part of the architectural features evaluation 4.2.5 TUGC0 Quality Assurance 4.2.5.1 Scope Inspected control room ceiling modifications 9
Inspected other modifications implemented as a result of damage study interaction resolution
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~ /~'g 4 RESULTS REPORT.
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ISAP II.d (Cont'd)
~4.0 'CPRT ACTION' PLAN (Cont'd)-
Witnessed handrail' testing'as part of the architectural features evaluation
.4.2.5.2 Personnel Mr. P. Halstead Site Quality Control Manager 4.2.6 Third Party 4.2.6.1 Scope Reviewed control room ceiling analysis
.c and design 1
Reviewed architectural features evaluation i
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Reviewed DSP procedures and. criteria Reviewed ~ implementation of DSP' procedures Performed independent walkdowns to j
identify interactions Prepared Results Report 4.2.6.2 Personnel Mr. H. A. Levin TENERA - CPRT Civil / Structural Review Team Leader Dr. J. R. Honekamp TENERA - CPRT TRT Technical Manager Mr. J. C. Miller TENERA - CPRT TRT Issues Manager Mr. P. Streeter TENERA - Issue Coordinator (DSP)
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RESULTS REPORT' Q;
ISAP II.d' (Cont'd).
4.0' CPRT ACTION PLAN;(Cont'd)-
Dr. J. Arros.
TENERA - Issue Coordinator-(control' room ceiling) 4.3 Personnel Qualification Requirements Third-party participants'in.the implementation of this Action Plan meet the personnel qualification and objectivity requirements of the CPRT Program Plan ~ and its. implementing procedures. Other participants were qualified to_the requirements of the CPSES Quality Assurance Program'or to the specific requirements of the CPRT Program Plan. Activities
. performed by other than third-party personnel were governed by the applicable principles of Section III.K,'" Assurance of CPRT Program-Quality", of the CPRT Program Plan (Reference 9.5).
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.4.4 Procedures Used Gibbs' & Hill issued the procedure DP-3, " Control Room -
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Ceiling" (Reference 9.6), for.the design of the control room ceiling steel' frame. Procedures directly applicable to.and used in performing the damage study efforts for this action
. plan have undergone a series of changes'during the implementation of ISAP II.d (note that these changes have not been effected'by revisions but-instead by issuance of new procedures superseding ths. previous procedures). These changes are: described for each procedure'as part of the
-Chronology. presented in Appendix 2.
4.5 Standards / Acceptance Criteria The FSAR was used as the base document for establishing acceptance criteria. Where the criteria in the FSAR required increased detail to define specific requirements not covered by the standards and regulatory guidance' referenced in the FSAR, the bases used were accepted engineering principles and/or practices applicable to the same or similar situations.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The implementation of this action plan involved the following areas:
./. d' Design of a new control room ceiling to resolve the seismic interaction concerns, and J
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1 Pass 16 of.58 RESULTS REPORT
_f(f ISAP II.d-(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Damage' Study' Program extension and verification.
Sections 5.1.snd 5.2 respectively,' address each of these areas:
5.1 Control Room Ceiling Redesign 5.1.1 Description of the Redesigned Control Room Ceiling (refer to Figure 4)
The control room ceiling presently installed is a i
completely new design.
It is a three-dimensional space frame with two horizontal grids separated by vertical hangers and diagonal braces. This structure expands over the entire area bounded by the control panels.
Discontinuities in the main grid at the north and south ends of the ceiling divide the ceiling into a central section (approximately 91 feet long in-north-south direction) and two end sections (approximately 12 feet f%
long in the north-south direction).
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The main grid, at elevation 842'-6", is suspended from a concrete slab (top of concrete elevation 854'-4") by vertical hangers and diagonal braces, which form a-stiff truss system in both north-south and east-west directions. The end sections are only braced in the east-west direction. The mechanism for transferring north-south seismic loads from the two end sections to the central section is provided by north-south spanning tube sections that are attached to the bottom of the horizontal main grid.
j The lower grid, at elevation 839'-4", is suspended from the main grid by hangers that are provided in the north-south direction with moment-resisting connections at the main grid.
In the east-west direction the connections of the hangers to the main grid are not fully moment-resisting, and the east-west loads are transferred to the beam along the exterior boundary of the lower grid.
The lower grid, with the hangers between it and the upper grid, creates a frame to support the light dif fusers.
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1 Pag 3 17 of 58 RESULTS REPORT i
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ISAP II.d
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The concrete structure above the control room from which the steel frame is suspended consists of a rectangular slab system with T-beams spanning east-west and several rectangular beams spanning north-south.
The concrete slab was evaluated by G6H for the appropriate ceiling structure reactions and other loads on the slab.
5.1.2 Review of Design Adequacy of the Redesigned Control Room Ceiling Steel Frame The process of evaluating the design of the control room ceiling structure was initiated by reviewing the design procedure DP-3, " Control Room Ceiling". All design calculations, including the equivalent static computer analysis that utilized the STRUDL program, were reviewed for compliance with the acceptance criteria indicated below. The response spectrum s
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computer analysis performed to justify the adequacy of the equivalent static analysis as a design basis was spot-checked for inputs and reasonableness of results.
The evaluation of the concrete structure at elevation 854'-4" was also reviewed by the third party.
Acceptance Criteria The first step in reviewing the design adequacy was to l
develop acceptance criteria for the review.
In accordance with the commitments of FSAR Section l
3.8.4.5.1 for steel structures, the acceptance criteria i
for this review were taken from the Specifications of l
the AISC manual, 7th edition (Reference 9.7).
The l
applicable AISC criteria for members, beams, hangers, and braces are identified in an engineering evaluation (Reference 9.8).
The acceptance criteria for torsion effects in the members were taken from the recommendations of the AISC publication " Torsional Analysis of Steel Members," 1983 (Reference 9.9).
The acceptance criteria for the evaluation of the concrete slab at elevation 854'-4" above the control room I
ceiling steel framing follow ACI-318-71 (Reference 9.10).
Tension and shear allowables for Hilti anchor bolts are in accordance with the G&H Specification SS-30 (Reference 9.11).
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(Cont'd)
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35.01: IMPLEMENTATION OFIACTION PLAN'AND DISCUSSION OF RESULTS (Cont
.The acceptance criteria'for the computer _models used B
were that they accurately reflect'(1) the geometry. (2)-
' material and member section' properties, and (3) the F1 10 Enember end conditions-as shown on the design drawings 1 '
listed-in Table 1 of Reference 9.8 asLwell as (4) all specified loads and load combinations. The loads and load. combinations used were in"accordance with FSAR~
>Section 3.8.4.3.3.
Seismic analysis was performed'in-3 accordance~with FSAR Section 3.7B.3.
J Evaluation of Design Procedure DP-3 The design procedure DP-3, " Control Room Ceiling",
' classifies the control room ceiling steel frame as a.
'l seismic Category I structure.- The load combinations in
'the ' procedure are in accordance with the acceptance criteria specified in FSAR Section 3.8.4.3.3.
I c fg DP-3 specifies the equivalent static method as the fQ method-to be used for the design analyses.
In light of the complexity:of the-frame structure,'and also to assure that-the equivalent static' analysis was appropriate and conservative for the ceiling frame, j
G&H performed a response. spectrum analysis of the frame i
to verify that the accelerations within the frame were
{
-less than the 1.5 times the floor response spectra' peak l
accelerations specified for the equivalent. static-analysis..FSAR Section 3.7B.3.5' allows for equivalent.
static. analysis of structures when'such structures can j
be conservatively modeled.
Evaluation of Design Calculations and Equivalent Static Analysis i
The equivalent. static analysis was performed in two parts:
(1) the main space frame by computer analyses (STRUDL program), and (2) the portion below the main horizontal grid, i.e., the lower grid with the hangers, by hand calculations.
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During the review of these calculations and computer analyses, questions raised by the third party resulted in the identification of discrepancies in the calculations and in the computer model. The identified discrepancies were documented on a C-type DIR (C-0428).
Gibbs & Hill resolved and corrected the identified discrepancies and issued revisions to the drawings and calculations.
The third-party review of the design calculations is documented in checklists (Appendix 1 of Reference 9.8).
These checklists identify the appropriate acceptance
}
criteria for each component and provide a mechanism for j
assuring that all criteria have been addressed and met.
Evaluation of Response Spectrum Analysis The response spectrum analysis utilized a computer
{
n model (NASTRAN program) identical to the one used for j
(")
the static analyses.
It included spring-mass systems j
below the main grid to represent the effects of the lower grid on the main grid. The parameters of these I
" equivalent" spring-mass systems were determined such that their mass and natural frequencies in three f
directions were identical to those of the actual lower j
frame.
)
Because of the relative uniformity of the distribution i
of the mass and stiffness in the ceiling structure and j
the expected uniformity of the acceleration pattern within the structure, modal acceleration was selected as a basis for comparison of results between those predicted by the equivalent static and response spectra methods.
The accelerations from the response spectrum analysis were shown to be less than 1.5 times the floor response spectra peak accelerations everywhere in the structure with a few exceptions. All members and connections adjoining the nodes where acceleration exceeded 1.5 times spectral peak were evaluated in the G&H calculations for loads corresponding to the higher vertical accelerations obtained from the response spectrum analysis and found to meet the design
[V}
criteria. The third party reviewed this evaluation and concurred with the conclusion that the design criteria are met by the redesigned control room ceiling.
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1 5.0 IMPLEMENTATION OF ACTION PLAN AND DI3CUSSION OF RESULTS (Cont'd) 5.1.3 Review of Commodities Attached to or Above the Control j
Room Ceiling The identification of potential interactions was performed by the Project in accordance with TNE 1
Instruction CP-EI-4.'0-36 and Procedure TNE-DC-23 I
(Reference 9.12).
The resolution methodology for potential interactions is addressed in Specific j
Technical-Issue Report STIR-CPRT-S-008, " Resolution of
)
ISAP II.d Open Issues" (Reference 9.13).
This effort i
is ongoing as.part of the Systems Interaction Program (SIP) in accordance with TNE Procedure ECE 2.24, (Reference 9.14), TNE Design Basis Document DBD-ME-005, (Reference 9.15), TNE Field Verification Method CPE-EB-FVM-SI-40, (Reference 9.16), and INE Mechanical Engineering Technical Procedure EME 2.24-01 (Reference 9.17).
j
(}
The third-party review of the commodity and interaction E /
identification approach and the interaction resolutions s-and methods all presented in STIR-CPRT-S-008 and the SIP procedures noted above, concludes that reasonable approaches have been and are being taken.
i 5.1.4 Summary of Control Room Ceiling Issue
]
The original ceiling was raplaced with a design that is in conformance with the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.
Methods have been identified that, when implemented, will assure that commodities attached to or above the ceiling satisfy these same provisions.
E-type DIRs were prepared to document initiating external source concerns; one about the ceiling and six about commodities on or above the ceiling. These are discussed in Section 5.3.
Because all of these were categorized as unclassified deviations, a root cause evaluation was performed and is discussed in Section
{
5.5.
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RESULTS REPORT
!U ISAP II.d (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2 Damage Study Program Verification The Damage Study Program (DSP) has been an ongoing activity at CPSES since 1982 (refer to the Chronology in Appendix 2).
The DSP includes the identification, evaluation, and resolution of potential seismic interactions. These particular aspects of the DSP are the focus of this ISAP. This section addresses:
the Project effort to identify, evaluate, and resolve those potenttal seismic interactions involving architectural features as sources that were not included in the original DSP; the third-party review of the above Project effort; the third-party evaluation of DSP procedures and criteria;
~
i
(')s the third-party evaluation of DSP implementation; and, I
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a comparative interaction assessment conducted by the j
third-party, j
The above five sub-topics are addressed in Sections 5.2.1, 5.2.2, 5.2.3, 5.2.4, and 5.2.5, respectively.
j i
5.2.1 Project Evaluation of Architectural Features Process of Evaluation l
The objective of this Project activity was to extend the DSP to include an appropriate treatment of architectural features. To do this, TNE Instruction CP-EI-4.0-63 (Reference 9.18) was prepared by the Project specifically to address the identification of potential sources of seismic interactions involving architectural features. This procedure required a I
complete review of all architectural specifications and I
drawings in order to identify potential source commodities.
Following commodity identification, potential interactions were identified and resolved in the same manner as for other interactions involving non-architectural feature source commodities through the use of TNE Instructions CP-EI-4.0-36 and
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(Cont'd) t 5.0.
IMPLEMENTATION OF ACTION PLAN'A5D DISCUSSION'0F RESULTS (Cont'd)
During implementation of the portion ofthe review entailing resolution of interactions, the Project determined that certain aspects ofithe process were in question. These aspects primarily involved the completeness of potential source commodity identification. As a result, TNE Instruction CP-EI-4.0-63 was revised and reissued as TNE Procedure TNE-DC-26 (Reference 9.19) to improve the identification process. Project implementation of the reissued procedure was then followed by interaction identification and resolution in accordance with-s Procedure TNE-DC-23.
The timing and content of-these activities is presented in the Chronology in Appendix 2.
Acceptance Criteria The decision / acceptance criteria used by the Project in the architectural features evaluation were the same as l
/]
for other aspects of the DSP except for an initial
,{
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screening activity specifically associated with "I
CP-EI-4.0-63 and TNE-DC-26.
These procedures required that there be documented concurrence between civil / structural personnel and'DSP personnel about l
which types of architectural feature source commodities might be excluded from subsequent DSP evaluation.
Evaluation Results The Project's architectural features evaluation i
resulted in the identification of several interactions involving various groups of source commodities. Many
{
of these interactions were resolved by the Damage Study l
Group in accordance with DSP procedures. However, j
remaining unresolved interactions were identified to the Project's civil / structural discipline for resolution. Although the Project efforts were initiated by the G&H civil / structural discipline to resolve the interactions, none of these efforts were l
{
completed prior to SWEC's involvement in October, 1986.
Following this transfer of responsibility, the resolutions were addressed in a series of Specific Technical Issue Reports (STIRS). The timing of the issuance of the STIRS is presented in the Chronology ic e-~g Appendix 2.
A discussion of each STIR is presented tr Q) l l
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,ISAP II.d (Cont'd) 50 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
.i Appendix 3.' including a description of any ongoing l
.c..
activities.' The following groups or architectural RS *
. feature source commod. ties are addressed.by these H
,L 'i STIRS:.
i Source Commodity STIR No. (Reference) i
.r.
Sheet Rock (drywa41) Walls
.STIRLCPRT-S-006 (9.20)
Doors and Security Barriers STIR-CPRT-S-007 (9.21)
Floor Gratings' STIR-CPRT-S-011 (9.22)
Handrails-STIR-CPRT-S-012 (9.23)-
Ladders STIR-CPRT-S-Oli (9.'24) 5.2.2 Third-Party Review of Architectural Features Evaluation-Process of Third-Party Review The objective of this review was to provide an
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assessment of the following three activities:
V
.I the process by which. architectural features were M[
identified for seismic interaction consideration; the subsequent damage study of those architectural features; and
{
the resolutions of any unacceptable it.teractions.
The third-party efforts primarily involved a review of documentation associated with the above activities.
- since the DSP implementation evaluation (fection 5.2.4) and the comparative interaction assessment: (Section 5.2.5) included numerous physical inspections specifically related to the overall DSP process.
Acceptance Criteria In general, the third party reviewed procedures and i
implementing documents (including the' STIRS) to insure
)
that applicable FSAR cannitments were satisfied.
-l Implementing documents associated with potential source and interaction identification were also-reviewed to, assure compliance with the applicable DSP procedures.
I Implementing documents associated with interaction resolution were also evaluated against the more
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specific criteria identified in the various STIRS.
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-(Cont!d) 4 5.0.. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF'RESULTS'(Co
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x Results of the Procedures Review Procedures CP-EI-4.0-63 and TNE-DC-26,: issued by the Project for identifying types of architectural feature source commodities, were considered by the third-party-3D to provide reasonable bases for assuring that all appropriate. architectural festures were included in the evaluation process.
11 Results of the Implementation Review y
t+'
The review of the architectural features identification
-process produced examples where specific commodities that.should have been included for DSP evaluation were omitted. This resulted'in concerns involvin$
documentation and the thoroughness's of the Project's -
architectural feacures identification effort. While the number of such" commodities appears to be limited, C :b this situation remains.co be confirmed.by ongoing 1(
).
Proj ect. ac tivities. The concerns were documented on t
'C-type DIRs' (C-032T through' C-0331). All'other aspects sI of the Project interaction identification.and evaluation activities were found to be performed' consistant with the.same processes. applied for all.
f other source commodities, i
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Interaction = resolutions for all identified-interactions involving architectural feature source conunodities are
. addressed in the STIRS. As discussed in Appendix'3, several resolution activities are ongoing.
5.2.3 Review of Damage Study Program Procedures and Criteria Process of Third-Party Review The review of the original DSP included evaluation of the following areas:
l DSP Procedures,
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Interfaces between the Damage Study Group and other disciplines, l
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION.0F RESULTS (Cont'd) i Potential for omission of generic areas, 7
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.DSP selection. criteria for sources'and targets
. including setsmic. Category II criteria.-
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Basis'for determining interactions,.
DSP criteria for interaction evaluation and Method of identifying classified and= unclassified rooms.
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i The objective of this review was to ensure that these criteria'and procedures.were compatible.with associated FSAR commitments and accepted engineering practices.:
The review specifically addressed the DSP procedures and' criteria that were in effect prior to the TRT.
actions that initiated this ISAP.
' Acceptance Criteria:
The process being reviewed was compared with general FSAR'11 censing commitments. However, the DSP procedures generally provided methods for implementing FSAR commitments that were more detailed than the FSAR.
In these situations.l acceptability was based on meeting the intent of FSAR constituents regarding source -
commodity, structural' integrity or potential interaction resolution. That is, the FSAR requires that potential j
source commodities be shown to remain in place during and after an SSE,for, if source commodity damage and/or
' ?,
failure does occur, that there will be no unacceptable.
effects on adjacent safety-related commodities.
]
Results of Review Concerns were identified by the third party about
]
several aspects of the DSP. These aspects are I
sunmaarized below. Disposition of associated DIRs is f
addressed in Section 5.3; associated ongoing corrective J
. actions are addressed in Section 5.6.
Documentation of the third-party review is contained in an engineering evaluation (Reference 9.25).
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IS AP II.d i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Relative Building Motions:
This concern involved the failure of the DSP to identify potential interactions between Seismic Category I commodities attached to different buildings or portions of buildings (e.g., the clearance between a pipe support attached to the containment internal structure and and a pipe support attached to the containment shell, where relative structural motions exceed this clearance'). DIR D-1841 was prepared to document this concern.
Related to the above concern, there also was an apparent failure to identify potential interactions involving commodities attached to secondary (non-load bearing) walls (e.g., a Train A or B conduit support attached to a secondary wall and a Class 5 pipe support attached to the adjacent ceiling, may have a clearance between them that is insufficient to accommodate the
'"')
relative motions of the wall and ceiling). This
(_/
concern was identified during implementation of ISAP II.c (Reference 9.26) but was more closely related to this ISAP and is addressed here. DIR D-2132 was prepared to document this concern.
j Horizontal Motion of Suspended Lighting Fixtures:
This issue involved the failure of the DSP to identify interactions resulting from the horizontal swaying of
{
suspended lighting fixtures even when stainless steel cable had been added to prevent falling. DIR D-1843 was prepared to document this concern.
j A related area of concern involved certain frame-supported lighting fixtures that had been assumed by the Damage Study Group not to be potential sources on the basis of the presence of stainless steel cable.
The cable, however, was secured to the supporting frame for which there was no analytical documentation of seismic adequacy. DIR D-2183 was prepared to document this concern.
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ISAP II d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
W Attachments to Large Seismic Equipment:
This concern involved the failure to identify interactions associated with source commodities not seismically-qualified but attached to large seismically-qualified equipment (primarily cranes) after the equipment was installed. DIR D-1840 7
was prepared to document this concern.
Line-Mounted items on Small Bore Piping:
This concern involved the failure to identify potential interactions resulting'from source commodities that were line-mounted on small-bore piping. Thess commodity weights were well in excess of standard in-line items such as valves.
DIR D-2200 was prepared to document this concern.
Horizontal Motion of Piping / Conduit:
For cable-restrained piping and Train C conduit greater than two inches in diameter and for all small bore piping, it was assumed by the Damage Study Group that there would be no adverse impact of potential targets due to horizontal motion of the source commodities.
There was documentation for these assumptions for cable-restrained piping and conduit greater than two inches in diameter (G&H civil / structural discipline study), but review by the third party indicated the documentation to be inadequate to support the i
assumption. There was no such documentation for small bore piping even though the third party identified specific potential interactions. DIR D-1842 was prepared to document these concerns.
Pipe / Conduit Over Cable Trays:
This concern involved an inadequate basis for one of j
the Dynamic Impact Criteria (Reference 9.27) used by.
the Damage Study Group during walkdowns to resolve potential interactions. Specifically, the criterion in question allowed walkdown persennel to resolve interactions in instances where potential source pipea/ conduits were above safety-related cable trays.
i The resolution was implemented on the basis of judgeent j
. I but without regard for pipe / conduit size, distance above the cable tray, tray support span etc.
DIR D-1844 was prepared to document this concern.
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Use of Nomogram to Support Class 5 Large Bore Pipe Seismically:
l-Some large bore class 5 piping that was' designated as Seismic Category II was seismically supported based on use of a nomogram in G&H specification 2323-MS-46B
-(Reference 9.28).
The third party identified a concern that the. lack of guidance for determining support loads might lead to underprediction of loads and potential invalidation of the Seismic Category II designation.
DIR D-1845 was prepared to document this concern.
y 5.2.4 Review of Original Damage Study Program Implementation Objective and Process of Third-Party Review The primary objective of this review was to assess the overall implementation of the DSP.
This was done by evaluating the entire DSP process. The review
{
specifically addressed implementation of'the DSP procedures prior to the TRT actions which initiated this ISAP. A limited number of source' commodities with' and without interactions were selected to represent the types of commodities encountered during the DSP.
Existing DSP documentation was provided by the Damage Study Group, with the source commodities being selected as much as possible from different rooms or areas.
Additional documentation was provided as necessary by other discipline groups on site (e.g., calculations, designs for physical modifications).
Each package wcs evaluated against a standard checklist (Reference 9.25).
A secondary objective of the third-party review was to verify the adequacy of interactions resolved using the Dynamic Impact Criteria (DIC). This objective was a result of the procedures and criteria evaluation discussed in 5.2.3.
The verification was done by first selecting a cample of the interactions resolved using the DIC. Each interaction was then independently resolved by quantitative means based on accepted engineering principles. It was not intended that this effort specifically evaluate whether the appropriate DIC was selected to resolve an interaction.
- Instead,
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each of the selected interactions was quantitatively
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r'L(_,fa ISAP II.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd).
l assessed so as to measure the acceptability of l
interaction resolution whenever any of the qualitat1ve DIC were employed.
Acceptance Criteria Acceptability of DSP implementation was based on consistency of application and compatibility with j
applicable procedures.- Because the FSAR does not include criteria specific enough for the level of methodology reviewed here, analytzcal resolutions were
)
primarily compared to accepted engineering principles.
However, where it was clearly indicated in available documentation that seismic Category I criteria were-applied, application of such criteria was considered to be acceptable without further review.
The acceptability of the DIC was based on satisfactory
\\-
conclusions being reached for each of the selected
,^;
interactions. This involved performing independent I
'ss calculations to verify the DSP results. The calculations were not intended to insure strict compliance with FSAR criteria for seismic Category I items but rather to provide reasonable assurance either that source failure would not occur or that, if it did, target function would not be impaired.
Results of Review Based on physical walkdowns and a review of documentation, evaluation checklists were completed for twenty-two (22) sources for which there were fourteen (14) identified interactions. Based on these efforts, it was concluded that overall DSP implementation was adequate. Documentation of this evaluation is contained in Reference 9.25.
For the DIC, calculations were performed for the selected interactions based on physical measurements and other data gathered during third party walkdowns.
^
It was concluded that use of the DIC was an acceptable i
method of interaction resolution with the exception of Criterion 6, which is applicable to source pipe / conduit
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, (k ISAP II.d (Cont'd) 5.0 ' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS-(Con in over safety-related cable tray. This.iconcern is discussed in Section 5.2.3.
The Project responded to this concern by reviewing all-interactions ~that-had1been resolved through use of'this Criterion. Some hardware modifications resulted and the SIP' procedures do net include the criterion.
Associated ongoing. corrective actions are addressed in Section 5.6.
5.2.5 Comparative Interaction Assessment (CIA)
Process of CIA I
The objective of this evaluation was to provide an.
additional measure ~of;the adequacy of'the DSP by
. identifying interactions (by a walkdown process) in particular areas, and then comparing the results with existing DSP interaction identification documentation
,N for those same areas.
The results of the CIA are documented in Reference 9.25.
Acceptance Criteria The most obvious basis for acceptance was for the
-interactions identified during this assessment to match those already. identified by the Damage Study Group (DSG). However, strict agreement was not expected for the following reasons:
Some of the interactions identified initially by the DSG would have been resolved by physical modifications. Therefore, they would no longer be interactions and would not be identified as such during this ansessment.
Some differences might occur simply as a result of j
dif ferences in judgment.
i Where differences in judgment resulted in third-party identification of a potential interaction not previously identified by the DSG, an assessment was w(
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.ISAP :II.d '
(Cont'd)
-i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF'RESULTS (Cont'd) made to verify that the basis for the DSG conclusion, i.e., that no unacceptable interaction occurs,'was still. valid. This assessment was based primarily on accepted. engineering principles.
CIA Results The rooms that were walked down contained what is considered by the third party to be representative of 1
components typically encountered in nuclear plant installations. Except for architectural festures and.
Train C junction _ boxes. there were no particular disparities between CIA results and existing DSP results.
Train C junction boxes were~ generally not considered by DSP walkdown teams to be of consequence relative to source potential..For.the specific junction box that initiated this area of concern, the third party concluded that junction hax attachment failure was not credible; this could not be readily verified for the more general application to all'Trafn C junction boxes.
However, further third-party inve'stigation was considered unnecessary because of other on-going Project programs that. are addressing the seismic capability. of conduit and cable tray including junction boxes. The'se other. programs and associated criteria are described in STIR-CPRT-008.
It also was determined that the architectural features identified as part of the CIA walkdowns were also identified as part of the DSP architectural feature walkdowns discussed in Section 5.2.2.
It is concluded that the comparative interaction assessment (in conjunction with other parts of this evaluation) provides reasonable assurance that DSP walkdowns (including architectural features walkdowns) have included all general categories of source commodities with the possible exception of Train C junction boxos.
Associated ongoing corrective actions are addressed in Section 5.6.
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ISAP II.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS <(Cont'd) 5.2.6 Summary of Damage Study Program Verification l
The Project extended the DSP to include architectural 1
features. The third-party review of this effort and the original DSP identified several areas of concern.
In response to these concerns, the Project has identified several actions that, when implemented, will assure that all potential seismic interactions are identified and resolved consistent with Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.
Nine D-type DIRs and two E-type DIRs were prepared to document concerns associated with the DSP. These DIRs are discussed in Section 5.3.
5.3 Sumary of DIRs A total of 18 DIRs (D-Type and E-Type) were written to h
document discrepancies identified in the implementation of this ISAP.
L/
These discrepancies reside in two major categories. The first of these involves discrepancies related to the development of the DSP and the second involves discrepancies related to the development of Project engineering design criteria and their application by the Proj ect.
Fourteen DIRs* were issued to document concerns related to the original DSP. These DIRs included' discrepancies involving the control room ceiling and other architectural features, commodities attached to/above the control room ceiling, and relative building motion. A complete list of the D-Type and E-Type DIRs and their classification and disposition are contained in Appendix 4.
Six DIRs* were issued to document concerns identified regarding the development of Project engineering design criteria and their application by the Project. These DIRs document discrepancies involving support of Class 5 piping.
Note that two DIRs (D-1842 and D-2132) contain elements of both DSP and engineering criteria concerns.
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i ISAP II.d (Cont'd) 5.0' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)'
~ horizontal pipe / conduit motion, second'aryl wall motion, and adequacy of frame supports for'11ghting fixtures. The' classification and disposition of these DIRs'are also.
3 presented in Appendix 4'.
In addition-to the D-Type and E-Type DIRs discussed above,~ a total of 6 C-Type'(in-process) DIRs:were prepared to document concerns associated with Project ISAP. implementation activities. DIR-C-0428'was resolved during the. completion'of..
the control room ceiling redesign. DIRs C-0327 through C-0331 remain open and.are discussed in Section 5.6.
, 5.4 Safety Significance Evaluation The discrepancies identified on three-of the D-type DIRs t
1
.(D-1840, D-1843, and D-2200) were determined not to constitute deviations because no unacceptable interactions were identified and the DIRs were closed as observations. The 1
discrepancies identified on the remaining six D-type DIRs -
(D-1841, D-1842, D-1844, D-1845, D-2132, and D-2183) and on all nine E-type DIRs (E-0266, E-0267, E-0887, E-0988 E-0989 E-1045, E-1210. E-1218, and E-1221) were determined to be
-design deviations. Because of the extensive corrective actions instituted by the' Project,'it was determined to be
.more expeditious to proceed directly to an analysis of the root cause.and generic implications without evaluating the safety significance of the deviations. Therefore, these discrepancies were classified as unclassified' deviations.
5.5 Root Cause and Generic Implications As discussed in Section 5.3, the unclassified deviations fall into two general categories:
- 1) the development of the DSP and 2) the development of Project engineering design criteria and their application by the. Project. Similarly, the root cause evaluation summarized in this section focuses on these i
two categories. Specific details associated with this root cause evaluation applicable to individual unclassified deviations are documented within an engineering evaluation (Reference 9.25).
This evaluation f.escribes how specific unclassified deviations are associated with each category, i
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.ISAP II.d (Cont'd)
'5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The. criteria in Regulatory Guide 1.29 for addressing seismically-induced interactions between Seismic Category I commodities and non-seismic commodities focus largely on an identification of those conunodities that must remain functional during and after an SSE. Potential source commodities, on the other hand,'are addressed only'to the extent that it is stated that they should not impair the function of the safety-related commodities listed in the Regulatory Guide. Using the, terminology of the Regulatory Guide, potentia 1' source commodities include all portions of structures, systems, or components whosa continued function is not required to mitigate the consequences of.an SSE.
The FSAR conunits to Regulatory Guide 1.29 without exceptions. In contrast to the generality of the Regulatory Guide requirements, the DSP procedures were rather specific in identifying source commodities to be considered. However, this identification did not include all possible source commodities (or groups of commodities),
nor was there explicit direction to DSP walkdown team members to consider any source commodities not specifically listed in the n
procedures.
U Given this background, two root causes can be postulated for the failure of the DSP to identify and/or evaluate properly all potential source commodities:
- 1) less-than-adequate procedures and
- 2) DSP personnel had less-than-adequate ex p rience and/or training.
Considering the first of these postulated c mses, the nature of the physical features of the plant makes it impractical to identify all potential sources of interactions in such procedures prior to their implementation. Accordingly, sufficient guidance is typically built into similar programs in the industry to assure that source conanodities that may not be specifically addressed in procedures are addressed during seismic interaction walkdowns. However, for the specific area of architectural features, it is judged inappropriate to address such a broad category of conanodities in this manner.
Instead, architectural features should either have been explicitly identified at least as a category of source commodities for consideration during DSP walkdowns, or justification for exclusion should have been documented.
Therefore, the third party concludes that the DSP procedures did not include sufficient guidance to assure that, in particular, the broad category of architectural features was addressed, or that, in general, all unspecified source commodities would be considered.
Thus, the root cause is the failure of the DSP procedures to
{
provide such guidance.
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L RESULTS REPORT ISAP II.d.
1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS ~ (Cont'd)
~
Despite;the inadequacies-in'the. procedures, DSP personne1'were not
- e
~ precluded from identifying potential interactions involving source-commodities not specifically identified in the'DSP. procedures, and L
they did so in'several cases. 7Therefore, it is possible that. had the personnel involved in walkdowns had a higher level of experience',;they might have identified more such interactions. On
'the other hand, DSP personnel generally implemented the procedures acceptably for source commodities specifically identified:in the DSP. procedures.. With respect to the second postulated root:cause, therefore the third party. concludes that'DSP valkdown personnel 1
generally demonstrated sufficient capability.to implement the
.I procedures ~as written and that the failurei1n the architectural I
features area cannot be directly attributed to less-than-adequate training of personnel. However, it is judged that personnel may.
have had less than desirable experience based on tho'incomp1'te e
identification of source commodities beyond those specified in'the DSP procedures.
Ow The second group of DIRs addressed problems in the development and
. application of criteria by the G&H engineering disciplines. _These criteria helped form the engineering bases for certain DSP input assumptions (e.g., seismic capability of architectural features) and for resolving' seismic interactions (e.g., impact of a non-safety related item with a safety-related item).. The reviews conducted during the implementation of this ISAP identified a lack of design calculations and analyses supporting engineering assumptions, incomplete consideration of certain sources and associated motions, and the failure to consider loads in the design of structures. These findings are the result'of weaknesses in the design control elements of the engineering program. 'An investigation into the specific nature of these weaknesses and their possible causes, e.g'., less-than-adequate procedures or-inexperienced engineering personnel, was not conducted as part of this ISAP. However, the third party notes that they are similar to findings against the design control program. identified during the conduct of the CPRT Design Adequacy Program.
The ongoing and recommended corrective actions described in Section u
j.
5.6.will address, when implemented, the root cause and generic implications of the less-than-adequate DSP procedures and less-than-desirable experience among DSP personnel, and will assure that the requirements of Regulatory Guide 1,29 are met. The Systems Interaction Program is being implemented as part of the TU Electric Corrective Action Program (CAP). The CAP has sufficient g
breadth and depth to address the root causes and generic implications of the design control program weaknesses.
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ISAP.II.d
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(Cont'd) 1 I
c 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.6 Ongoins Corrective Actions and Re' commendations The ongoing Project. activities described in the previous
~
sections form corrective actions.in' response to ISAP II.d implementation..These corrective actions.are summarized here and are supplemented in some' cases by third party recommendations.- Where: appropriate. the identified corrective actions will.be overviewed in accordance with SRT direction to
. assure that.the' actions taken address these recommendations and' adequately' satisfy ISAP II.d commitments.
'5.6.1 Commodities On/Above Control Room Ceiling (from 5.1.3)-
Resolutions of interactions associated with commodities attached to or above the control room ceiling.are presented in STIR-CPRT-S-008 and are based, to some extent, on engineering judgement.. Because of this, the Project is confirming these resolutions using the L
industry experienced-based methods addressed in the new s
, SIP procedures (References 9.14 through 9.17).
This offort is ongoing.
5.6.2 Architectural Features Identification (from 5.2.2)'
It is recommended:that implementation of the new SIP procedures *(References 9.14 through 9.17) include a-validation of the architectural features process 4
currently based on Procedures CP-EI-4.0-63 and I
TNE-DC-26.
Specifically, it should be assured that reasons for including and excluding particular architectural feature commodities are clearly identified / documented. Additionally, the responsibilities of the Systems Interaction and Civil / Structural groups should be clearly established i
for this effort, including control / documentation of all j
interface activities between.these groups. These recommendations are based on concerns documented in DIRs C-0327 through C-0331.
5.6.3 Architectural Features Interaction Resolutions (from 5.2.2)
The activities associated with implementation of O
STIR-CPRT-S-006 and -016 are complete. Most of the activities associated with implementation of STIR-CPRT-S-007 and -011 are ongoing.
Several
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RESULTS REPORT
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ISAP II.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) calculations are to be performed to assure structural integrity of the potential source commodities (doors, floor gratings, ote.) associated with these latter two STIRS. Because these STIRS do not necessarily limit such commodities to Seismic Category I design requirements, it is recommended that the design criteria used be clearly identified / referenced in each i
calculation. Where criteria might be less conservative than Seismic Category I requirements, justification for use of the criteria should also be included.
5.6.4 Relative Building Motions (from 5.2.3)
Implementation of the commodity clearance program presented in STIR-CPRT-S-018 (Reference 9.29) is ongoing. This program addresses the adequacy of clearances around all safety-related commodities in the plant and includes consideration of relative building motions.
Several specific third party concerns have
,,_ A
\\--
been identified regarding the implementing documents e
which support the commodity clearance program.
These concerns are presented in Appendix 2.2D of the Engineering Evaluation (Reference 9.25) and will not be repeated here.
It is recommended that these concerns be addressed as appropriate during implementation of the associated documents.
5.6.5 Secondary Walls (from 5.2.3)
Implementation of STIR-CPRT-S-009 (Reference 9.30) for secondary walls is ongoing. This effort is based in part on satisfaction of fairly general criteria.
It is recommended that associated calculations identify the specific criteria used (by reference to the FSAR, AISC/ASME codes, or other existing project criteria documents with specific load combinations /allowables).
Additionally, where the criteria used are not the same as FSAR criteria f or similar commodities, the justification for any differences should be identified / documented.
5.6.6 Frame-Supported Lighting Fixtures (from 5.2.3)
Implementation of STIR-CPRT-S-008 for frame-supported i
(q lighting fixtures is ongoing. This effort 1s based on
_)
satisfaction of general criteria.
It is recommended
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RESULTS REPORT
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ISAP,II d (Cont'd) h 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) that associated calculations. identify'the specific l
criteria used (by reference:to the FSAR, AISC code, Lor
- other existing project criteria documents with specific load' combinations /allowables). Additionally, where the criteria used'are not the same'as FSAR criteria for similar commodities, the justification for any l.
differences should be identified / documented.
5.6.7' Line-Mounted Items on Small Bore Piping (from 5.2.3)
Implementation of new Systems Interaction Group procedures (References 9.14 through'9.17).is ongoing.
These procedures include'line mounted: items on small bore piping as source commodities.
5.6.8. Horizontal Motions of Piping and Conduit (from 5.2.3)
Implementation of STIR-CPRT-S-008 for the horizontal
. motions of all sizes of non-seismic piping and large
(~
diameter Train C conduit involves application of-the commodity clearance program.. In addition to the recommendations for this program referred to in Section 5.6.4, it is recommended that the program implementation documents CPE-TVM-CS-068 and'CPES-S-1021 (References 9.31 and 9.32,-~respectively) specifically identify small bore non-seismic piping as part of the program.
In. addition, the bases for the tabulated motions (in the program documents) for-all types of piping and conduit should be justified and documented.
5.6.9 Class 5 Large Bore Piping Supported Based on Nomogram (from 5.2.3)
Implementation of STIR-CPRT-S-008 is ongoing for, Class 5 large bore piping which had been seismically supported based on a nomogram method.
Implementation 3
is by way of Project procedure CPPP-30 (Reference
- 9. 3 3).
l
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5.6.10 Train C Junction Boxes (from 5.2.5)
Implementation of STIR-CPRT-S-008 is ongoing for activitieu associated with Train C junction boxes.
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ISAP II.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.6.11 Systems Interaction Program Procedures As indicated in some of the specific areas above, implementation of the new Systems Interaction Program procedures addresses certain areas of concern j
identified during implementation of ISAP II.d.
These procedures were prepared based in part on ISAP II.d activities and results and the procedures are being l
implemented by personnel with significant previous experience in seismic interaction assessment (refer to the root cause discussion in Section 5.5).
As such, the ongoing implementation of the procedures for all aspects of seismic interaction evaluation is considered to be part of Project corrective actions in response to j
overall ISAP II.d efforts.
I
6.0 CONCLUSION
S O
I Conclusions reached by the third-party during the investigation of the control room ceiling and Damage Study Program issues discussed l
in this report are summarized in this section.
6.1 Control Room Ceiling Element Redesign Based on the engineering review and evaluation performed by l
j the third party, the redesign of the control room ceiling meets the design commitments and acceptance criteria defined in the FSAR.
6.2 Damage Study Verification The Project review of architectural features resulted in several design and hardware modifications to assure compliance with FSAR commitments regarding seismic interaction.
Third party review of these activities resulted in identification of concerns primarily regarding the completeness of the Project review (it appears that Project resolutions to the concerns will result in a small increase, if at all, in the number of potential interactions). The procedures that govern implementation of the Systems Interaction Program and the commitments made in the several l
relevant STIRS that cover civil / structural discipline issues G
provide assurance that all these concerns have been or will be adequately addressed.
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'RESULTS REPORT ISAP II.d (Cont'd)
Damage Study Program procedures and their implementation prior L
'to ISAP II.d were reviewed by the third, party.
While DSP
. implementation was found to.be satisfactory, several concerns
. ere identified related.co procedures and criteria. Current-w Systems Interaction Program procedures and-commitments in civil / structural. discipline Specific Technical-Issue Reports provide. assurance that all,these concerns have been or will be adequately addressed.
7.0' ONGOING ACTIVITIES-The' majority of ongoing activities associated with ISAP II.d are part ofsche corrective actions described in Section 5.6.-
Two additional' activities are related to the ISAP. The first activity involves the control room ceiling calculations; the Proj ct e
activities are ' described in STIR-CPRT-S-013 (Ref erence 9.34). The second activity involves suspended lighting fixture sway
~
calculations; the Project activities are described in C\\
STIR-CPRT-S-008.
In both cases, the efforts involve confirmation by the SWEC civil / structural discipline of previously-completed G&H.
civil / structural calculations. Because the G&H calculations were completed and reviewed by che third party, the additional confirmation efforts are not considered by the third party to be corrective actions.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Successful implementation and completion of the corrective actions described in Section 5.6 will provide assurance that the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8 are satisfied.
i
9.0 REFERENCES
9.1 " Safety Evaluation Report related to the operation of Comanche j
Peak Steam Electric Station, Units 1 and 2," USNRC Document i
No. NUREG-0797, Supplement No.8, February, 1985.
}
9.2 " Seismic Design Classification", U.S. NRC Regulatory Guide 1.29, Revision 2, February 1976.
9.3 " Control of Seismic & Non-Seismic Component Interaction f-*
Evaluations", TUSI Instruction No. CP-EI-4.0-36, Revision 0, November 8, 1982.
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Page.41'of 58-p RESULTS REPORT'
- d. -
ISAP II.d (Cont'd)
9.0 REFERENCES
(Cont'd) 9.4 " Maintenance of Damage Study Analysis", TUSI Instruction No.,
CP-F.I-4.0-53, Revision 0, March 19, 1984.
9.5 Comanche Peak Response Team Program Plan'and Issue-Specific Action Plans, Revision 4, 6/18/87.
9.6 " Control Room Ceiling," G&H Procedure No. DP-3, Revision 1.
9.7 AISC Manual of Steal Construction, 7th Edition, 1969.
I 9.8 "CPRT Engineering Evaluation for the Control Room Ceiling".
Engineering Evaluation No. II.d.4b.1.
"TorsionklAnalysisofSteelMember,"AISCpublication,1983.
9.9 9.10 " Building. Code Requirements for Reinforced Concrete," American Concrete Institute Document No.:ACI-318-71, 1971.
.O} '
9.11 " Structural Embedment Specification", G&H Specification No.
k/~
SS-30, Revision 1.
i.
l-9.12 " Unit 1 Damage Study Analysis", procedure number TNE-DC-23, i
Revision 0, September 3, 1985.
9.13 " Resolution of ISAP II.d Open Issues," STIR-CPRT-S-008 Revision.0, 7/2/87.
9.14 " Systems Interaction Program," TUEC Engineering and Construction Procedure No. ECE 2.24, Revision 0, 7/21/87.
9.15 " Seismic /Non-Seismic Systems Interaction Program," CPE CPSES Design Basis Document No. DBD-ME-005, Revision 0, 2/10/87.
9.16 " Seismic /Nonseismic Walkdowns Systems Interaction Program Ebasco," TUEC Engineering CPSES Units 1 and 2 Field Verification Method No. CPE-EB-FVM-SI-40, Revision 0, 6/15/87.
9.17 " Evaluation of Seismic /Nonseismic Interactions," CPE Mechanical Engineering Technical Procedure No. EME 2.24-01, Revision 0, 7/21/87, 9.18 " Review of Architectural Specifications and Drawings to Identify Non-Seismic Sources," TUGC0 Instruction No.
CP-EI-4.0-63, Revision 0, 10/15/84.
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IS AP ' II'.d (Cont'd)
9.0 REFERENCES
(Cont'd) 9.19 " Review of. Architectural Specif1 cations and Drawings to.
Identify Non-Seismic Sources " TNE Procedure No. TNE-DC-26 Revision 0, 05/08/86.
9.20 " Seismic /Non-Seismic Interaction of Sheet Rock Walls,"
STIR-CPRT-S-006, Revision.0, 4/3/87.
9.21 " Doors ~and Security Barriers," STIR-CPRT S-007, Revision 0, 6/12/87.-
9.22 " Seismic /Non-Seismic Interaction of Floor' Gratings,"
STIR-CPRT-S-Oll, Revision 0, 6/12/87.
9.23 " Hand Rail Upgrade," STIR-CPRT-S-012, Revision 0, 4/30/87.
4 9.24 " Upgrade 'of Ladders, STIR-CPRT-S-016, Revision 0, 6/12/87.-
9.25 "CPRT Engineering Evaluation of Seismic Interaction Portions of the Damage Study Program" Engineering Evaluation No.
- 3. -
II.d.4b.2.
9.26L" Maintenance of Air Gap Between Concrete Structures", ISAP II.c.
- 9.27 " Comanche Peak Seismic Interaction Criteria Document", TUGC0 l
memo CPPA 27912, 2/18/83.
-i 9.28 "Non-Nuclear Pipe Hangers and Supports," G&H Specification No.
2323-MS-46B, Revision 3.
9.29 " Commodity Clearance," STIR-CPRT-S-018, Revision 0, 7/2/87.
9.30 " Commodities Attached to Secondary Walls," STIR-CPRT-S-009 Revision 0, 6/26/87.
I l
9.31 " Field Verification Method Commodity Clearance". Stone &
(.
Webster Engineering Corporation TU Electric Procedure No.
j; CPE-FVM-CS-068. Revision 0.
9.32 " Commodity Clearance", TU Electric Specification CPES-S-1021, Revision 0.
9.33 " Validation of Seismic Category II Large Bore Piping and
- n Support Designs", TU Electric Project Procedures No. CPPP-30, Revision 0.
1
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v RESULTS REPORT ISAP II.d (Cont'd).
9.0 REFERENCES
(Cont'd) 9.34 " Seismic Design of Control Room Ceiling,'_' STIR-CPRT-S-01N Revision 0, 6/26/87.
9.35 " Unit 2. Damage S tudy Analysis," TNE Procedure No. TNE-DC-9, Revision 1, 11/12/85.
4 9.36 " Gypsum Dry Wall," G&H specification 2323-AS-036, Revision 0, 2/4/76.
9.37'" Miscellaneous Metal," G&R specification 2323-AS-005, Revision 0, 11/21/75.
9.38 " Hollow Metal Doors:and Frames," G&H specification 2323-AS-018, Revision 0, 12/18/75.
9.39 " Finishing Hardware," G&H specificatica 2323-AS-022A, Revision 1 5/15/79.
9.40 " Rolling Steel Doors," G&H specification 2323-AS-025, Revision 0, 4/7/76.
9.41' " Watertight Doors," G&H specification 2323-AS-027, Revision 1, 6/13/78.
9.42 " Missile resisting Doors," G&B specification 2323-AS-054 Revision 1, 8/11/80.
9.43 " Bullet Resisting Doors and Penetration Resisting Doors," G6H specification 2323-AS-061,' Revision 0, 4/30/79.
9.44 " Design Basis Document Seismic Category I Structural Steel,"
DBD-CS-085, Revision 0, January, 1987.
9.45 " Metal Gratings," G6H specification 2323-AS-007, Revision 0.
2/18/76.
9.'46 " Metal Stairs, Railings, and Handrails," G6H specification 2323-AS-006, Revision 0, 2/12/76.
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1 Page 44 of 58 RESULTS REPORT ISAP II.d (Cont'd)
Figure 1 Original Control Room Ceiling Design (f
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.77 RESULTS REPORT
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.ISAP II.d (Cont'd) l Figure 2 Project ISAP Implementation Architectural Features -- Activities Reviewed by Third Party re:
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1 Paga 46 of 58
/~5 RESULTS REPORT r
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ISAP II.d i
i (Cont'd)
Figure 3 Project Activities Completed Prior to TRT i
and Reviewed by the Third Party appttCAkt Mi,lW Cet tftl
- 31. g h.
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- v RESULTS REPORT ISAP II.d (Cont'd)
Figure 4 Redesigned Control Room. Ceiling Frame
]
(Computer-Drawn Model) i
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Pags 48 of 58
.RESULTS REPORT
,-fs b)--
'(
1 ISAP II.d (Cont'd)
. Appendix 1 Glossary of Terms l
Architectural features-Any item specifically identified in an architectural specification or on.
an architectural drawing (specification containing an "AS" in the. number as in "2323-AS-5"; and drawings containing an'"A" in the number as in "2323-Al-0531").
CIA Comparative Interaction Assessment
.DIC-Dynamic Impact Criteria: a series of nine criteria.used by the DSG to resolve postulated interactions (see Reference 9.27).
The criteria were non-quantitative in nature and necessitated using engineering-judgment to apply.
DSG Damage Study Group DSP Damage Study Program; although the DSP encompasses other areas besides seismic interaction, when used in this report "DSP" refers only to those portions of the program that
(
involve seismic interaction.
It should be noted that the Damage Study Program has undergone a name change during the period of ISAP l
implementation (refer to Appendix f
2).
The new name is Systems Interaction Program.
In most cases, the report uses the earlier name.
However, in certain instances where the discussion is strictly applicable to the present program,
" Systems Interaction" is used instead of " Damage Study."
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RESULTS REPORT A
.'i ISAP II.d (Cont'd)
Appendix 1
.(Cont'd)
Interaction'.
Physical cont'ct.between a source a
'and a target which occurs as'a direct result of an SSE.: Damage to the functional capability'of the n
target (either structural or operational) is postulated as a consequence of this physical contact.
Seismic' Category I-Refera to comodities that aust
-remain functional during and following an'SSE'and co control room
. occupants. This list is discussed in NRC Regulatory Guide.1.29 and is committed to with nofexceptions in the CPSES FSAR (see FSAR Appendix 1A (B)).
O Seismic Category II Unique-designation for CPSES' defined in FSAR paragraph 3.2.1.2.
Refers to those commodities whose continued function is not required but whose failure could reduce the functioning of any 3eismic Category I commodity to an unacceptable level or could result in incapacitating injury to occupants of the control room.' These commodities are to be designed and constructed so that a SSE will not cause such failure.
SIP Systems Interaction Program (refer to definition of DSP)
Source Any physical commodity on the plant site that is not designated as Seismic Category I or Seismic Category II.
A source coaunodity might be " upgraded" to Seismic Category II so that it would no longer be a source.
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1 Page 50 of 58 RESULTS REPORT ISAP II.d I.
(Cont'd)'
Appendix 1 (Cont'd)
~ Safe-shutdova earthquake.
STIR Specific Technical Issue Report.
Target Any conunodity on the plant sice that is designated as Seismic' Category I; also, any occupants of-the control room.
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i ISAP II.d (Cont'd)l u
Appendix.2-l Chronology of events associated with the; Damage Study / Systems-
- Interaction program and implementation of ISAP II.d 1
11/8/82 Issuance of CP-EI-C.0-36, " Control of Seismic & Non-Seismic Coupon 6nt Interaction Evaluations" (Reference 9.3)
Seismic interaction program initiated on the basis of:this procedure. Procedure. addressed scope of program and how to identify and resolve potential interactions.
S.
.2/84 Implementation of CP-EI-4.0-36 completed (date approximate).
3/19/84 Issuance _of.CP-EI-4.0-53, "Maint'enance.of Damage Study LAnalyses" (Reference 9.4)
Procedure identified how to maintain the DSP that had been initiated based on CP-EI-4.0-36.
Generally, this provided for
- i O
ongoing walkdowns to identify any new potential interactions that might result from continuing construction activities.
9/18/84 NRC Meeting with TUEC Identified TRT concerns regarding the control room ceiling and requested review of the overall DSP.
10/5/84 Issuance of ISAP II.d, " Seismic Design of Control Room Ceiling Elements" to address issues. identified _during NRC meeting above.
j l
10/15/84 Issuance of CP-EI-4.0-63, " Review of Architectural
-l Specifications and Drawings to Identify Non-Seismic Sources" (Reference 9.18)
)
Architectural features review initiated in response to paragraph 4.1.3.1 of ISAP II.d.
Procedure provided method for identifying architectural features for subsequent evaluation by the Damage Study Group.
11/2/84 Implementation of CP-EI-4.0-63 and subsequent DSP walkdowns are completed.
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RESULTS REPORT
' I 1
ISAP II.d'
- (Cont'd)'
Appendix 2 (Cont'd) 8/20/85 Issuance of THE-DC-9. " Unit 2 Damage-Study Analysis" (Reference 9.35)'
i Consolidated and replaced DSP procedures CP-EI-4.0-36 and -S3 for Unit 2' efforts.
Issued as part of internal _ Project-reorganization.
~
9/3/85 Issuance of THE-DC-23, " Unit 1 Damage Study Analysis" (Reference'9.12)
Consolidated and replaced DSP. procedures CP-EI-4.0-36 and -53 for Unit:1 efforts.
Issued as part of internal Project reorganization.
5/8/86 Issuance of THE-DC-26,." Review of Architectural Specifications and Drawings to Identify Non-Seismic Sources" (Reference 9.19) l Project identifies concerns with implementation of
($g CP-EI-4.0-63.
Concerns were related primarily to completeness
(,,/
of review. Procedure revised to address these concerns and reissued as part of internal Project reorganization.
1 8/86 Ebasco takes over the DSP.
10/86 SWEC replaces G&H for civil / structural discipline.
10/20/86 Implementation of TNE-DC-26-and subsequent DSP walkdowns are completed.. Documentation of earlier commodity identification effort (per CP-EI-4.0-63) is retained.. As a result of the implementation of CP-EI-4.0-36 and TNE-DC-26, several groups of architectural feature commodities are identified as having-unacceptable potential interactions. Because all these commodities are within the scope of the civil / structural discipline, SWEC initiates program to address resolution of the various interactions (STIRa-006, -007, -011. -012, -016, and (to a limited extent)
-008).
i 10/22/86 " Damage Study Program" changed to " Systems Interaction I
Program" (name change only).
I 1
2/10/87 Issuance of DBD-ME-005**, " Design Basis Document, I
Seismic /Non-Seismic Systems Interaction Program" l
(Reference'9.15)
O Provides criteria and general methods for performing seismic interaction evaluations.
l
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Revision:
'l Page 53 of 58 L
/'~%[..
RESULTS REPORT-l; T j
_ISAP II.d (Cont'd) l Appendix 2 (Cont'd) 4/3/87 Issuance of STIR-CPRT-S-006, " Seismic /Non-Seismic Interaction of Sheet.Reck~ Walls" (Reference 9.20) -- refer to Appendix 3 for discussion of STIR.
4/30/87 Issuance of STIR-CPRT-S-012, " Handrail Rail Upgrade" (Reference 9.23) -- refer to Appendix 3 for discussion of STIR.
6/12/87 Issuance of STIR-CPRT-S-007, " Doors and Security Barriers" (Reference 9.21) -- refer to Appendix 3 for discussion of STIR.
6/12/87 Issuance of STIR-CPRT-S-Oll, " Seismic /Non-Seismic Interaction.
of Floor Gratings" (Reference 9.22) -- refer to Appendix 3 for discussion of STIR.
6/12/87 Issuance of STIR-CPRT-S-016 " Upgrade of Ladders" ~(Reference p-s 9.24) -- refer to Appendix 3 for discussion of STIR.
Al 6/15/87 Issuance of CPE-EB-FVM-SI-40**, " Field Verification Method, Seismic /Nonseismic Walkdowns Systems Interaction Program" (Reference 9.16)
Provides criteria and methods for performing walkdown portions of seismic interaction evaluations.
6/26/87 Issuance of STIR-CPRT-S-009, " Commodities Attached to Secondary Walls" (Reference 9.30)
' Addresses identification and resolution of interactions associated with secondary wall motions. Resulted from concerns identified during implementation of ISAP II.c,
" Maintenance of Air Gap Between Concrete Structures;" but addressed within the II.d Results Report because of potential effects of safety-related commodities due to the walls' seismic motions. Project implementation is ongoing and may result in hardware modification in some cases.
6/26/87 Issuance of STIR-CPRT-S-013. " Seismic Design of Control Room i
Ceiling" (Reference 9.34)
Addresses SWEC civil / structural review of G&H calculations for redesigned ceiling. Review is ongoing.
O U
i J
Op ! 9 4 QW R3 vision: '
1; Pagef54 of 58-L;r~vi RESULTS REPORT' l s_,
- I y
h ISAP II.d-3 (Cont'd)
Appendix 2, (Cont'd) 6/30/87 Issuance of STIR-CPRT-S-008, " Resolution of IS AP II.d' Open Issues" (Reference 9.13)-
Addresses resolutions of various third party concerns-
-identified during.ISAP II.d implementation (not related to architectural features). Also addresses resolutions of interactions involving commodities attached to'or above the.
control room ceiling. Various resolution 1 activities are ongoing; hardware modifications may be required but likelihood:
considered minimal-by the Project for connodities attached to
-or above the control room ceiling.
7/2/87 Issuance.of STIR-CPRT-S-018. " Commodity Clearance" (Reference 9.29)
Addresses identification and resolution of potential
' interactions associated with potentially insufficient clearance between commodities, one or both of which are safety-related. Based on concerns-identified by' third party
,^
during implementation of ISAPs II.c and II.d.. Implementation of the STIR is ongoing; hardware modifications may result.
7/21/87 Issuance of ECE 2.24**, " Systems Interaction Program" (Reference 9.14)
Identifies overall purpose of Systems Interaction Program including seismic interaction portion. Describes general methods for performing seismic interaction evaluations.
7/21/87 Issuance of EME-2.24-01**, " Evaluation of Seismic /Nonseismic Interactions" (Reference 9.17)
Presents methods for resolving identified seismic interactions, i
These four procedures consolidate applicable portions of TNE-DC-23 and -9 and include program changes in response to third party concerns noted during implementation of ISAP II.d (unrelated to architectural features effort). Procedures were issued as part of internal Project reorganization. The third party concerns are O
discussed in Sections 5.2.3, 5.2.4, and 5.2.5 of the body of this results report.
__m_m_2.1_.._._
a g ;%;t:
e:
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It 4
Page. 55 of 58 1
1
' py RESULTS REPORT u
ISAP.II.d 3
(Cont'd)'
.m Appendix'3
. Specific Technica1' Issue l Reports Issued to-s Address Resolution of Interactions, Identified.
. as a Result of the Proj ect's. ISAP. II.d Architectural Features Review
'Shoet Rock Walls.(STIR-CPRT-S-006) l l
This applies to specification.2323-AS-36 (Reference 9.36).
Numerous-f interactions were identified by the Damage Study Group (DSG). Except:
i for the sloped sheet rock above the-control room"(which was' removed,as' j
part of the control room ceiling redesign -- see discussion in 4.1.1 of~
H this results report), the project determined. that -it was unnecessary to remove or otherwise restrain sheet rock installations throughout the plant. This determination was made on the basis _of existing test data which demonstrated'that failure modes were limited to cracking and/or-minor spalling, popping:of a i wa11 board screws, and minor distortion of framing elements. Such ft.ures occurred at mid-span acceleration values in excess of~ design: values at CPSES. In addition, it was concluded that required inspection and maintenance programs would assure O
that any-sort of operating damage (e.g., moisture)-which might affect structural integrity would not go undetected.
Doors and Security Barriers (STIR-CPRT-S-007)
.This' applies to seven architectural feature specifications (References
-9.37 to 9.43).
Several interactions were identified by the DSG for the l
various. types of doors and security barriers. As a result, the project L
.has committed to assuring that all such commodities will remain in place during an SSE. This commitment will be satisfied initially by a review of the associated specifications and vendor documents to determine what load capacities have been used for design. These would then be compared with CPSES seismic loadings to determine if further analyses are i
required to assure structural integrity. Where analyses are performed (either with or without any hardware modifications), criteria used will be campatible with existing project criteria for Seismic Category I commodities (e.g., Reference 9.44).
DCAs will be issued as necessary for any hardware modifications. STIR implementation is ongoing.
Floor Gratinas (STIR-CPRT-S-Oll)
This applies to specifications 2323-AS-005 and -007 (References 9.37 and 9.45; note that -005 is a miscellaneous metal specification; only the portion of the specification dealing with checkered plate is addressed by this STIR). Numerous interactions were identified by the DSG. As a result, the project has committed to assuring that all such commodities O
will remain in place during an SSE. This commitment will be satistied j
L
Revision:
1 Paga 56 cf 58 RESULTS REPORT U
ISAP II.d (Cont'd)
Appendix 3 (Cont'd) initially by a review of drawings and performance of walkdowns to identify all gratings and checkered plates installed in Seismic Category I areas.
Calculations will then be performed to assure that,all commodities are consistent with existing project criteria for Seismic-Category I commodities (Reference 9.44).
DCAs will be issued as necessary for any hardware modifications. STIR implementation is ongoing.
I Handrails (STIR-CPRT-S-012)
This applies to specification 2323-AS-006 (Reference 9.46; note that
-006 also applies to stairs; only the portion of the. specification dealing with handrails is addressed by this STIR). Numerous
{
interactions were identified by the DSG. As a result, the project has comunitted to assuring that all such commodities will remain in place during an SSE. This commitment has been completed. The approach taken was to perform testing of certain configurations of handrails and handrail connections to assure that all handrails installed in Seismic Category I buildings at CPSES will remain in place during and after an e
i SSE. Test loads were developed to conservatively represent worst case SSE loads and also to address OSHA requirements. As a result of the testing, four actual handrail anchorages were modified to conform to tested configurations; all others were determined to be adequate. All
)
future installations will be designed / installed in conformance with one I
of the tested configurations thereby assuring structural adequacy.
Ladders (STIR-CPRT-S-016)
This applies to specification 2323-AS-005 (References 9.37; note that i
-005 is a miscellaneous metal specification; only the portion of the specification dealing with ladders is addressed by this STIR). Several interactions were identified by the DSG. As a result, the project has co W tted to assuring that these ladders will remain in place during an SSE. 'This effort is complete. The ladders were qualified in accordance with the seismic design requirements of Reference 9.44.
No hardware modifications resulted.
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