ML20236P657

Rev 0 to Project Status Rept, Cable Tray & Cable Tray Hangers, Corrective Action Program

ML20236P657
Person / Time
Site:	Comanche Peak
Issue date:	11/06/1987
From:	Alexandru R, Ashley G ABB IMPELL CORP. (FORMERLY IMPELL CORP.), EBASCO SERVICES, INC.
To:
Shared Package
ML20236P622	List: ML20236P657 TXX-6930, Forwards Rev 0 to Project Status Rept, Cable Tray & Cable Tray Hangers. Resolution of Issues Identified in Cable Tray & Cable Tray Hangers Generic Issues Rept, Contained in Apps a & B of Encl Rept
References
PROC-871106, TAC-R00280, TAC-R280, NUDOCS 8711180082
Download: ML20236P657 (182)

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COMANCHEPEAK  !

STE AM ELECTRIC STATION UNIT 1 and COMMON I

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CORRECTIVE ACTION PROGRAM O

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PROJECT STATUS REPORT ,

CABLE TRAY AND CABLE TRAY HANGERS  ;

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Generating Division ilA222888"80s8I4s PDR.

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' Revision 0 TU ELECTRIC' COMANCHE PEAK STEAM ELECTRI'C STATION UNIT 1 AND COMMON IMPELL CORPORATION 1 AND E8ASCO SERVICES INCORPORATED PROJECT STATUS REPORT-CABLE TRAY AND CABLE TRAY HANGERS 1 l l

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DM G.R. Athley/ .Q Impe11, Assistant Project' Manager l R.S. Alexandru Ebasco, Senior Supervising Engineer O

l TABLE OF CONTENTS I

l Section Title PJLeft EXECUTIVE

SUMMARY

iii ABBREVIATIONS AND ACRONYMS vi

1.0 INTRODUCTION

1-1 Figure 1-1 Cable Tray and Cable Tray Hanger Corrective-Action Program 2.0 PURPOSE 2-1 1

3.0 SCOPE 3-1.

i 4.0 SPECIFIC ISSUES 4-1 1

5.0 CORRECTIVE ACTION PROGRAM METHODOLOGY AND RESULTS ' 5-1 j 5.1 METHODOLOGY AND HORK PERFORMED 5-1 I 5.1.1 Licensing Commitments, Design Criteria

\M and Procedures 5-1 5.1.1.1 Verification of Design Criteria and Procedures- 5-2 5.1.1.2 Resolution of Cable Tray and Cable Tray Hanger Related Design Issues 5-6 5.1.2 Design Validation Process - 5-9 5.1.2.1 Validation of As-Built Attributes of Cable Trays and Cable Tray Hangers . 5-9

, 5.1.2.2 Analytical Methods for Design Validation l of Cable Trays and Cable Tray Hangers 5-10 5.1.2.3 Resolution of Design Validation Results 5-13 5.1.2.4 Final Reconciliation 5-13 l 5.1.3 Post-Construction Hardware Validation l Program (PCHVP) 5 5.2 RESULTS 5-20 5.2.1 Cable Tray Hanger Design Validation Results 5-20 5.2.2 Cable Tray Design Validation Results 5-20 5.2.3 Design Validation Packages 5-20 5.2.4 Post-Construction Hardware Validation Program (PCHVP)

Results 5-20 j 5.3 QUALITY ASSURANCE PROGRAM 5-20 fm 5.3.1 Summary of Impell and Ebasco Quality Assurance (QA) Audits '5-24 5.3.2

(*) Summary of Audits by TV Electric Technical Audit Program (TAP) and the NRC 5-25 i

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V Section Title Eagt 5.3.3 Engineering Functional Evaluation-(EFE) 5-25 5.4 CORRECTIVE AND PREVENTIVE ACTIONS 5-25 Figure 5-1 Typical Cable Tray Configuration Figure 5-2 Typical Tray Clamp Assemblies '

Figure 5-3 Cable Tray and Cable Tray Hanger Design Validation Process Figure 5-4 Cable Tray and Cable Tray Hangers Corrective Action j Program Technical Interfaces. j Figure 5-5 Post-Construction Hardware Validation Program (PCHVP)'

Table 5-1 Cable Tray and Cable Tray Hangers Governing Design -

Validation Procedures Table 5-2 Post-Construction Hardware Validation Program (PCHVP)-  ;

Cable Tray and Cable Tray Hanger Attribute Matrix -

Table 5-3 Summary of TU Electric- Technical Audit Program (TAP)

'O Audits

6.0 REFERENCES

6-1 LIST OF APPENDICES:

APPENDIX A: Comanche Peak Response Team and External Issues A-l' APPENDIX B: Issues Identified During the Performance of The Corrective Action Program B-1 O

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EXECUTIVE

SUMMARY

a This Project Status Report (PSR) summarizes the systematic validation process for safety-related cable trays and cable tray hangers implemented by Impel 1-Corporation (Impell) and Ebasco Services Incorporated (Ebasco) at Comanche Peak Steam Electric Station (CPSES) Unit.1-and Commoni. This Project Status Report (PSR); presents the results of the design validation and describes the Post Construction Hardware Validation Program (PCHVP). .Impell/Ebasco activities are governed by the TU Electric Corrective Action Program (CAP).

which required Impe11/Ebasco to:

1. . Establish'a consistent set of CPSES safety-related cable' tray and-cable tray hanger design criteria that complies with the CPSES licensing commitments.

2. Produce a set of' design control procedures that assures compliance with the design criteria.

3. Evaluate systems, structures, and components..and direct the corrective actions recommended by the Comanche' Peak Response Team i (CPRT) and those determined by Corrective Action Program (CAP) investigations to be necessary to demonstrate that~ systems, '

structures, and components ~are in conformance..with_the design. j

4. Assure that the validation resolves the cable tray and cable tray. i hangerrelateddesignandhardwareissuesigentifiedbythe. Comanche Peak Response Team (CPRT), external. sources , and the Corrective Action Program (CAP)..

ICommon refers to areas in CPSES that contain both Unit 1 and Unit 2 systems, structures and components.

2E xternal Issues are issues identified by the following: -i NRC Staff Special Review Team (SRT-NRC)

NRC Staff.Special Inspection Team (SIT) I NRC Staff Construction Appraisal Team (CAT)

Citizens Association for Sound Energy (CASE) l Atomic Safety and Licensing Board -(ASLB) '

NRC Region IV Inspection Reports' NRC Staff Technical Review Team (TRT).[SSERs 7-11]

CYGNA Independent Assessment Program (IAP)  !

Comanche Peak Response Team (CPRT) issues are. issues identified by the following:

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.CPRT Design Adequacy Program.(DAP)

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CPRT Quality of. Construction Program (QOC) iii  !

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5. Validatethatthedesignofsafety-related.cabletraysandcEble~

tray hangers is in conformance with the licensing commitments and that the installed hardware is in conformance with the validated.

design.

6. Produce a set of consistent and validated design documentation.

A consistent set.of design criteria for CPSES safety-related cable trays and cable tray hangers has been developed and used by Impe11/Ebasco for the design validation process. This set of design criteria is in conformance with the CPSES' licensing commitments. It has been' independently and extensively reviewed and was accepted by the Comanche Peak Response Team (CPRT). To' provide added assurance of the conservatism of the analytical: methods, design criteria and of ths design adequacy of the cable tray and cable tray hangers, numerous engineering studies were performed and a comprehensive testing program was conducted.

Impell/Ebasco established design control procedures to implement the design criteria and methodologies above, and to govern the work flow and technical interfaces with other disciplines for both the design and hardware validation.

processes. These procedures specify the processes (such as, the validation of cable tray and cable tray hanger input, cable tray and cable tray hanger checklists, documentation control, and final reconciliation) which have been implemented throughout the safety-related cable tray and' cable tray hanger Corrective Action Program.(CAP).

Impell/Ebascohasperformedanalysestovalidatethedesignoffas-built'CPSES cable trays and cable tray hangers. The results are documented in

>approximately:5549 Design. Validation Packages (DVPs) that contain approximately 7566 cable tray hangers. The as-built hardware for safety-related cable trays and cable tray hangers is being validated to the-design by the Post-Construction Hardware Validation Program (PCHVP).

Methodologies have been incorporated into'the Impell/Ebasco design. criteria and the Post-Construction Hardware Validation Program (PCHVP) implementation procedures which have resolved the cable tray and cable tray hanger related l design and hardware issues identified by the Comanche Peak Response Team (CPRT), external sources, and the Corrective Action Program (CAP).

Consequently, the validated design of the CPSES safety-related cable trays and cable tray hangers has resolved these cable tray and cable tray hanger ~related' issues.

The Post-Construction Hardware Validation Program (PCHVP)' assures'that the safety-related cable trays and cable tray hangers are installed in conformance with the validated design. Impell/Ebasco has-reviewed:and revised the CPSES cable tray and cable tray hanger related installation specifications, construction procedures, and quality control inspection procedures to assure-that the validated design requirements are implemented. -The'PCHVP for safety-related cable trays and cable tray hangers, including the reinspection, 1

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engineering walkdowns and evaluations, implements the corrective actions recommended by the Comanche Peak Response Team (CPRT), as well as those i required by the Corrective Action Program (CAP) investigations.

Impell/Ebasco will provide to TU Electric a complete-set of validated design documentation for CPSES safety-related cable trays and cable tray hangers, including the cable tray and cable tray hanger calculations, drawings, design changes, inter-discipline transmittals, and hardware modifications.3 This-documentation can provide the basis for CPSES configuration.contro1 to, facilitate maintenance and operation throughout the life of the plant.

l In-depth quality and technical audits performed by Impe11; Quality Assurance  !

and Ebasco Quality Assurance, TU Electric Quality Assurance, and the- H l independent Engineering Functional Evaluations (EFE) verified that .

j l implementation of the validation program was in conformance with 10CFR50, 1 Appendix B quality assurance requirements. In addition, the third party l overview performed by TENERA,'L.P. (TERA) for the Comanche Peak ResponseLTeam-  ;

(CPRT) verified that .the Impell/Ebasco design criteria complied with the i licensing commitments.

The Unit 1 and Common safety-related cable tray and cable tray. hangers Corrective Action Program (CAP) validates:

1 The design of the cable trays and cable tray hangers comply with the  !

CPSES licensing commitments.

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• The as-built-safety-related cable trays and-cable tray hangers comply with the validated design. ,

• I' The cable trays and cable tray hangers comply with the CPSES licensing commitments and will perform their safety-related ,

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i 3Cconfiguration control is a system to assure that the design and hardware remain in compliance with the licensing commitments throughout the life of ,

the plant.

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ABBREVIATIONS AND' ACRONYMS j

AISC Americtn Institute'of Steel Construction AISI American Iron & Steel Institute ANCO ANCO Engineers, Inc.

ANI Authorized Nuclear Inspector-ANSI American National Standards Institute ARS Amplified Response Spectra ASLB Atomic. Safety and Licensing Board ASME American Society of Mechanical Engineers CAP Corrective Action Program CAR Corrective Action Request. '

CASE Citizens Association for Sound Energy CAT Construction Assessment Team (NRC Staff)

CCL Corporate Consulting &; Development Company,.Ltd.c. l CFR Code of Federal Regulations. 3 I CMC Component Modification Card '

CPE Comanche Peak Engineering (TV Electric)

CPRT Comanche Peak Response Team (TU Electric) ,

CPSES Comanche Peak Steam Electric Station l CYGNA CYGNA Energy Services ..

DAP Design Adequacy Program (CPRT)- '

DSCP Design, Basis Consolidation' Program' DBD Design Basis Document DCA- Design Change Authorization DIR Discrepancy Issue Report (CPRT-DAP)

DR Deviation Report DSAP Discipline Specific Action Plan'-(CPRT)

DVP Design Validation Package.

EBASCO Ebasco Services Incorporated ,

EFE Engineering Functional Evaluation. ,

ERC Engineering Research Corporation ESM Equivalent State Method ETR Ebasco Topical. Report FSAR Final Safety' Analysis Report FVH Field Verification Method GIR Generic Issues Report IA Inaccessible Attribute IAP Independent Assessment Program (CYGNA)

IMPELL Impell Corporation IRR Issue Resolution Report (CPRT)

ISAP Issue Specific Action Plan (CPRT)

HRH Multimode Response. Multiplier NCR Nonconformance: Report l NOV Notice'of Violation'(NRC) l NRC United States Nuclear Regulatory Commission l NRR Office of Nuclear Reactor Regulation ~(NRC)'

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NUREG NRC' Document. .

NUREG/CR- NRC Document developed by.an NRC Contractor OBE . Operating Basis Earthquake PCHVP Post-Construction' Hardware Validation Program PSR Project Status Report

- QA Quality Assurance .

c 00C Quality.of Construction and QA/QC Adequacy Program.(CPRT) J QC Quality Control .

RSM Response. Spectra' Method-

.RIL Review Issues. List (CYGNA)'. ,. .

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'SDAR Significantl Deficiency Analysis Report (TU Electric)

SER ' Safety Evaluation' Report (NRC, NUREG-0797)'.

SIT Special. Inspection Team-(NRC Staff)-

SRP Standard Review Plan (NRC, NUREG-0800):

SRT Senior Review Team (CPRT)

SRT-NRC .Special Review Team (NRC).

.SRSS Square Root.of the Sum of the Squares SSE . Safe Shutdown Earthquake:

SSER Supplemental Safety Evaluation Report.(NRC; NUREG-0797)

SHEC Stone & Hebster Engineering Corporation SHEC-PSAS Stone & Hebster Engineering Corporation - Pipe Stress and Support Project (SHEC)

TAP' Technical Audit Program (TU Electric)

TERA TENERA, L. P. ..

TRT . Technical Review Team (NRC Staff, SSERs.7-11)-

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1.0 INTRODUCTION

In October 1984, TU Electric established the Comanche Peak Response Team- ,

(CPRT) to evaluate. issues that have been. raised-at CPSES and to prepare a plan

.for resolving those issues. ;The CPRT program plan was developed and~ submitted

.to the NRC.

< In mid-1986 TU Electric performed a qualitative and quantitative. review'of the preliminary results of the Comanche Peak Response Team (CPRT) (References .

59 and 64). -This review . identified that thel Comanche Peak Response Team (CPRT) findings were very broad in scope'and included:eachidiscipline. TU Electric decided that the appropriate. method-to correct'the issues raised and.

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to identify and correct any other. issues that potentially existed at CPSES 3

l would be through one integrated program rather.than a separate program for l each issue. TU Electric decided to initiate a comprehensive Corrective Action: -

1 Program (CAP) to validate'the entirety of CPSES safety-related designsl.: Z.  ;

The scope of the CAP has the following objectives:  :

Demonstrate that the design of safety-related systems, structures and components complies with licensing commitments.

Demonstrate that the existing systems, structures and components are-in compliance with the design-or develop modifications.which:will bring systems, structures and components.into compliance with design. l O

• Develop procedures, an organizational plan, and documentation to-maintain compliance with licensing. commitments throughout.the life of i' CPSES. ,

The Corrective Action Program (CAP) is thus a comprehensive program to validate both the design and the hardware at CPSES. including resolution of specific Comanche Peak Response Team (CPRT) and external issues. .,

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I Portions of selected non-safety-related systems, structures and components are included in the Corrective Action Program (CAP). These are Seismic.

Category II systems, structures and components, and Fire Protection Systems.

2 NSSS design and vendor hardware design and their respective QA/QC . .. .. ,

programs are reviewed by the NRC independently of CPSES and are not included. -l in the Corrective Action Program (CAP) as noted in SSER 13; however, the design interface is validated'by the CAP.

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A Cl TU Electric contracted and provided overall management-to Stone & Hebster Engineering Corporation (SHEC), Ebasco Services Incorporated (Ebasco), and Impell Corporation (Impell) to implement the Corrective Action Program (CAP),

and divided the CAP into eleven disciplines as follows:

Discioline Responsible Contractor Hechanical SHEC'

- Systems Interaction Ebasco Fire Protection Impell ,

Civil / Structural SHEC.

Electrical SHEC Instrumentation & Control. SHEC Large Bore Piping and Pipe Supports SHEC-PSAS Cable Tray and Cable Tray Hangers Ebasco/Impe11 Conduit Supports Trains A, B, & C > 2" Ebasco Conduit Supports Train C 1 2" Impell Small Bore Piping and Pipe Supports SHEC-PSAS HVAC Ebasco Equipment Qualification Impell-A Design Basis Consolidation Program (DBCP) was developed to define the methodology by which Impe11 and Ebasco performed the design and hardware validation. The approach of these DBCPs is consistent with ccher contractors' efforts.and products.

The design validation portion of the Corrective Action Program (CAP) identified the design-related licensing commitments. The design criteria' were developed from the licensing commitments and consolidated in the Design Basis Documents (DBDs). The DBDs identify the' design criteria for the design validation effort. If the existing design did not satisfy the design criteria, it was modified to satisfy the criteria. The design validation l effort for each of the eleven Corrective Action Program (CAP) disciplines was documented in Design Validation Packages (DVPs). The DVPs provide the documented assurance (e.g., calculations and drawings) that the validated .

design meets the licensing commitments, including resolution of all Comanche Peak Response Team (CPRT) and external issues.

The design validation effort revised the installation specifications to reflect the validated design requirements. The validated installation specifications also contain the inspection requirements necessary to assure that the as-built hardware complies with the validated design.

The hardware validation portion of the Corrective Action Program (CAP) was implemented by the Post-Construction Hardware Validation Program (PCHVP),

I which demonstrates that existing systems, structures, and components are in I compliance with the installation specifications (validated' design), or l identifies modifications that are necessary to bring the hardware into l compliance with the validated design.

1-2 L___________--____m_-_________________-___m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ . - . _ _ _ . . _ _ _ - _ _ _ _ _ _ _._______.-_--_________a_.-m_.

OI The results of the performance'of the Corrective Action Program (CAP) for each I discipline are described in a Project Status Report (PSR). This PSR describes  ;

the results for the cable tray and cable. tray hanger CAP. l

.Impe11/Ebasco have performed a comprehensive validation of safety-related  !

cable trays and cable tray hangers for CPSES in order to demonstrate that the l l .as-built design complies with licensing commitments. Impell/Ebasco were initially contracted by TU Electric in 1985 to validate cable tray and cable i

tray hangers at CPSES. When the Corrective Action Program (CAP) was created in 1986, it incorporated and expanded upon Impell/Ebasco's existing program.

The validation process was ' conducted in accordance with the Impell and Ebasco Design Basis Consolidation Programs (DBCP) (References 43 and 44), which . 'I control implementation of the cable. tray and cable. tray hanger portion of. the TV Electric Corrective Action Program (CAP). The cable tray and cable tray hanger Corrective Action Program (CAP) encompassed the Comanche Peak Response i Team - Discipline Specific Action Plan VIII (CPRT - DSAP VIII) (Reference 8).

The cable tray and cable tray hanger Corrective Action Program (CAP) is shown schematically in Figure 1-1. The design bases of the CAP are contained within the CPSES Design Basis Document (DBD) (Reference 42) for safety-related cable' trays and cable tray hangers.  !

Validation of the CPSES cable trays and cable tray hangers was accomplished by-complete cable tray and cable tray hanger analysis, and design and implementation of required field modifications. The results of and the methodology used in' implementing both the design and hardware-related s validations for Unit i and Comnen cable trays and cable tray hangers are presented in this Project Status Report (PSR).

This cable tray and cable tray hanger Project Status Report (PSR) describes the validation effort from the early stages of design criteria establishment -

through the development and implementation of the detailed design and design control procedures. The report' traces the updating of design / installation specifications and construction /QC procedures, the implementation of the Post-Construction Hardware Validation Program (PCHVP) to validate the as-built cable tray and cable tray hanger design, and the completion of the Unit 1 and l Common analysis packages.

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FIGURE:1 CABLE TRAY.AND. CABLE TRAY HANGER CORRECTIVE ACTION PROGRAM.

~ IDENTIFY LICENSING FSAR COWITnENTS OTER LICENSING OOCUMENTS U

DEVELOP OESIGN BASIS DOCUMENTS (080s)-

U PERFORM OESIGN CPRT (OAP a' OOC)

-VALIDATION  : EXTERNAL' ISSUES

- NRC (SRT. SIT, TRT, CAT)

- CYONA (1AP) p CASE

- ASLS~

- MtC INSPECTION REPORTS WODIF ATION  : DESIGN REQUIRED MODIFICATIONS

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l t POST CONSTRUCTION HARDWARE VALIDATION c 0 PROGRAM (PCHVP).

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FINAL DESIGN RECONCILIATION

.I I f IS YES ADDITIONAL VALIDATION REQUIRED  ;

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FINAL DOCUMENTATION (CESIGN VALIDATION PACKAGES) l ___ - __- --_- Q

I 2.0 PURPOSE The purpose of this Project Status Report (PSR) is to demonstrate that the safety-related cable trays and cable tray hangers in Unit I and Common are in conformance with the.CPSES licensing. commitments', satisfy design criteria, and' will satisfactorily perform their safety-related functions.

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, A V 3.0 SCOPE l The scope of the Corrective Action Program (CAP) implemented for CPSES l

Unit 1 and Common cable trays and cable tray hangers includes both Seismic Category Il and Seismic Category II2 cable tray systems 3 The CAP, as implemented for Unit 1 cable trays and cable tray hangers in Unit 1 and Common, does not distinguish between the functional and design requirements related to the Seismic Category of the cable tray system, but rather has validated the design of both Category I and Category II Unit 1 cable tray systems using the more stringent Category I requirements. Unit 2 cable tray systems in the Common have been validated such that their failure presents no adverse effects on the Seismic Category I systems, structures, and components required for Unit 1 operation. Subsequently, throughout this Project Status Report (PSR), the term safety-related cable trays and cable tray hangers refers to both Seismic Category I and II Unit 1 cable tray systems in Unit 1 and Common.

The cable tray and cable tray hanger Corrective Action Program (CAP) contains a design validation portion and a hardware validation portion to assure that the design documentation corresponds to the as-built hardware. This Project Status Report (PSR) includes all of the features of the CAP as implemented by Impe11 for the Unit 1 Reactor and Safeguards Buildings and by Ebasco for the remainder of Unit 1 and Common Areas. The primary features of the Corrective Action Program (CAP) are:

i 1. Establishment of cable tray and cable tray hanger design criteria

! which comply with licensing commitments.

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2. Development of the Design Basis Document (DBD) for CPSES cable trays and cable tray hangers, which contains the design criteria. This Design Basis Document (DBD) provides the basis for corrective and preventive actions throughout the life of the plant. This document also identifies the updated installation specifications, QC/ Construction procedures, and detailed design and design control procedures used in the validation process.

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Structures, systems, and components that are designed and constructed to l

withstand the effects of the Safe Shutdown Earthquake (SSE) and remain functional are designated as Seismic Category I in accordance with the requirements of NRC Regulatory Guide 1.29 (Reference 45).

2 Those portions of structures, systems, or components whose continued l function is not required but whose failure could reduce the functioning of i

) any Seismic Category I system or component required to satisfy the {

l requirements of Regulatory Guide 1.29 to an unacceptable safety level or j could result in incapacitating injury to occupants of' the control room are i designated Seismic Category II, and are designed and constructed so that the ;

p SSE would not cause such failure. l 3

A cable tray system is defined as an assemblage of cable trays, cable tray hangers, and related cable tray components (such as cable tray clamps, splices and fittings).

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3. Implementation of' design and hardware validationsbconsisting of

. analysis', identification andiimplementation of necessary; modifications ~, and field.verificationsLas identified:in the, .

Post-Construction Hardware Validation' Program (PCHVP). : The as-built j

' design'of cable trays and. cable' tray hangers isivalidated by'  ;

. inspections... reinspection, engineering walkdowns; and evaluations.. 1 Analysis results,; including the identification ofinecessary 1 modifications, are documented in' cable tray and cable tray hanger; i Design Validation, Packages'(DVPs).

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4. . Resolution' of the design'and hardware-related issues of CPSESicableS q trays'and cable' tray hangers'and implementation of,a corrective-  ?

' action plan;for closure of:these issues. These issues include :

external: issues, Comanche Peak Response Team'(CPRT); issues, and l issues. identified during the performance of the' Corrective Action-

Program (CAP).(See Section'4.0). ,

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5. The. validated design documentation' formsc the basis for configuration

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control of CPSES' cable. trays and cable tray hangers. - The validated )

design documentation 'and'updatediprocedures/ specifications lwill' be y provided to TU. Electric:to facilitate operation,' maintenance,land '

a future modifications following issuance.of an' operating' license.

Within Section 5.1; Section 5.1.1Ldescribes'the_ methodology by which the CPSES-licensing commitments were identified, the design criteria were established and the procedures were developed. These: technical and design control-O' procedures, in conjunction with the CPSES quality assurance procedures and design and installation specifications that were updated to meet the u

L corrective actions for cable' trays and cable tray hangers are consolidated in-the CPSES Design Basis Document-(DBD).  !

Section 5.1'.2 describes the design validation process, including the-calculation input / output reviews and interface requirements with'other d

disciplines.

Section 5.1.3 describes the Post-Construction Hardware Validation Program (PCHVP) process and the procedures for field verifications (inspections, l;

reinspection, engineering walkdowns and evaluations) implemented to validate i that the as-built cable trays and cable tray hangers are in compliance with  !

the design documentation. ~

j Section 5.2 presents a summary of the design validation and Post-Construction  ;

Hardware Validation Program (PCHVP) results, including the hardware i modifications resulting from the' Corrective Action Program (CAP).. .!

Section 5.3 describes the' quality assurance program implemented for'the validation process.

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l (R) Section 5.4 describes the transfer of a complete set of the validated design documentation and technical and desi'gn control procedures to TU Electric Comanche Peak Engineering (CPE). This documentation can provide the basis for CPSES configuration control throughout the life of the plant. Within the boundary of Unit 1 and Common, a11.7566 cable tray hangers and their attached trays have been validated.

Appendix A describes the details of Corrective Action Program (CAP) resolutions of the Comanche Peak Response Team (CPRT) and external issues. i Appendix B describes the details of resolutions of issues identified before I and during the cable tray and cable tray hangers Corrective Action Program i (CAP). These issues are Significant Deficiency Analysis Reports (SDARs) i (10CFR50.55(e)) initiated by TV Electric.

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4.0 SPECIFIC ISSUES The cable tray.and ca'ble tray hanger Corrective Action Program (CAP)Lresolved all of the related Comanche Peak Response. Team.(CPRT) issues, external? issues and issues identified by the CAP.. .This section presents a listing of'all' cable tray and cable tray hanger related issues addressed in this ProjectE Status Report (PSR). Technical review, resolution, corrective and preventive actions for all external and Comanche Peak Response Team (CPRT) issues c.re described in Appendix A. Technical review, resolution, and corrective.and-preventive action taken for issues identified before'and during implementation of the Corrective Action Program (CAP) are described in Appendix B.'

Comanche Peak Response Team (CPRT) and external. issues are identified in the Cable Tray and Cable Tray Hangers Generic Issues Report (GIR) (Reference.20).

This Generic Issues Report (GIR).has been transmitted to the NRC,' CASE, CYGNA,  :

and is incorporated in Subappendices Al through A31 of this report. The

j. Comanche Peak Response Team (CPRT) contracted TENERA, L'.P.=(TERA).to perform the third party overview (Reference 59) for the completeness and adequacy of these issues / resolutions, and the overview of corrective action implemented.by Impell/Ebasco to resolve these issues. The results of these Third Party _

overviews are presented by TERA in the Discipline Specific' Action Plan Results Report (DSAP-VIII) (Reference 48).

Comanche Peak Response Team (CPRT) and external issues are' listed below (issue number corresponds to subappendix number in Appendix A).

Issue No. Issue Title Al Controlling Load Case for Design A2 Seismic Response Combination Method A3 Anchor Bolt Design A4 Design of Compression Members A5 Vertical and Transverse Loading on Longitudinal Type Supports A6 Support Frame Dead and Inertial Loads A7 Design of Angle Braces Neglecting Loading Eccentricity A8 Dynamic Amplification Factors (DAF) Tributary Tray Support Reactions and Missing Mass Effects A9 Reduction in_ Channel Section Properties Due to Clamp Bolt Holes A10 System Concept All Validity of NASTRAN Models A12 Horking Point Deviation Study A13 Reduced Spectral Accelerations A14 Non-Conformance with AISC Specifications A15 Member Substitution 1 A16 Held Design and Specifications  !

A17 Embedded Plate Design 1 A18 Tray Clamps l A19 FSAR Load Combinations j i

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i A20 Differences Between Installation and Design / Construction Drawings '

Nithout Appropriate Documentation A21. . Design Control A22 . Design.of Support No. 3136 Detail."5",

Drawing 2323-S-0905 '

A23- Loading in STRESS Models A24 Design of Flexural Members A25 Cable Tray Qualification A26 Base Angle Design A27 Support Qualification by Similarity ._

A28 . Critical Support Configurations and Loadings <

A29 Cumulative Effect of Review Issues.

A30 Cable Tray System-Damping Values

-A31 Modeling of Boundary Conditions l A32 Conduits Attached to Cable Trays or Supports A33 As-Built Halkdown Procedures A34' System Analysis Methodologies A35 Failure to properly inspect. cable tray hangers (NRC NOV 50-445/8416-V-01).-

Issues identified before and during implementation of the Corrective ' Action .

Program (CAP) are listed below (issue number corresponds to subappendix number in Appendix B):

Issue No. Issue Title B1 SDAR-CP-83 Bolting material _ for cable tray hanger clamps.

B2 SDAR-CP-85 Cable tray hanger design.

83 SDAR-CP-85 Cable tray Tee fittings. .

B4 SDAR-CP-85 Cable tray hanger reverification program. i B5 SDAR-CP-86 Cable tray splices / connections.-

B6 SDAR-CP-86 Cable tray hanger splice _ welds.

B7 SDAR-CP-87 Cable tray transverse clamps.

B8 SDAR-CP-87 Improper application of construction aids.

B9 SDAR-CP-87-76'- Field drilled cable tray holes.

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D 5.0 CORRECTIVE ACTION PROGRAM METHODOLOGY AND RESULTS I

This section of the Project Status Report (PSR) addresses the program methodology for the Corrective Action Program (CAP), including the establishment of design criteria in conformance with CPSES licensina  ;

commitments, the development of procedures, the implementation of the design  !

validation process and the Post-Construction Hardware Validation Program i (PCHVP), as well as the results of the CAP and corrective and preventive .

]

actions implemented to assure that the hardware remains in-compliance with the l licensing commitments throughout the life of the plant. ]

5.1 METHODOLOGY AND HORK PERFORMED The methodology and work performed by Ebasco and Impell in implementing the Corrective Action Program (CAP) for cable trays and cable tray hangers are.

discussed in the following sections.

5.1.1 Licensing Commitments, Design Criteria and Procedures l 1

The licensing commitments for the cable trays and cable tray hangers were identified by Impell/Ebasco through an extensive review of CPSES licensing i documentation (such as the FSAR (Reference 17), NRC Regulatory Guides, NRC 1 Inspection and Enforcement Bulletins, the AISC " Specification for the Design of Steel Structures" (Reference 9), and NRC/TU Electric correspondence.)

p Based on these licensing commitments, design criteria were established which d set forth requirements for validation of cable trays and cable tray hangers.

The design criteria are documented in the Design Basis Document (DBD). . Impell and Ebasco then developed design procedures (See Table 5-1) which include the following:

Design criteria Resolution of Comanche Peak Response Team (CPRT) and external issues Impell/Ebasco experience gained through the design of cable trays and cable tray hangers for several United States nuclear power plants Regulatory and Professional Society Guidance such as applicable codes and standards In addition, all cable tray and cable tray hanger related Significant Deficiency Analysis Reports (SDARs), identified in Appendix B, and Corrective Action Reports (CARS) were reviewed and all technical issues identified. The resolution of these technical issues was included in the procedures.

The results of extensive state-of-the-art testing and engineering studies (detailed analytical evaluations) were implemented in the procedures used in the cable tray and cable tray hanger design validation. For example, dynamic testing of full-scale cable tray systems, extensively instrumented to measure acceleration and displacement response, provided additional confirmation of the adequacy of the design validation methods required by the procedures. The 3

(V 5-1

test results provided a clear. confirmation' of cable tray system response and - :1 confirmed the values of. design input (e.g. damping) specified in the .. 1 1

procedures. Additional tests' demonstrated the ability of the cable tray systems to perform under seismic loading significantly higher than the CPSES design criteria. During testing, many of the cable tray test-specimens-sustained more than one hour of cumulative seismic load with no loss of

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' i function. '

5.11.'1

.' Verification of Design Criteria and Procedures To. provide added confidence of the conservatism of the analytical methods and  !

design criteria as. defined in the procedures and.of.the' design . adequacy of the. )

cable tray and cable tray. hangers, numerous. engineering studies.were performed, and a comprehensive testing program was conducted. .The engineering-studies were performed to develop and substantiate the methodology defined,in the cable. tray and cable tray hanger-design validation procedures.

Enaineerina Studies Numerous engineering studies were performed by Impe11/Ebasco during.the.

development of the cable tray and cable' tray hanger design' validation-procedures and throughout the design validation process. The primary objectives of these engineering studies were:

1. To establish and document the basis of design criteria;

2. To provide the basis, through detailed analytical evaluations, for engineering assumptions and technical methods;

3. To resolve, through detailed analytical evaluations, specific Comanche Peak Response Team (CPRT) issues, external issues, and issues identified by the cable tray and cable tray' hanger Corrective Action Program (CAP); and

4. To evaluate cable tray and cable tray hanger design validation results to provide added confidence of the conservatism of the analytical methods and design criteria as defined in the procedures. .

Testina Proaram The primary objectives of the testing program were:

1. To provide, through correlation with dynamic and static testing of-full-scale cable tray systems and. individual components, additional i confidence that the linear elastic methods used by Impe11/Ebasco y conservatively predict cable tray system dynamic response; j

2. To provide qualitative and quantitative data on the seismic l behavior '!

and seismic capacity of the cable tray systems when subjected to- .j earthquake excitation levels well above the CPSES design criteria;; and-O  !

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3. ToestablishloadcapacitiEsforcable.traycomponentsforwhich manufacturer's load capacity data was not available and traditional

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analytical methods were inappropriate. : Cable tray component testing ..

included straight cable trays, cable tray fittings, and cable tray clamps.

The cable tray system dynamic tests'and the cable' tray component tests were.

performed on full-scale systems and: components representative.of as-built' configurations. For all' testing-programs, a Corrective Action Program;(CAP)L engineer was present at.the testing facility to oversee and witness the tests. The test results were: fully. reviewed and accepted by Impe11/Ebasco.

Cable Trav System Dynamic Tests ' "

A total .of six-(6) different test specimens representative of the cable tray-hanger systems' installed at CPSES were subjected'to various types of. dynamic.

tests at the ANCO Engineers, Inc. testing laboratory.(Reference 25). These'-

tests represent various configurations of tray hangers, sizes of cable trays; types of tray clamps, and levels of cable fill-(i.e. weight of_ cable in thel tray) which were tested in various combinations ~of tray runs andisupport boundary conditions. In addition, some of the' test: specimens included various discrepancies identified during as-built inspections'such as:. oversized. bolt holes, unused bolt holes, reduced minimum edge distances, gaps between tray and clamps, and undersized welds between clamps and tiers.-

The main objectives of the tests were as follows:

a. Demonstrate that 4% of critical damping for Operating Basis Earthquake (0BE) events and 7% of critical damping'for Safe Shutdown Earthquake (SSE) events are appropriate; and

b. Provide test data to be used for correlation with analytically predicted values.

The tests also provided additional technical data regarding:

a. The tray / clamp slip behavior under the effects of postulated seismic events;

b. Cable tray system behavior when subjected to a design life of five (5) OBE events and one (1) SSE event,

c. Seismic effects on tray hangers having slender. post members

d. The ability of the cable tray systems to maintain integrity at seismic levels in excess of the CPSES design criteria; and' .i

e. The ability of the cable tray system to maintain its design function even with as-built conditions such as oversize bolt holes and reduced minimum edge distances as previously discussed.

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The. dynamic tests were conducted by ANCO Engineers, Inc. in accordance with- .l' requirements specified in References 11, 23 and 24 which include. requirements' for test specimen set-up, installation of instrumentation, test procedures, y and collection of data.

Cable' Tray System Dynamic Test Results 1 1

The full scale cable tray tests'provided meaningful data for the design validation of the cable trays and cable tray hangers at CPSES.... The majority of the test configurations were subjected .to a variety.of tests which, in

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total, exceeded an hour of. dynamic. loading.

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It was determined for.each test configuration (Reference'25)' that the damping .

i values used in design validation are conservative. .

The cable tray clamps showed no significant slip' and lost none of their '

displacement resistance or: load carrying capacity at the'0BE and SSE excitation levels. No damage resulting.in loss of design function occurred until load levels far in excess of the SSE were achieved. The tests clearly.

demonstrated that the cable tray systems at CPSES are capable of withstanding seismic motion greatly in excess of CPSES design criteria without loss of function.

The testing of as-built conditions, such as gaps between. tray and clamps and 4 oversize bolt holes as previously discussed, has demonstrated that these conditions have negligible effect on cable tray system seismic response.

Test results are contained in References 25 through'31.

Correlation of Analysis with Dynamic Test Results The dynamic tests of the cable tray systems provided measured response data which were used by Impell/Ebasco for correlation with analytically predicted system response. This correlation was used to provide additional: confidence-in the Impell/Ebasco analytical modeling and. seismic response prediction techniques which were applied in the design validation at CPSES. The' summary of the results of this correlation is presented in Reference 7. j Impell and Ebasco concluded the following from the correlation of analysis i with test results: l

1. The cable tray system behavior, when subjected to. seismic loadings, is predictable. In particular, the friction type: clamps exhibit i linear (non-slip) behavioriunder seismic loads. The analysis methods.

t- used for design validation conservatively predict _the dynamic; characteristics of the systems;  ;

2. The analysis procedures substantially overpredict actual measured i response when the strcctural damping-is assumed to be 4% and 7%'for.

the OBE and SSE' design earthquake respectively. The damping values of 4% and 7% are the licensing commitments at CPSES; and ,

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The effective cable tray system damping is 7-15% for OBE motions and L' 3.

10-20%.for SSE motions indicating that the criteria implemented for design validation ~(4% OBE and 7% SSE) is conservative.

Cable Trav and Cable Trav Fittina Static Tests Cable trays, as shown in Figure 5-1, are fabricated from cold-formed steel and consist of two side rails with either a series of rungs or sheet. metal between the side rails. The flanges on the side rails always face inwards and the.

sheet metal of the solid bottom trays or the rungs of ladder type trays are welded to the side rail bottom flange. The height of side rails-and the width i of the trays essentially define the size of cable trays (e.g. 4x24 inches). 1 The trays used are either 4 inches or 6 inches.in height with their width varying from 6 to 36 inches. . The thickness (gauge) of side rails and rungs varies with the size of the tray.

The purpose of the cable tray component tests was to establish' load capacities and determine the stiffness of cable tray components. For these componer,ts, it is appropriate to conduct tests .in the vertical and transverse directions to obtain load capacities and to derive equivalent inertial'section properties (area moment of inertia) from load / deflection curves. The load-carrying capacities of the cable trays in the longitudinal direction are calculated on i the basis of the AISI specification (Reference 33). Original tests on cable  :

trays were performed by the cable tray suppliers (Reference 32 and 36).

Impell and Ebasco reviewed the original tests and determined that additional tests of cable trays and cable tray fittings were required. ' These additional O- tests were performed by Corporate Consulting and Development Company, Ltd.

(CCL) (Reference 56).

For each tray test, the load / deflection curve up to failure load was recorded. The failure load provided the maximum load carrying capacity and the load / deflection curve was used to calculate the equivalent area moments of j inertia of the trays.

The tests conducted by CCL included tray fittings (e.g. tray bends and tees).

The additional tests conducted by CCL also provided information pertaining to, the installation discrepancies that were identified during cable tray inspections. The tray / fitting discrepancies which were identified during the Post-Construction Hardware Validation Program (PCHVP) and subsequently tested include:

Cable Tray Tee Type Fitting Held Test - Held discrepancies in Tee type fittings Field Fabricated Splices - Tests for various types of field splices ,

and tests for configurations with a minimum number of bolts to provide full splice strength in tray splicing A

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i Review of Cable Tra'v and Cab 1'e Trav Fittina Static' Test Data Test data for cable trays (both original ; tests' performed by the tray. suppliers and: additional tests performed by CCL)-was reviewed,by.Impell/Ebasco.

Equivalent section properties.and load capacities were determined.and tabulated in design procedures (References 4,.14,'and-34).- For further j

! details related to the use of this information see Sections 5.2.2.and 5.2.3. 1 Test data for cable tray fittings ~ has been' reviewed by Impell/Ebasco to. l develop design procedures (References 4 and 34) specifically for tray- l fittings. . The test data also provided sufficient information to resolve the issues.(Subappendices B4 and B6) pertaining to. cable trays identified by the Corrective Action Program (CAP).. In some instances this resolution consists, q of design validation of the,as-built configuration;'in other instances the resolution requires hardware modifications.

Trav Clamo Assemb1v Static Tests-The cable trays are fastened to the hangers with.several types'of clamp ,

assemblies'(see Figure 5-2). The assemblies are either bolted directly to the I trays (longitudinal clamps) or clamped over the side rails ~of the trays- l without a bolted connection to the tray (friction clamps). J Tests of CPSES Unit 1 and Common tray clamp assemblies were performed at the laboratories of Corporate Consulting and Development Company,lLtd. (CCL)

/~ (References 57 and 58) to establish load capacities for use in the design . -

l

\ validation. The clamp assemblies tested were selected through'a review of the installed clamp types to determine the test assemblies which would conservatively envelope the other installed clamp types (i.e.,'to' test the-clamp assemblies with the lowest capacity). The clamp assemblies were tested l to failure in each of the directions in which these assemblies provide

! significant restraint, and the load / displacement behavior was' recorded. From i

these results, the allowable design'1oad was determined. To provide assurance that the clamp assembly would remain functional when. subjected'to' cyclic loads produced by seismic events, cyclic tests were performed to simulate the design life of five (5) OBE events and one (1) SSE event.

Review of Clamo Assembly Static Test Data 1

1 Test data for clamp assembly tests was utilized by Impell/Ebasco to determine assembly allowable loads and load interaction equations which were incorporated into the design procedures (References 4 and 35). ,

5.1.1.2 Resolution of Cable Tray and Cable Tray Hanger Related Design Issues Subsequent to the performance of the walkdowns of Unit 1 and. Common cable trays and cable tray hangers (References 6, 21, and 49), Impell/Ebasco.

reviewed the as-built information to determine:

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i Whether there were-any additional technical issues'related to.the-functional behavior of cable tray systems-that should be evaluated

-i during the Corrective Action Program (CAP) j Whether' additional design inputs, guidelines, or; procedures were necessary to complete the. cable tray and cable tray hanger design' j

validation effort Impell/Ebasco then evaluated the issues. listed in Section 4.0 and: described in Appendices A and B, and developed technical and design. control procedures to resolve the issues. The resolution of these issues _was reviewed by TU-Electric Comanche Peak Engineering (CPE) and TENERA .L.P. (TERA). These-resolutions were incorporated into:the. updated installation specifications,.as 1 well as the CPSES Quality Control and construction procedures. ]

i The issue resolution and implementation' processes were as follows: 1

1. For each issue that affected the cable tray,and cable tray hanger ,

- validation effort, Impell/Ebasco. reviewed the associated .!

documentation to gain an understanding of the background. ,

Impe11/Ebasco then defined their understanding ~ of the issue;-

2. With the issue thus defined, Impell/Ebasco developed and executed an action plan to resolve the issue; and O 3. The resolutions were implemented.in appropriate Impe11/Ebasco. project-

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procedures used for the CPSES Corrective Action Program (CAP). '

Compliance with these procedures-is~ assured by the Impe11'and Ebasco.

Quality Assurance Programs.

Third Party Overview Results l

TENERA, L.P. (TERA), the lead contractor for the Comanche Peak Response Team (CPRT) Design Adequacy Program (DAP), conducted'the third party overview to assure that all Comanche Peak Response Team _(CPRT) and external issues are clearly identified and resolved in accordance with the CPRT Discipline Specific Action Plan VIII (DSAP-VIII).  ;

The scope of the third party overview as stated in the Discipline Specific l Action Plan Results Report for Cable Trays and Cable Tray Hangers (Reference 1

48) included: 1 external source issue identification j design criteria / commitment identification 1 as-built procedures review design validation procedures review engineering studies. review test programs review j issue resolution review .

overview of corrective actions implemented by Impell/Ebasco.

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- During performance of the CPRT-DAP, TENERA,. L.P. (TERA). identified discrepancies and documented these discrepancies.in Discrepancy Issue Reports

(DIRs). Impell/Ebasco have responded to and closed.all of the:240 DIRs-received from TERA. <

TERA has' completed the third party overview and presented the results.in the Discipline. Specific Action Plan ~Results Report for Cable Trays and Cable' Tray?

' Hangers. TERA concluded on.page 1-2:

"The assessment of.the overall adequacy of Ebasco'.s and Impell's design validation effort was accomplished by:> l Third Party review of-the. procedures, supporting'special studies and tests, Land resolution methodology for each external source-issue. These rev_iews.were performed.to evaluate the adequacy of'Ebasco's and Impell's: design validation procedures and to-assess:their, compliance with applicable FSAR and licensing criteria. Based on the findings.of these reviews. it is concluded that the design validation. procedures;and issue resolution .

methodologies are'in conformance with the appropr.iate-  !

criteria.

In summary, the Third Party has concluded that the- 1 Project's cable tray / supports; design validation l program is comprehensive and capable of resolving known technical issues and assuring that the design-  :

will meet the FSAR.and licensing comitments." l CYGNA Independent Assessment Proaram Cygna Energy Services (CYGNA), a consulting. firm, was' originally' contracted by TV Electric to perform a project review, identified as the' Independent' Assessment Program (IAP). As 'a result of this review, .CYGNA identified cable tray and cable tray hanger related issues which they sumarized inLthe Review Issues List (RIL) (Reference 12).

CYGNA is reviewing Impell and Ebasco technical and design control procedures developed to resolve the cable tray and cable tray, hanger related issues identified during the Independent Assessment Program (IAP).

TU Electric Technical Audit Proaram The TU Electric Technical Audit Program (TAP) .is auditing .the cable. tray and cable tray hanger portion of the Corrective Action Program (CAP).to' assure; ,

that the design criteria are reconciled with the ilcensing comitments. -

Sumary The reviews (TV Electric CPE, TU Electric TAP, TERA,.CYGNA) of the technical and design control procedures developed to resolve the Comanche Peak Response .

5-8

Team (CPRT) and external issues provided assurance that the procedures developed were satisfactory to perform the design validation of cable trays and cable tray hangers.

5.1.2 Design Validation Process After the establishment of design criteria and the development of procedures consistent with the licensing commitments, the Impe11/Ebasco cable tray and cable tray hanger design validation process was established. The validation process can be visualized as a four step process (see Figure 5-3). The first step, described in Section 5.1.2.1, was to establish the input for the cable tray and cable tray hanger analytical models. The second step, described in Section 5.1.2.2, was to evaluate the design of cable trays and cable tray hangers including the evaluation of cable tray fittings and cable tray clamps. The third step, described in Section 5.1.2.3, was to review the  ;

results of step two and identify if the design criteria were satisfied. If the analysis results did not satisfy the design criteria, the hatdware was modified to conform to the design criteria. The last step, or final reconciliation, described in Section 5.1.2.4, is the process to consolidate analysis, hardware modification and inspection documentation to assure consistency of the cable tray and cable tray hanger design documentation with the hardware installation. Technical interfaces for the cable tray and cable tray hangers design validation are shown schematically in Figure 5-4. This section of the Project Status Report (PSR) discusses the steps involved in the design validation process.

5.1.2.1 Validation of As-Built Attributes of Cable Trays and Cable Tray Hangers The first step in the design validation process of the cable tray hanger Corrective Action Program (CAP) was to obtain as-built information (design ,

attributes) for the cable tray systems at CPSES Unit 1 and Common. The '

as-built information necessary to verify compliance with design criteria was obtained by walkdowns conducted by experienced Ebasco personnel trained in i accordance with walkdown procedures (References 6, 21, and 49). The results were used to create as-built drawings of the cable tray and cable tray hangers. To provide additional assurance of the accuracy of the as-built drawings, TV Electric QC personnel verified these drawings to the as-built hardware in accordance with approved QC procedures (References 18 and 19).

The cable tray and cable tray hanger as-built inspections provided the necessary data to determine the cable tray layout and cable tray hanger configuration. As-built inspections identified the length of cable tray spans, cable tray hanger identification numbers, cable tray hanger orientation, and cable tray end locations. In cases where cable tray and cable tray hanger design attributes were inaccessible as a result of congestion and/or the presence of fire protection material, these inaccessible design attributes are noted by engineering walkdown personnel as "IA" on the cable tray hanger as-built drawings. A complete discussion of the design validation of cable trays and cable tray hangers with inaccessible attributes is provided in Section 5.1.2.2. J 5-9

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-Cable tray hanger modifications resulting from the design validation effort.

are incorporated. into the final as-built drawings. The modified hanger is:

then reinspected by.QC for final validation.- j Desian Inout Data The following documents were the. source of the Input information for the~ j design validation process:

l

1. ~As-bullt drawings: As-built cable tray and cable: tray hanger d drawings were prepared as a result of the. engineering walkdownu  !

process.- These. drawings provide.information for-determining'the I cable tray routing,' the location of the hangers on the cable tray.

run, tray identification number, cable tray hanger type, hanger; identification number, number and size of cable trays supported!by- .

the hanger, location of tray hinges, cable tray ends, . dimensions.ofi )

tray fittings, location of. fire protection material.

(thermolag/thermoblanket), and hanger geometry (member sizes,.

dimensions, anchor bolt. information, ' weld -joints , e clamp: type, ' and.

orientation of the hanger relative' to the tray); .N

2. Cable Fill Documents: These documents provide the as-built cable fill loads at cable tray hanger locations. Cable' fill data (Reference 39) was used to determine the; actual cable weight in the tray. The design validation process considered that additional O cables may be added to the tray during the life of the-plant by assuming additional cable weight in the design analysis.'In addition, design control procedures (Reference 68) assure.that design validated j

cable fill loadings are not exceeded; and

3. Amplified Response Spectra (ARS):- The ARS (CPSES seismic design information) was used as input to the design validation of. the cable trays and cable tray hangers.

5.1.2.2 Analytical Methods for Design Validation of Cable Trays and Cable Tray Hangers The cable trays and cable tray hangers were design validated for dead. weight loads and seismic loads. The effects of operating thermal loads and accident thermal loads were considered in a detailed engineering: study (Reference 41).

Analyses were performed which determined that the maximum operating thermal displacements were small and would not induce thermal loads in the cable trays-and cable tray hangers. Using the recommendations provided in NUREG-0800 Chapter 3 (Reference 46) additional analyses were performed to provide assurance that the cable trays and cable tray-hangers, including the. hanger anchorages, could accomodate the displacements associated with.the accident temperatures without loss of function. The analyses. considered the largest postulated accident thermal displacements (i.e., resulting from thermal expansion of a 40 foot straight tray run) and the cable tray system O

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configurations most susceptible to an applied displacement..(i.e., very stiff:

cable tray hangers). The.results showed that the cable. tray hangers are sufficiently ductile to accomodate the postulated accident thermal displacements without. reduction in seismic load resistance or loss of function.

. Dead weight includes' both cable tray and cable tray hanger weight and is determined from the as-built information (span lengths, tray configuration, fire protection material: configuration, and cable weight). The cable tray l dead weight includes cables, tray, tray cover, side rail extensions and fire protection material where encountered.

The seismic load is produced during the OBE or the SSE event as defined by .the "

j CPSES Amplified Response. Spectra (ARS).

Cable tray and cable tray hanger design validation was-performed using either.

of two analytical approaches:

1. Equivalent Static Method (ESH); or

2. Response Spectra Method (RSM).

Both of these methods are described below. .

1 Eauivalent Static Method 'I l The Equivalent Static Method (ESH) utilizes individual models of each hanger l for hanger design validation as described in Reference 14. After generating a three dimensional computer model of the cable tray hanger, which includes contributory cable tray weight, a frequency analysis is performed to obtain the fundamental (lowest). frequency of the hanger in the transverse,  !

longitudinal and vertical directions. This frequency was'then combined with  ;

the fundamental frequency of the tray in the corresponding direction to calculate the system frequency.

The system frequency is used to determine the seismic acceleration value in each direction from the Amplified Response Spectra (ARS).. This acceleration from the ARS is conservatively increased by at least 25 percent, and used to determine the equivalent static loads applied to the hanger in each direction.

Design validation of cable trays by the Equivalent Static Method. considered that tray spans (including straight trays, bends, tees,:and crosses) were either subjected to peak seismic accelerations or to seismic accelerations at the system frequency in each direction from the Amplified Response Spectra-(ARS). In all cases these accelerations were increased by at least 25 percent.

Resoonse Soectra Method Design validation of cable trays and cable tray hangers by the Response Spectra Method (RSM) utilized three dimensional models of the cable tray systems. All significant components of the cable' tray systems were modeled in Q sufficient detail to accurately predict the system response to the design .!

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i loads. 'More.specifically, tray. components'(including straight trays, bends',

tees, crosses, and reducers) and. hanger components (including tray-to-hanger -!

clips, hanger members, member connections and hanger anchorages) were included i in the models. .j

.. . 2 Significant connection eccentricities existing in the cable tray system were .j also modeled. A detailed description of the modeling procedures used in the )

.RSM approach is provided in References 2 and 37.

The dynamic responses of. cable tray systems due to seismic loading were-evaluated using the standard response spectrum method. Separate analyses were performed for the OBE and .SSE load cases. using 4% and 7% structural. damping, respectively. All frequencies of vibrations up to 33. cycles per second were-considered in the analyses. The modal responses for each frequency were combined in accordance with Regulatory GJide 1.92 (Reference 47).: The N-S, E-H and vertical directions of earthquake were considered to act simultaneously and the responses were combined using the square root of the sum of the squares (SRSS) method.

.]

Validation of Cable Tray Hanaer Systems with Inaccessible Attributes-The approach to validate the. cable trays and cable tray hangers with inaccessible a configurations {tributesutilizedtheextensivedatabaseofattribute resulting from the as-built inspection of the cable tray and cable tray hanger accessible attributes. The cable trays and cable-tray hangers were design validated considering each inaccessible attribute to have O a configuration which was determined as follows:

l 1. For attributes with a relatively small number of variations 'in i configuration (e.g., tray clamps) as determined from a review of all-l as-built configurations, the configuration resulting in the lowest {

load capacity was selected; )

1

2. For attributes with many variations in configuration (e.g. welds) as j

determined from a statistically significant sample of all as-built '

I configurations, the configuration resulting in the lowest load capacity was selected; or 4

3. For attributes which were inaccessible as a result of fire protection material, the field walkdowns provided profile and dimensional information about the attributes. The details of the~ attribute configuration (e.g., member lengths) were then determined by engineering evaluation.

I Attribute configuration is defined as the details of a particular attribute which are required for design validation. Some examples are clamp type, weld <

size and weld length. '

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Additional assurance in the adequacy of the approach was provided by:

1 Actual verification of the design validation methods.for inaccessible attributes on attributes which were accessible. This verification was performed on the most highly stressed attributes, and demonstrated that the design validation methods for inaccessible attributes are conservative.

Inspection of previously inaccessible attributes and comparison of the as-built attribute configuration with the configuration determined from the inaccessible approach. This inspection was -

conducted on the most highly stressed inaccessible attributes and further demonstrated that the approach is valid.

Development of a database of stress levels for the. validated cable trays and cable tray hangers. This database demonstrates that the average stress levels in the cable trays and cable tray hangers are low and that the most highly stressed have been reviewed again to provide additional assurance of their design adequacy.

TENERA, L.P. (TERA), as part of the scope of their third party review of all CPRT and external issues (as discussed in Section 5.1.1.3),-reviewed the criteria and methodology used for the design validation of cable trays and cable tray hangers with inaccessible attributes. In the Discipline. Specific Action Plan Results Report for Cable Trays and Cable Tray Hangers on page 3-7, TERA has concluded the following:

• The results of the Third Party review of the Project's methods and related special studies for determining design validation for inaccessible cable tray / support components are documented in DAP-E-C/S-126, DAP-E-C/S-160 DAP-E-C/S-181 and DAP-E-C/S-182. All Third Party concerns related to inaccessible attributes have been satisfactorily resolved by the Project." ~

5.1.2.3 Resolution of Design Validation Results The design validation results were reviewed to determine if the design criteria were satisfied. If this review identified cable trays and cable tray hangers that did not conform to the design criteria, the hardware was modified to conform to the design criteria.

5.1.2.4 Final Reconciliation The purpose of final reconciliation is to consolidate analysis, hardware modification, and inspection documentation to assure consistency of the cable tray and cable tray hanger design documentation with the hardware installation (see Figure 1-1). The final reconciliation process is performed in accordance with approved procedures (References 1 and 15). The final reconciliation of cable trays and cable tray hangers incorporates the following:

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.The Post-Construction Hardware Validation Program-(PCHVP)-results" which assure that the design validated configuration agrees with the  ;

hardware (see Section 5.1.3).

Resolution of the cable tray and. cable tray hanger related Comanche Peak Response Team (CPRT) and external issues. Final reconciliation also includes confirmation that the interfacing organizations have Jr j

-accepted the Impell/Ebasco cable tray and cable tray hanger results as compatible with their validated design. :The interfacing.  !

organizations and a brief description of the interface function are {

shown in Figure 5-4.  ;

Finally. closure of-open items,' observations and' deviations felated;t'o cable trays and cable tray hangers that were identified bylthe'TU Electric Technical Audit Program (TAP) and the-Engineering-Functional Evaluation (EFE) are-

- resolved prior to the completion of final reconciliation. Items.from NRC1 Notices of Violation.(NOVs) and TU. Electric Significant Deficiency Analysis Reports (SDARs) (10CFR50.55(e)) are also' resolved during the; final reconciliation process.

At the conclusion'of final reconciliation, the Design Validation l Packages.

(DVPs).as described in Section 1.0 are compiled. The. cable tray.;and cable' tray hanger DVPs consist of as-built cable tray and cable. tray hanger data',

cable trays and cable tray fitting calculations, cable tray clamp . .

calculations, cable tray hanger calculations, and design validated cable-tray hanger drawings.

5.1.3 Post-Construction Hardware Validation Program (PCHVP)-

The Post-Construction Hardware Validation Program (PCHVP) (Reference 60) is the portion of TU Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware. The Post-Construction Hardware Validation Program (PCHVP) process:is shown' diagrammatically in Figure 5-5.

The input to the Post-Construction Hardware Validation Program (PCHVP) is 1 contained in the installation specifications. The installation specifications j

implement the licensing commitments and design criteria of the' Design Basis l Document (DBD), which were developed during the Corrective Action Program j (CAP) design validation process. .;

Final acceptance inspection requirements identified in the validated installation specifications were used to develop the Post-Construction j Hardware Validation Program (FCHVP) attribute matrix. This matrix is a  :

complete set of final acceptance attributes, identified for installed hardware.. The Post-Construction Hardware. Validation Program (PCHVP), by. j either physical validations or through an engineering evaluation methodology, assures that each of the attributes defined in the attribute matrix is  ;

validated. l O

5-14 v

+- ,

(

Physical validation of an attribute is performed by Quality Control inspection or engineering walkdown, for accessible components. Quality Control inspections and engineering walkdowns are controlled by appropriate Field Verification Method (FVM) procedures.

The Post-Construction Hardware Validation Program (PCHVP)' engineering evaluation depicted in Figure 5-5 is procedurally controlled to guide _the Corrective Action Program (CAP) responsible engineer through the evaluation of each 1 tem on the attribute matrix to be dispositioned by the engineering:

evaluation method. Dispositions:of each attribute will .be clearly documented. If the technical disposition.of the' final acceptance attribute is'.

"not acceptable" or the attribute cannot' be dispositioned~ based on available information, an alternate plan consisting of additional evaluations,itesting,, ^

inspections /walkdowns or modification as necessary will be developedLto demonstrate and document the acceptability of the attribute.

Recommendations from the Comanche Peak Response Team (CPRT) effort _ comprise'a portion of this evaluation. A component of th'e Comanche Peak Response Team

-(CPRT) program has been the inspection of a' comprehensive, random sample of' existing hardware using an independently derived set of inspection-attributes. However, for the cable tray and cable tray hanger Corrective Action Program (CAP), as a result of the comprehensive as-built program, the.

CPRT inspections were limited to cable trays. The Comanche Peak Response Team (CPRT) inspection was performed and the results evaluated by third party.

personnel in accordance with Appendix E to the CP.RT Program Plan-(Reference 61). The scope of the inspection covered the. installed safety-related cable tray hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished product). Samples of these populations were inspected to provide reasonable assurance of hardware acceptability in accordance with Appendix D to.the Comanche Peak Response Team (CPRT) Program Plan.

Corrective action recommendations were made to TU Electric based on the evaluated findings when a Construction Deficiency existed, an Adverse' Trend existed, or an Unclassified Trend existed, as defined in accordance with Appendix E to the Comanche Peak Response Team (CPRT) Program Plan.

The Post-Construction Hardware Validation Program (PCHVP) assures that Comanche Peak Response Team (CPRT) recommendations are properly dispositioned.

Figure 5-5 illustrates that during the evaluation of a given attribute from the Post-Construction Hardware Validation Program (PCHVP) attribute matrix, the initial task of the Corrective Action Program (CAP) responsible engineer is to determine if any of the.following statements are true:

a. The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT);

O 5-15

If (j_ b. Design Validation resulted in a change to design or to a hardware final acceptance attribute that is more stringent than the original acceptance attribute or those attributes not inspected by the Comanche Peak Response Team (CPRT); or

c. Design Validation resulted in new work, including modification to existing hardware.

If the Comanche Peak Response Team (CPRT) had no recommendations and items b.

or c, above do not apply, the attribute under consideration will-be accepted.

This conclusion is justified by the comprehensive coverage of the Comanche Peak Response Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective. The attribute matrix is then updated to indicate that neither the engineering walkdown nor quality control inspection of the attribute is necessary. A completed evaluation package is prepared and forwarded to the-Comanche Peak Engineering (CPE) organization for: concurrence. The evaluation package becomes part of the Design Validation Package'(DVP) after Comanche Peak Engineering (CPE) concurrence is obtained.

If any of the three statements above are true, it is assumed that the final

' acceptance attribute must be further evaluated as. follows:

Determine Attribute Accessibility A The Corrective Action Program (CAP) responsible engineer will determine if the V attribute is accessible. If the attribute is accessible, a field validation of the item's acceptability will be performed and documented in accordance with an approved Field Verification Method (FVM).

If the Corrective Action Program (CAP) responsible engineer reaches the conclusion that the attribute is inaccessible, an engineering evaluation will be conducted by technical disposition of available information.

3 After completing the attribute accessibility review, the Corrective Action I Program (CAP) responsible engineer will update the attribute matrix as J necessary to reflect the results of that review.

Technical Disposition The Corrective Action Program (CAP) responsible engineer identifies the data to be considered during the subsequent technical disposition process.

Examples of such items used in this disposition may include, but are not limited to:

Historical documents (e.g., specifications, procedures, inspection l results)

Comanche Peak Response Team (CPRT) and external issues resolution O

v 5-16

q 1 . ,

yo

~

.; b j

Construction practices

-Quality records a

. l

'1 Test results: '

. Audit reports; "-

A ~*

' Authorized N clear In'spectors(ANI) records- >

c Surveillanceeports.

r

'NCRs, DRs, SDARs, and) CARS y A

m Inspections. conducted to date o 4 .. ,

n s .

,+

~*

Results of. Third Party reviews.

Purchasing documents Construction packages

, 4 Hardware receipt inspections After. compiling the data identified as pertinent.to the attribute, the O

d technical disposition will be performed.: The actual steps and sequence of actions required.for each technical: disposition will differ; however7the tangible results from each technical disposition will be consistent. 'These results will include as a minimum: ,

a. A written description of the attribute;

b. A written justification by the Corrective Action Program (CAP) responsible engineer for acceptance lof the attribute;i

c. A written explanation of the logic utilized to conclude that the

• attribute need not be field va11 dated;.

d. A chronology demonstrating that the attribute has not been significantly altered by redesign;

e. All. documents viewed to support the disposition; and.

f. Concurrence of the acceptance of the attribute's validity by, Comanche Peak Engineering (CPE).

If the Corrective Action Program (CAP) responsible ~ engineer concludes that the-data evaluated represents evidence of the attribute's' acceptability,- the conclusion will be documented. The documentation will be; reviewed and-approved by Comanche Peak Engineering (CPE) and filed in the Design. Validation O

5-17 -

n:

I l

l Package (DVP). If the Corrective Action Program (CAP) responsible engineer

' determines that the data reviewed does not provide evidence of the attribute's I acceptability, the documentation will explain why the attribute cannot be I accepted and recommend an alternate course of action. The alternate course of I action may take various forms such as making the attribute accessible and inspecting it,-or testing to support the attribute's acceptability. This-alternate plan, after approval.by Comanche Peak Engineering (CPE), will be implemented to validate the attribute.

4 In summary, the Post-Construction Hardware Validation Program (PCHVP) is a comprehensive process by which each attribute in the PCHVP attribute matrix is validated to the validated design. The TV Electric Technical Audit Program (TAP) will audit the Post-Construction Hardware Validation Program (PCHVP).

This audit program is complemented by the Engineering Functional Evaluation (EFE) being performed by an independent team comprised of Stone & Webster, Impell, and Ebasco engineering personnel working under the Stone & Webster QA program and subject to oversight directed by the Comanche Peak Response Team's (CPRT) Senior Review Team (SRT). The Post-Construction Hardware Validation Program (PCHVP) will provide reasonable assurance that the validated design has been implemented for safety-related hardware.

To provide assurance that the as-built hardwaro complies with the validated design, the Post-Construction Hardware Validation Program (PCHVP) for cable tray and cable tray hangers developed a matrix of final acceptance attributes (See Table 5-2) based on the validated installation specifications. The Field Verification Methods (FVMs) (including those used to obtain as-built h/^ information utilized as input for the design validation) were then reviewed to j, determine whether all final acceptance attributes had been addressed. This i review concluded that all final acceptance attributes were addressed in the FVMs. 1 A brief description of the Field Verification Methods (FVMs) implemented in the Post-Construction Hardware Validation Program (PCHVP) is given below:

FVM-001/FVM-003 l

Field Verification Methods (FVMs) CPE-FVM-CS-001 (Reference 6) and TE-FVM-CS-003 (Reference 21) were j developed to control the collection of as-built data for Unit I and 1 Common cable tray hangers.  ;

i FVM-019/FVM-048 Field Verification Methods (FVMs) TE-FVM-CS-019 (Reference 22) and ,

TE-FVM-CS-048 (Reference 50) were developed to control the collection i of as-built data for Unit 1 and Common cable tray splices. i o

l 5-18

c

, r i t.

.\

.1

• ~ '

FVM-36

~ Field Verification Method _'(FVM)LTE-F % CS-036'(' Reference 49)?wase developed to control the collection.of as-built data.for the main.

structural' framework associated with cablejtrays.-in the cable spread;'

room; ,

FVM-50 Field Verification Method (FVM). TE-FVM-CS-050.(Reference 51) was, developed to control-the' collection of as-built data for Unit liand' Common 1 flat. ladder Tee fittings. ,

- F E 68 ,

Field Verification Method (FVM)' CPE-SHEC-FVM-CS-068 (Reference 54) was . developed to control the collection'of as-built data for Unit ~1 -

. as relating to Commodity' Clearance.

FVM-84 Field Verification Method (FVM) CPE-EB-FVM-CS-084-(ReferenceL52) was developed to control. the collection of as-built data for Unit and Common cable tray fittings.-

FVM-86 Field Verification Method (FVM) CPE-SHEC-FVM-EE/ME/IC/CS-086 .

(Reference 70)-was developed to identify the location and color code for Unit 1 and Common cable trays with thermolag.

FVM-088 Field Verification Method (FVM) CPE-SHEC-FVM-EE/ME/IC/CS-.088' c (Reference 55) was developed to c.ontrol the collection of as-built data for Unit 1 and Common cable tray separation _and barriers.

FVM-090 .

Field Verification Method (FVM) CPE-SHEC-FVM-EE/ME/IC/CS-090:

(Reference 71) was developed to control the collection of specific as-built data.(i.e., Hilti thread engagement, cable tray covers, and-cable tray fill above side rails) for Unit 1. and Common cable trays and cable tray hangers.

F E 98 .,

. Field Verification Method (FVM) CPE-EB-F%CS-098 (Reference 53) was-

- developed to control the collection of as-built data for Unit 1-and Common cable tray rung. spacing.

j 5-19 e

}

i q

j

• FVM-100 Field Verification Method (FVM) CPE-EB-FVM-CS-100 (Reference 69)'was developed to control the collection of as-built data for Unit 1 and Common cable tray clamp combinations.

5.2 RESULTS This section discusses the results of the cable tray and cable tray hanger-Corrective Action Program (CAP).

5.2.1 Cable Tray Hanger Design Validation Results The cable tray hanger analysis validated that all 7566 cable tray hangers in Unit 1 and Common comply with the design criteria. During the cable tray hanger design validation process, modifications to approximately 874 hangers were identified. These modifications are being implemented to correct the following:

member overstresses weld overstresses member slenderness ratio exceedence clamp capacity exceedence anchor bolt capacity exceedence.

5.2.2 Cable Tray Design Validation Results The cabl. tray analysis validated that all cable trays in Unit 1 and Common a comply with the design criteria. During the cable tray design validation  !

approximately 93 modifications were identified and are being implemented to correct cable tray overstress.

5.2.3 Design Validation Packages The cable tray and cable tray hanger design validation documentation will be transferred to TV Electric in 5549 design validation packages.

5.2.4 Post-Construction Hardware Validation Program (PCHVP) Results l l

The Post-Construction Hardware Validation Program (PCHVP) is being implemented I through the verification of the final acceptance attributes for cable trays and cable tray hangers in Unit I and Common as discussed in Sect'.on 5.1.3.

5.3 QUALITY ASSURANCE PROGRAM  !

Activities of the Unit I and Common cable tray and cable tray hanger Corrective Action Program (CAP) were performed in accordance with Impell's or Ebasco's Quality Assurance (QA) program as applicable.

/~

V) u 5-20 l

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i I

Nuclear safetp related work at Impell is performed in accordance with the Impell Quality Asw rence Program (Reference l Appendix B,' ANSI N45.2, and with appropriat'10),shich compliesincluding e ANSI daughter standards with 10CFR50, N45.2.9, N45.2.11, N45.2.12, and.N45.2.23...Impell's Corporate Quality Assurante Program was reviewed and approved by TU Electric's Quality Assurance organization.; Prior to initiation of work to implement the, cable tray and cable tray hanger Corrective Action. Program (CAP) a cable tray and cable tray hanger Project Quality Plan was. developed in accordance with the Impell Corporate Quality Assurance Program. The Project Quality Plan has been reviewed by TU Electric and serves to control all Impell work performed to:

validate the design of the CPSES cable trays and cable tray hangers.

Ebasco implements their Nuclear Quality Assurance. Program which is described )

by the NRC approved Topical-Report ETR-1001 (Reference 62). Ebasco's corporate program, ETR-1001, addresses all phases of completion of a nuclear power plant including design, procurement,.and construction. The corporate Topical Report has been modified to make it project specific;' sections that- ,

did not apply to the cable tray and cable tray hanger Corrective Action- 1 Program (CAP) scope of services were deleted.- Ebasco's Nuclear Quality. j Assurance Program as modified for CPSES Unit I and Common has been reviewed '

and approved by TU Electric's Quality Assurance organization.

Impell developed a Project Quality Plan specifically for the TU Electric CPSES cable tray and cable tray hanger related work. The Project. Quality Plan -

(Reference 65) includes specific instructions and procedures to supplement the ]

O Impell Corporate Quality Assurance Program. The instructions and procedures (V were issued to direct the organization and format for design validation

]

calculations and to assure that documentation is provided in a standard and complete manner. To provide additional assurance in the technical adequacy of i design calculations Impell Corporate Quality Assurance Program has established a Technical Quality Review program (conducted internally). The Technical ~ >

Quality Review consists of a detailed technical assessment by' qualified )

engineers of the reasonableness of the technical. work performed. The program has been implemented in all Impell offices and on CPSES cable tray and cable tray hanger related work. Technical Quality Reviews are documented and are made part of project records. ,

Ebasco developed and issued a Manual of Procedures (Reference 15) specifically related to TV Electric CPSES work. This manual includes very specific instructions and procedures to supplement the Ebasco standard Engineering,-

Nuclear, Project and Procurement Procedure Manuals. The Manual _'of Procedures includes in tructions for all aspects of the design validation' effort performed under Ebasco's quality program and also references the walkdown activities that are conducted under the TV Electric QA program at the site.

Separate instructions are issued to direct the precise organization and format 1 for documents that validate designs. These instructions are issued so-calculation documentation will be provided in a uniform and complete manner..

A design validation checklist was developed for this project and has been used to document Ebasco responses to questions identified for design validation in ANSI-N45.2.11 and NRC Regulatory Guide 1.64 (Reference 66).

O 4 5-21

f In accordance with these Quality Assurance (QA) programs, design basis documents (DBDs), detailed procedures, and project specific QA programs covering the essentials of the cable tray and cable tray hanger program were developed. . These documents were distributed to Impell/Ebasco supervisory engineers and were readil.y available to Impell and Ebasco personnel. .The.

issuance of design criteria, validation procedures,.and major revisions were  ;

followed with training programs for the applicable personnel. In particular, 1 cable tray and cable tray hanger engineers on the project received training in.. 1 the design procedures and the design control procedures. ]

Project Quality Assurance (QA) Managers for both Impell and Ebasco, who report-to Impell and Ebasco Corporate Vice Presidents, respectively, and who have-management experience in auditing and Q.A. program procedure development for 1 engineering activities _ were assigned to the project in the earliest stages of J project mobilization. This reporting responsibility assures independence of' Quality Assurance (QA) functions. -QA personnel provide assurance that the QA program properly addresses all project activities and assists project personnel to understand and properly implement the QA program.

To date more than 35,000 man-hours have been expended by Impell and Ebasco in activities directly attributable to the overall Project Quality Assurance program (i.e., training, procedure development, auditing..and the project QA supervisory staff).

The adequacy and implementation of the Impell and Ebasco Quality. Assurance programs was extensively audited internally by Impell's and Ebasco's Quality O Asterance Engineering Audit Groups respectively, and externally by TV Electric Technical Audit Program (TAP), Nuclear Regulatory Commission, and TENERA, L.P.

(TERA). A total of 40 audits were performed by these organizations-from February, 1985 to date for both' Unit 1 and Common as follows:

Impell Audit Group -

6 audits  !

- 3 surveillance, 1 Ebasco Audit Group -

12 audits TU Electric - TAP 2 -

13 for Ebasco 8 for Impell NRC -

1 for Ebasco TERA - Interface with both Impell and Ebasco from October,,1986 to date.

2The TU Electric Technical Audit Program (TAP) has been in effect since January, 1987. Prior to this the TV Electric Quality Assurance Department performed audits of selected engineering service contractors using technical specialists as part of its vendor audit program.

5-22

l O . .

V In addition, the Engineering Functional Evaluation (EFE) team has audited Impell's and Ebasco's progress since' June, 1987.

The Impell and Ebasco, NRC, and TV Electric Technical Audit Program (TAP)-

audits evaluated the technical adequacy of the engineering product (e.g..-

calculations,_' drawings, and specifications) and assessed the adequacy and implementation of the Quality Assurance Programs.

Impell's Quality Assurance (QA) Program and Ebasco's Quality Assurance'(QA)

Program each require that QA audits _of all safety-related. project activities-be performed periodically.. These audits are both' programmatic and technical' in nature. Summaries of the audit details for the Impell and the Ebasco Quality Assurance (QA) Programs are provided in Section 5.3.1. ,

TU Electric conducted technical audits as part of the ~TU ElectricL Technical Audit Program.(TAP). The details.of calculations, drawings, procedural compliance and technical interface were evaluated. These technical audits have resulted in enhancements to the procedures and methods, and thus,-

contributed to the overal1~ quality of the CPSES cable tray and cable tray hanger design.

The NRC audits. included in-process reviews of Impell's and Ebasco's progress and methods for resolving the generic technical issues and verification of the adequacy of cable tray and cable tray hanger walkdowns.

A Third Party organization (TENERA, L.P. (TERA)) was contracted by the Comanche Peak Response leam (CPRT) to overview the adequacy of.Impell and Ebasco cable tray and cable tray hanger design methodology.~ -The Third Party concluded that cable tray and cable tray hanger validation program _was comprehensive and capable of resolving known Comanche Peak Response Team (CPRT) and external issues. This Third Party overview provides additional assurance that the CPSES cable trays and cable tray hangers satisfy the licensing commitments.

TV Electric has initiated the independent Engineering Functional Evaluation (EFE) program to provide an overview of the technical activities being conducted on the CPSES projects. The EFE program for cable trays and cable tray hangers was initiated in May, 1987. Cable tray and cable tray hanger design has been reviewed to assure consistency with validated input data and to~ assure outputs have been transferred to appropriate interfacing.

organizations.

The audits described above represent very detailed and complete assessments of the following:

Adequacy of the-Quality Assurance program Implementation of the Quality Assurance program Technical adequacy of the design criteria'and procedures Implementation of the design criteria and procedures O

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As such, these audits identified items in design criteria, procedures, calculations,.and project documentation and training for which action was j required to clarify or improve the design validation process and assure continued compliance with procedures. Each item identified through the. audit process was reviewed in detail to determine the extent of the condition, the cause of the condition and any corrective or preventive action required.

, Complete responses were provided for each item identified. Subsequent audits have verified that appropriate corrective and preventive actions were -

implemented to address the previously identified audit items.

In addition to the quality assurance reviews, audits and surveillance, a rigorous Quality Control (QC) inspection program is in place on the CPSES -

site. The QC inspection program provided a review of the cable tray and cable t tray hanger as-built walkdowns. Inspection procedures identify the attributes. j which QC inspectors must inspect before a particular installation is acceptable. '

In summary, an appropriate level of attention.has been given to the quality of all activities; the Quality Assurance (QA) program is appropriate for the scop'e of work; project performance has been demonstrated to be in compliance 1 with the QA program; and appropriate corrective and preventive actions were j

taken whenever they were required.

5.3.1 Summary of Impe11 and Ebasco Quality Assurance (QA) Audits O 'i V To date, Impell QA has performed 6 audits and 3 surveillance of the Impe11 cable tray and cable tray hanger design validation program. Ebasco QA has performed 12 audits of the Ebasco cable tray and cable tray hanger design validation program. Each Impell and Ebasco location has been audited. The following list of audit subjects describes the depth of auditing that has been performed:

1. Adequacy of the Project Design Procedures

2. Adequacy of the Project Procedures

3. Calculations - Technical Adequacy

4. Calculations - Documentation

5. Compliance with Project Procedures '

6. Construction Support Activities

7. Document Control

8. Indoctrination and Training

9. Licensing Activities j O

5-24

10. Records Maintenance

11. Maintenance'of Project Procedure Manuals j l

12. Personnei Qualification and Experience Verification l

13. Inputs to Cable Tray and Cable Tray Hanger Analyses' 5.3.2 Summary of Audits by TU Electric Technical Audit Program (TAP) i and the NRC In addition tt: the Impell'and Ebasco internal Quality Assurance (QA) Audits,  ;

both Impell M Ebasco were audited by the TO Electric Technical Audit Program (TAP) and tne NRC.

To date, TV Electric's Technical Audit Program has performed 8 audits of Impell and 13 audits of Ebasco. Each location (performing cable tray and l cable tray hanger related work for CPSES) of each organization has been audited at least once. . These audits are essentially equivalent to the Impell and Ebasco audits discussed in Section 5.3.1. The list of audit subjects in Section 5.3.1 is representative for these audits. A tabulation of the TU Electric Technical Audit Program (TAP) audits is presented in Table 5-3.

In August of 1986 the NRC Vendor Program Branch performed an audit.of Ebasco's implementation of Ebasco's approved Nuclear ~ Quality Assurance Program. Their O

V inspection was specifically related to Ebasco's QA Program Implementation'on the Comanche Peak Project. Their report, #99900505/86-01, indicated that the NRC Inspectors found no instance where the implementation of Ebasco's QA i program for CPSES failed to meet NRC requirements.

NRC personnel are currently performing audits of the Impell and Ebasco cable tray and cable tray hanger design validation programs. The results of their  ;

audits will be published at a later date. '

5.3.3 Engineering Functional Evaluation (EFE)

The Engineering Functional Evaluation (EFE) is currently in progress.

5.4 CORRECTIVE AND PREVENTIVE ACTIONS Impe11 and Ebasco have developed the technical and design control procedures and updated the installation specifications to-implement the corrective actions resulting from the cable tray and cable tray hanger Corrective Action Program (CAP). These procedures and specifications are identified within the cable tray and cable tray hanger Design Basis Document (DBD) (Reference 42) which contain the bases for validating the cable trays and cable tray hangers in Unit I and Common. As a result of this effort, the Comanche Peak Steam Electric Station Unit I and Common cable trays and cable tray hangers are validated as being capable of performing their safety-related functions. ,

5-25

b This validation is documented in the' drawings; calculations and specifications. The validated design documentation will be provided to'TU Electric. This validated design documentation can provide the basis for configuration control of CPSES cable-trays and cable > tray hangers to i facilitate operation, maintenance, and . future modifications following_ issuance-of an operating license.

At the completion of the validation, Impe11 and Ebasco will provide.TU.

Electric Comanche Peak Engineering.(CPE) with the complete set of cable tray hanger drawings and cable tray and cable tray hanger calculations, contained ~  ;

within the 5549 Design Validation Packages (DVPs) for Unit I and Common, .!'

necessary for maintenance of the design. .Impe11/Ebasco procedures used-.for validation will be provided to Comanche Peak Engineering (CPE).

Implementation of these procedures by CPE will assure that future CPSES. cable tray and cable tray hanger design is performed in accordance with the licensing commitments.

Training for Comanche Peak Engineering (CPE) personnel will be provided by Impe11 and Ebasco. The training will cover background assumptions-and the methodology.used in the validation of the cable trays and cable tray hangers.

TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design. function from 1 Impell and Ebasco to CPE. The program provides for the identification of l those tasks presently being performed by.Impe11 and Ebasco which are.to be

'O transferred to CPE and the identification of all procedures, programs, training, and staffing requirements. The program is based upon three prerequisites: (a) the cable tray and~ cable tray hanger Corrective Action Program (CAP) effort to support plant completion is finished for the particular task; and (b) the cable tray and cable tray hanger Design',

Validation Packages (DVPs) are complete;'and (c) any required preventive:

action taken, as discussed in Appendices A and B is complete. '

This program assures the transfer of complete design documentation and procedures to Comanche Peak Engineering (CPE).

O  :

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__j

I FIGURE 5-1 TYPICAL CABLE' TRAY CONFIGURATION'

. VERTICAL

- U.

TRANSVERSE U

U A -

Y mme ] d TRAY WIDTH

~

- ( INCHES)

LADDER BOTTOM CABLE TRAY- .)

l

' VERTICAL i

h TRANSVERSE

/___

I f gg s'

RAIL -

me-maj _

TRAY WIDTH

- ( INCHES)

SOLID BOTTOM CABLE TRAY

FreuRE s-2 l o TYPICAL TRAY CLAMP ASSEMBLIES l

80LTED TO TIER /

(([ -

TIER

/ .w M= .- ,

/ / '

-)

[  !

i FRICTION TYPE CLAMP -i (LADDER BOTTOM TRAYS ONLY) l 0

i 1

BOLTED TO TRAY j l

WELDED'OR FCLTED

_ _ 'TO TIER i TIER a f f

l l  !

' LONGITUDINAL TYPE CLAMP l

l I

f FIGURE ~5.3:

CABLE TRAY..APO-CABLE TRAY HANGER-DESIGN'. VALIDATION PROCESS O .

IPPUT

- CABLE TRAY. SPAN DRAWINGS'

- CABLE TRAY HANGER DRAWINGS.

- CASLE TRAY FILL LOADS:

- ARS CURVES I t EVALUATION

- CABLE TRAY / FITTING STRESS ANALYSIS.

- - CABLE TRAY CLAhF STRESS ANALYSIS-

- CABLE TRAY HANGER STRESS-ANALYSIS 1

l I f ACCEPTABLE E

7-l i

i NO 1

i t l MODIFICATION

- DESIGN CASLE AY MODIFICATIONS- Ie MODIFY SUPPORTS OR SUPPORTS)'

- DESIGN CABLE TRAY CLAnF MODIFICATIONS (le CHANGE CLAAP TYPE) . .

- DESIGN PEW OR WODIFIED CASLE. TRAY HANGERS I f-FINAL" RECONCILIATION-

- ASSURE DESIGN VALIDATION. ]

IS IN ACCORDANCE-WITH,'

. PROCEDURES C

'(- - ASSURE HARDWARE MATCES VALIDATED DESIGN I

e

FIGURE 5-4 CABLE TRAY AND CABLE TRAY HANGERS -

CORRECTIVE ACTION PROGRAM TECHNICAL ~ INTERFACES-O &

-TU ELECTRIC COMANCHE PEAK ENGINEERING

- MANAGEENT OF CORRECTIVE -

ACTION PROGRAM ll U

T j IMPELL/EBASCO j l VALIDATION OF

-O y WIN x

CABLE TRAYS ANO ISSUES CABLE TRAY O HANGERS  : - OVERVIEW PROCEDURES OF TE VALIDATION PROGRAM I

'i j

i i n

l SWEC - CIVIL / STRUCTURAL j

- LOADS ON STRUCTURES AhD CONCRETE ANCHORAGES O

FIGURE 5-5 POST CONSTRUCTION HARDWARE. VALIDATION PROGRAM (PCHVP) c_--_-- ,

l m m !x aEv u P o n l l DESIGN VALICAT!QN l

!DENTIFY FINAL. l l

l MVIE IWTALL.ATION SPECIFICATION

%ll l

ACCEPTANCE ATTMIBt.lfE

{

l

i. _ _ _ _ _ _ _ .! I I I am!x I i___..___J U

CPRT M / MComemDE M.!NSPECT!QN

?

• NO p .__ _ - __ ____

3 DER!GN l ENG!4ERING EVALUATION l VAL!DAT!W a i 45J.T IN CHANED 3 1 M CE510N QR ACCEPTANm l g g , IDENT!FY WC g ggyECT C0hP!LE DATA

, 'l l

l. l e l PsRFa= t g TEDN! CAL 2 l j O! POSIT!QN t VAL! OAT!QN  ! '*" i b! RERA.T IN WW mm!x 8 W0% INCLLC! W l l ts00!F! CATION OF l l El* l = m2.T5 No i u

i "7'*" i l @

l IS l l ATTM!8ifrE ND rg i YES I g g

, TEONICAL

,7 l DISPOE!T!CN YES l-YES g CobrLETE M ISLE l 1 EV AUATION T  !

1i l LPOATE 16ATM!x l l PACNAGE l

l No I

- OC IN m ECTION g

g

- EMS!MER!W WENDOWN '

! 4AAKE ACCESS!8LE l .

l * ^' ""* I  !

l UPDATE m m!x l I I i I ry , I I I CPE I l Fw I CoNewmMu * ^

l '

i l i Fl u i i VALIDATICM l l i . .J vEs l l

, r u_______ _ _ _ _ _ . ._____s (J

m  !

! u. . DE= !=

l gg.7g _ VALIDAT!DN _

oEs!W Pac"^at

? (DVP)

NO l it isOD1FICATICM l _ _ _ _ _ _ _

i G

Q' . TABLE 5-1 CABLE TRAY AND CABLE TRAY HANGERS i

^

GOVERNING DESIGN VALIDATION PROCEDURES ~

PI-02 Dynamic Analysis of. Cable Tray Systems (Reference! 2) )

PI-03. Design Verification of Cable Tray Supports (Reference,3)

PI-06 Design Verification of. Cable Trays and Tray Clamps' (Reference 4).- ,

PI-07 Design Verification of Base Plates, Base Angle and '

Embedment Plate (Reference 5)

PI-08 Cable Tray Fill Loads-(Reference 40)  ;

PI-ll Cable. Tray System Analysis and. Qualification Closecut:- l (Reference 1) 1

, SAG.CP3 Seismic Design Criteria for Cable Tray Hangers for- ,

l Comanche Peak SES Unit 2 (Reference 63) j l SAG.CP4 Seismic Design' Criteria for Cable Tray Hangers for- .;

l Comanche Peak'SES Unit 1 (Reference 13)-

l SAG.CP9 Instructi.on.for Re-evaluation of Cable Tray Hangers 1 l

Affected by the Longitudinal Tie of Transverse Hangers' i to the Tray For Comanche Peak SES Unit 2, (Reference 16).

SAG.CPil System Analysis of Cable Tray and Hanger Assembly for Comanche Peak Steam Electric Station Units 1 and 2 (Reference 37) 4

/

l SAG.CP18 Design Verification of Cable Trays for Comanche Peak'SES

\

l Units 1 and 2 (Reference 34)

SAG.CP19 Design Criteria'and Procedures. for Design Verification of Cable Tray Clamps for Comanche' Peak SES Units.l and 2, i

(Reference 3S)

SAG.CP28 Procedure for Screening of Cable Tray Hangers to Assess j the Applicability of a 1.25 HRH in Equivalent Static  !

Method Analysis in Hanger Design Verification;for Comanche Peak Steam Electric Station Units 1 and 2 (Reference 38)

SAG.CP34 General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES Nos. I and 2, (Reference 14) l l

r

I' s

. TABLE'5-2 POST-CONSTRUCTION HARDWARE VALIDATION PROGRAH CABLE TRAY AND CABLE TRAY HANGER ATTRIBUTE MATRIX.

Construction Final Acceptance PCHVP Attribute Work Cateaory Attribute ' Validation Method Cable Tray Type / size CPE-EB-FVM-CS-019.

Configuration (Reference 22)

TE-FVM-CS-048-(Reference 50)

Rung spacing at CPE-EB-FVM-CS-098 splices '(Reference 53)

Edge distance for field ECE 9.04-05 drilled holes (Reference 67)'

Sharp edges ECE 9.04-05 Rung spacing - ECE 9.04-05 (other than splices)

Q Splice plate type' CPE-EB-FVM-CS-019-LI TE-FVM-CS-048 Boltedjoints' tight -ECE.9.04 .i and rigid 1 Field fabricated CPE-EB-FVM-CS-084 1 fittings' configuration' (Reference 52)' l and dimensions j 1

Hisdrilled holes ECE 9.04-05 i

Location / routing CPE-FVM-CS-001 (Reference 6) '.;

CPE-EB-FVM-CS-019 i

Clearance CPE-SHEC-FVM-CS-068 (Reference 54)

Gap at splice plate ECE 9.04-05 P1 '

V i

1 s  !

i N,./ . TABLE 5-2 (Continued)

-Construction Final Acceptance PCHVP Attributes .

Work Cateaorv Attribute' Validation Method .j Cable Tray Color code ECE 9.04-05' Configuration (cont'd)

Color code for trays CPE-SHEC-FVM-with themolag EE/ME/IC/CS-086' (Reference 70) q l

Covers - location CPE-SHEC-FVM- 1 EE/ME/IC/CS-090 lj (Reference 71)

Damage ECE 9.04-05 Fill above side rail 'CPE-SHEC-FVM-EE/ME/IC/CS-090 )

i Fill verification- ECE 9.04-05

]

Identify cable trays CPE-SWEC-FVM- l with thermolag EE/ME/IC/CS-086 '

Routing verification ECE 9.04-05 Separation CPE-SHEC-FVM- i EE/ME/IC/CS-088 i (Reference 55) .

Barriers CPE-SHEC-FVM- i EE/ME/IC/CS-088 Cable tray welding Arc strikes ECE 9.04-05

]

Profile ECE 9.04-05 Surface slag ECE 9.04-05 Location ECE 9.04-05 j Size / length ECE 9.04-05 i

Fusion ECE 9.04-05 l I

l 2

1 1

q

- i :- ,

6 I

TABLE 5-2 (Continued) 1 Construction Final. Acceptance. .PCHVP Attributes.

Work Category Attribute- ' Validation Method .,

Cable tray welding. Craters 'ECE 9.04 -

(cont'd).

Undercut ECE 9.04-05 Porosity- ECE 9.04-05 Overlap ECE'9.04-05.

Cracks ECE 9.04-05 Vendor Tee fitting. welds- TE-FVM-CS-050- ,

(Reference 51)- l

' Cable tray hangers Hanger plumb and level CPE-FVM-CS-001.

general TE-FVM-CS-003 3 (Reference 21)' i i

Bolt hole size ECE 9.04-05 l 1

Hanger member shape CPE-FVM-CS-001 and size TE-FVM-CS-003' Material type other CPE-FVM-CS-001.

than A36 and'A500 TE-FVM-CS-003-Identification- .CPE-FVM-CS-001 TE-FVM-CS-003 Configuration / dimensions. CPE-FVM-CS-001 TE-FVM-CS-003' Cable tray hanger CPE-FVM-CS-001 span length TE-FVM-CS-003 Unused bolt holes CPE-FVM-CS-001 TE-FVM-CS-003 Attachment location / CPE-FVM-CS-001 orientation TE-FVM-CS-003' .

Hanger elevation CPE-FVM-CS-001 TE-FVM-CS-003 3-

TABLE 5-2 (Continued) >

' Construction l _ Final Acceptance- PCHVP' Attributes

.Mork-Cateaorv- '

Attribute Validation Method Cable tray hangers Hanger location CPE-FVM-CS-001 general (cont'd)~ TE-F h CS-003 Cable tray angularity 'CPE-FVM-CS-001 CPE-EB-FVM-CS-019i

-Clearance CPE-SMEC-F E CS-06B 1 ,

Cable tray hanger Edge distance .CPE-F E CSa001 l

bolted. joints TE-FVM-CS-003 Tightening CPE-F % CS-001 TE-FVM-CS-003 Configuration CPE-FVM-CS-001 TE-FVM-CS-003 Slope 1:20 .CPE-FVM-CS-001 TE-F % CS-003 Thread engagement CPE-FVM-CS-001 TE-FVM-CS-003.

Bolt type / size CPE-FVM-CS-001

-TE-FVM-CS-003 Bolt substitution CPE-FVM-CS-001 TE-FVM-CS-003 Bearing'of nuts and CPE-FVM-CS-001 washers TE-FVM-CS-003' Hashers CPE-F E CS-001 TE-FVM-CS-003 Turning elements CPE-FVM-CS-001 TE-FVM-CS-003 Cable tray hanger Hilti bolt CPE-FVM-CS-001 anchor bolts / size and type TE-FVM-CS-003' anchorages Hilti bolt' location _ CPE-FVM-CS-001 -

TE-FVM-CS-003

~

q 4 p

.i l-

TABLE 5-2 (Continued)'

Construction' Final Acceptance -PCHVP: Attributes

.Mork Cateaorv Attribute ' ' Validation Method Cable tray hanger Hilti bolt washer CPE-F % CS-001 anchor bolts / . TE-FVM-CS-003 anchorages (cont'd)

Hilti bolts tensioning. 'CPE-FVM-CS-001 TE-F % CS-003' Richmond anchors - CPE-FVM-CS-001 insert bolt engagement TE-FVM-CS-003 Richmond anchors - CPE-F % CS-001 Tightening TE-F 4 CS-003 Hi1ti bolt - nut CPE-FVM-CS-001 fully engaged /no ,TE-FVM-CS-003 bottom out CPE-SMEC-F % .

EE/ME/IC/CS-090 Skew 6 degrees .CPE-F % CS-001 maximum TE-FVM-CS-003-Hilti bolt.embedment .CPE-F % CS-001 length' .TE-FVM-CS-003 Hilti bolts - rework- CPE-FVM-CS-001 concrete damage. TE-FVM-CS-003:

Concrete anchorage CPE-FVM-CS-001-spacing requirements- TE-FVM-CS-003'-

Hilti bolts projection. CPE-F % CS-001 TE-FVM-CS-003 Bearing of baseplates CPE-F % CS-001 TE-FVM-CS-003-Richmond anchors size CPE-FVM-CS-001-TE-FVM-CS-003 Richmond anchors bolt CPE-FVM-CS-001 material TE-FVM-CS-003 0;

.5

1 J

TABLE 5-2.(Continued).

Construction. Final Acceptance PCHVP Attributes Mork Cateaorv Attribute Validation Method y a

Cable tray hanger Richmond anchors - CPE-FVM-CS-001'

]q anchor bolts / beveled washer TE-FVM-CS-003-anchorages (cont'd) fabrication 1 l

Richmond anchors CPE-FVM-CS-001 location TE-FVM-CS-003 Richmond anchors- CPE-FVM-CS-001 double nut TE-FVM-CS-003 Cable tray hanger Orientation of bolted CPE-FVM-CS-001 clamps clamps TE-FVM-CS-003 Gaps in welded clamps CPE-FVM-CS-001 -

TE-FVM-CS-003 j

\

Dimensions of welded. CPE-FVM-CS-001 clamps TE-FVM-CS-003 Orientation of CPE-FVM-CS-001 l welded clamps TE-FVM-CS-003 f

Gaps in bolted CPE-FVM-CS-001 clamps TE-FVM-CS-003 Dimensions of CPE-FVM-CS-001 bolted clamps TE-FVM-CS-003 u Clamps - formerly CPE-FVM-CS-001 inaccessible TE-FVM-CS-003 CPE-EB-FVM-CS-100 J (Reference'.69)

Cable tray hanger Location CPE-FVM-CS-001 1 welding TE-FVM-CS-003-Size / length CPE-FVM-CS-001 TE-FVM-CS-003 Fusion CPE-FVM-CS-001 TE-FVM-CS-003 ,

O s  ;

TABLE 5-2 (Continued)-

Construction Final Acceptance PCHVP Attributes Work Cateoorv- Attribute- Validation Method Cable tray hanger Craters CPE-FVM-CS-001 welding (cont'd) TE-FVM-CS-003.

Undercut. CPE-FVM-CS-001

. TE-FVM-CS- 003 -

Porosity ~ 'CPE-FVil- -CS 001 .

TE-FVM-CS-003 Overlap CPE-FVM-CS-001

- TE-FVM-CS-003

Cracks' CPE-FVM-CS-001 TE-FVM-CS-003 Arc strikes CPE-FVM-CS-001 TE-FVM-CS-003 Profile CPE-FVM-CS-001 O -- TE-FVM-CS-003

! v Surfate s1ag CPE-FVM-CS-001 ]

l TE-FVM-CS-003' i l

1 P

.l 7

T

.N%.) TABLE 5-3

SUMMARY

OF TV ELECTRIC 4 TECHNICAL AUDIT PROGRAM (1AP) AUDITS i

AUDIT NUMBER DATE'0F' AUDIT REPORT TES-2 (Ebasco)- January 31, 1985

.l TES-4 (Ebasco) ' July.3,.1985 i TES-5 (Ebasco) ' September 12,:1985 '

]

TES-6 (Ebasco) . February 17, 1986 j TEN-4 (Impell). March 26.-1986 TEN-5/C (Impell) March 27, 1986 TES-7 (Ebasco) April 10, 1986 TEN-6 (Impell) October 2, 1986-TEN-7/C (Impell) .0ctober 2, 1986 TES-8 (Ebasco) November 24, 1986~

TEN-8/S (Impell) February 3, 1987 ATP-87-10 (Impell) May 6,11987 ATP-87-08 (Impell) May 8, 1987 1 TCP-87-07 (Ebasco) May 11, 1987 ATP-87-04 (Ebasco) May 29, 1987 IO ATP-87-36 (Ebasco) June 15, 1987

'\ / ATP-87-19 (Ebasco) ' June 29, 1987 TCP-87-31 (Ebasco) September _25, 1987 TCP-87-24 (Ebasco) In progress ATP-87-54 (Ebasco) In progress ATP-87-47 (Impell) In progress.

1 O .

h

6.0 REFERENCES

1. Impe11 Instruction PI-11. " Cable Tray System Analysis and Qualification Closeout," Rev. 3, October 15, 1987.

2. Impe11 Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"'

Rev. 6, October 15, 1987.

3. Impell Instruction PI-03, " Qualification of Cable Tray Supports,"

Rev. 5, October 20, 1987.

4. Impe11 Instruction PI-06, " Tray and Clip Qualification," Rev.1, October 20, 1987; with Addendum dated 02/02/87.

5. Impell Instruction PI-07, " Design Verification of Base Plates, Base Angles, and Embedment Plates," Rev. 3, September 16,.1986, with Addenda dated 01/07/87, 01/19/87, and 09/30/87.

6. TV Electric Procedure CPE-FVM-CS-001, " Field Verification Method <

Unit 1 Cable Tray Hanger As-Builting and Design Adequacy Verification Program," Rev. 8, August 24, 1987.

7. Impe11 Report 09-0210-0017, "CPSES Cable Tray Analysis / Test Correlation Final Report,"- Rev. O, February,1987.

8. Comanche Peak Response Team Action Plan, DSAP VIII .

9 " Civil / Structural Discipline and Issue Specific Action Plan,"

Pev. 1 January 24, 1986.

9. AISC, " Manual of Steel Construction," 7th Edition including Supplements No. 1, 2, and 3, 1973.

10. Impell Quality Assurance Manual Rev. 17, July 15, 1985.

11. " Test Plan - Dynamic Testing of Typical Cable Tray Support Configurations," Document No. A-000150 Rev.1, December 1985 by ANCO Testing Laboratory.

12. CYGNA Cable Tray Supports Review Issues List, Revision 14, 07/31/87 transmitted to TU Electric by CYGNA letter No. 84056.114, dated 08/10/87.

13. Ebasco Document SAG.CP4 " Seismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 1," Rev. 6 July 1, 1987.

14. Ebasco Document SAG.CP34 " General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No. I and 2 " Rev. 11, August 27, 1987.

O ,

6-1

O L/

15. Ebasco Manual of Procedures, Comanche Peak SES, October 26, 1987.

16. Ebasco Document SAG.CP9 " Instruction for Re-Evaluation of Cable Tray

. Hangers Affected by the Longitudinal Tie of Transverse Hangers to the.

Tray for CPSES Unit 2," Revision 0, March 17, 1986.

17. CPSES Units 1 and 2 FSAR, with current amendments.

18. TU Electric Procedure, QI-QP-11.10-9, " Modification, Rework and

'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1,"

Revt 8, May 7, 1987.

19. TU Electric Procedure , QI-QP-11.10-2A, " Inspection of Unit II Cable-Tray Supports," Rev. 11, October 22, 1986.

20. TU Electric CPSES, " Generic Issues Report (GIR) " Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers,"

Rev. 2, March 13, 1987.

21. TU Electric Procedure TE-FVM-CS-003," Field Verification Method Unit  !

2 Cable Tray Hanger As-Builting and Design Adequacy Verification Program," Rev. 2, November 21, 1986. ,

22. TU Electric Procedure CPE-EB-FVM-CS-019, " Unit 2 Cable Tray Selected Attributes As-Builting Program," Rev. 2, June 3.-1987.

l 23. Ebasco Document SAG.CP5 " Specification for Dynamic Test of Cable Tray Hanger System for Comanche Peak Steam Electric Station," Rev. 3, l April 21, 1986.

i

24. Ebasco, " Dynamic Test Report of Cable Tray Hanger System for Comanche

! Peak Steam Electric Station," Part I, dated April .25,1986, Part II,  !

I dated July 2, 1986, April 21, 1986. l

25. ANCO, " Final Summary Report - Comanche Peak Cable Tray Tests," Rev.

1, May 1987. +

26. ANCO Data Package for Case 1 Comanche Peak Cable-Tray Tests, Rev. 1, l June, 1987.

l 27. ANCO Data Package for Case 2 Comanche Peak Cable Tray Tests, Rev. 0, February, 1987.

28. ANCO Data Package for Case 3 Comanche Peak Cable Tray Tests, Rev. O, February, 1987.

29. ANCO Data package for Case 4 Comanche Peak Cable Tray Tests, Rev. O.

February, 1987.

30. ANCO Data Package for Case 6 Comanche Peak Cable Tray Tests, Rev. 1, October, 1986.

l V l

l 6-2 9

,p .

, /

. (( , i

+

^

. ';  ; y 311 'ANCO Data package for Case 7 Comanche Peak. Cable Tray Tests :.Rev.1 t

. 0ctober, 1986.

32. T.J. Cope Test _. Reports:and Data included in letter from J. F.' Currie; ' #

(T.J. Cope) to R. Mannelyan (G&H). February?3, 1982;.

33. -AISI. " Specification for the Design of. Cold-Formed Steel Structural-Members'," September, 1980.

34. . Ebasco Document SAG.CP18 " Procedure for; Qualification of Cable . '

(

' Trays for Comanche Peak SES Units,1 and 2," Rev. 3, October 30, 1987.- <

g 35. Ebasco Document SAG.CP19. " Design Criteria and Procedures for Des.ign l Verification of Cable Tray Clamps .for Comanche Peak SES Units '1' and.

2,"-Rev. 4, October 30', 1987. '

1 36. Husky Products Seismic Calculations and Load Test,.Rev. 1,Jdated ,

October 25,11978 and Cable Tray Qualification' Data,'CPSES I and 2, and. Subsequent Test Data Transmitted by LPI to:G&H as.a series:of~

letters from February to October 1979.

37. . Ebasco Document SAG.CP11, " System AnalysisLfor Cable Tray and Hanger Assembly for CPSES Units 1 and 2," Rev. 4, July 1, 1987.

38. Ebasco Document SAG.CP28, " Procedure for Screening of- Cable Tray:

. O. Hangers to- Assess the Applicability of a 1.25 MRM in Equivalent-Static Method Analysis in Hanger Design Verification for Comanche Peak SES Units 1 and 2," Rev. 3, August.19, 1987.

l

39. CPSES Cable Schedule 2323-EI-1700 " Report Section 30 - Raceway.

Percent Fills," December 3, 1985.

40. Impe11 Instruction PI-08, " Cable Tray Fill Loads," Rev.0, April 21, 1986.

i 41. Impe11 Calculation No. M-27 " Thermal.. Load Evaluation," Rev. 3, October 26, 1987.

1 L 42. Comanche Peak Steam Electric Station.No.1 and 2 " Cable Tray and l Cable Tray Hanger Design Basis Document," DBD-CS-082 Rev. O,'

l July 31,'1987.

43. Impell. Report No. 09-0210-093Ifor TU Electric' Comanche Peak Steam:

-Electric Station Units 1 and 2. "CPSES' Design Basis Consolidation-Program Plan," Rev. O, May.22, 1987.

i. 44. TU Electric CPSES Unit.1 & 2." Design. Basis Consolidation Program Plan," Ebasco Services,lInc., Rev. 1,LApril 11, 1987.

45. U.S. Nuclear Regulatory Commission,' Reg. Guide 1.29 " Seismic Design Classification," Rev. 3,' September,1978.

l. '6-3 a s ..

s -

8 N 46. U.S. Nuclear Regulatory' Commission, Standard Review Plan, )

(d NUREG-0800, Section 3.8.4, July 1981.

1

47. U.S._ Nuclear Regulatory Commission, Reg, Guide 1.92 " Combining Modal l Responses and Spatial Components in Seismic Response Analysis," '

Revision 1, February, 1976.

48. TENERA, L.P. Discipline Specific. Results Report; Civil / Structural -

Cable Trays and Supports, DAP-RR-C/S-001 Rev. 1, September 25, 1987.

49. TV Electric Procedure TE-FVM-CS-036 " Field Verification Method-As-Built Verification of Attachments to the Main Structural Framework in the Cable Spread Room Supporting Unit 1 Designated .!

Cable Trays and Selected Attributes of Unit 1 Cable Trays," Rev. 0, . I February 19, 1987.

50. TU Electric Procedure TE-FVM-CS-048 " Field Verification Method Unit 1 Cable Tray Selected Attributes As-Built Program," Rev.:0, December 31, 1986.

]

]

51. TU Electric Procedure TE-FVM-CS-050 " Field Verification Method T.J.

Cope Flat Ladder Tee Fitting Selected Attributes Data Collection,"

Rev 0, January 5, 1987.

52. TU Electric Procedure CPE-EB-FVM-CS-084 " Field Verification Method -

Engineering Halkdown for Replacement of Cable Tray Fittings in Unit )

O g 1 and 2," Rev. O. July 28, 1987.

53. TU Electric Procedure CPE-EB-FVM-CS-098 " Field Verification. Method Cable' Tray Rung Spacing Halkdown Unit I and 2," Rev. O, July 28,.

1987.

54. TU Electric Procedure CPE-SHEC-FVM-CS-068 " Field Verification Method - Commodity Clearance," Rev. O, July 30, 1987.

55. TU Electric Procedure CPE-SHEC-FVM-EE/ME/IC/CS-088 " Post .

Construction Hardware Validation (PCHV) Program Engineering /0uality Control Reverification," Revision 1, September 21, 1987.

56. CCL Report No. A-719-86, " Test Report for Static Tests of Cable .

Trays and Fittings for Comanche Peak Steam Electric Station," July 1 3, 1986, Procedure No. 1903.20-1, Rev. 1.

57. CCL Report No. A-717-86, " Test Report for Honotonic and Cyclic Tests of Cable Tray Clamps for Comanche Peak Steam Electric. Station " June 27, 1986, Procedure No. 1903.22-1, Rev. 1.

58. CCL Report No. A-721-86, " Test Report for Additional Monotonic and Cyclic. Tests of Cable Tray Clamps for Comanche Peak Steam Electric Station," July 13, 1986,-- Procedure No. 1903.22-1, Rev. 1.

O v ,

6-4

lJ v

. 59. TV Electric Letter No. TXX 6631, H.G. Counsil.to U.S. Nuclear

( . ,

Regulatory Commission, Comanche Peak Programs, August 20, 1987.

]

60. TU Electric Engineering and Construction Procedure EC-9.04 '" Post Construction Hardware Validation Program," July 29. 1987.

. 1

61. Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Appendix D, CPRT Sampling Policy, Applications and Guidelines, Revision 1, January 31, 1986, and Appendix E, Resolution of Discrepancies Identified by the CPRT, Rev. 3, June 18.1987.

62. Ebasco Services, Inc. Nuclear Quality Asstrance' Program Manual As-adapted for the Comanche Peak SES Project No. ETR-1001, Rev. 6, July 10, 1987.

63. . Ebasco Document SAG.CP3 " Seismic Design Criteria for' Cable Tray l Hangers for Comanche Peak SES Unit 2," Rev. 9. July 1, 1987. j

64. TU Electric Letter No. TXX 6500, H.G. Counsil to U.S. Nuclear i Regulatory Commission, Comanche Peak Programs, June 25, 1987.

65. Impel) Project Quality Plan for TU Electric'CPSES Unit 1 Cable Tray,- )

Job Nos. 0210-040 and 0210-041, Rev. 3, September 16, 1987. j

66. U.S. Nuclear Regulatory Commission, Reg. Guide 1.64, " Quality q Assurance Requirements for the Design of Nuclear Power Plants,"

Q Rev. 2, June 1976.

67. TU Electric Engineering and Construction Procedure ECE 9.04-05, Post Construction Hardware Validation Program - Engineering Evaluations, Rev. O, September 1, 1987.

68. TU Electric Procedure ECS 5.01-15 " Verification and Maintenance of Cable Tray Loading," Rev. O. ,

i

69. TU Electric Procedure CPE-EB-FVM-CS-100, " Field Verification Method - Cable Tray Hanger Halkdown for Clamp Identification for Unit 1," Rev. O, September 9, 1987.

70. TU Electric Procedure CPE-SHEC-FVM-EE/ME/IC/CS-086 " Post Construction Hardware Validation (PCHV) Program Construction / Quality Control Reverification," Revision 1, September 21, 1987.

71. TV Electric Procedure CPE-SHEC-FVM-EE/ME/IC/CS-090 " Post Construction Hardware Validation (PCHV) Program Quality Control Reinspection," Revision 1, September 21, 1987.

O 6-5

,)- APPENDIX A  ;

i 4

COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL ISSUES

l. Introduction f This appendix contains a comprehensive summary of the Impell/Ebasco evaluation, resolution and corrective and preventive action for all 1 Comanche Peak Response Team (CPRT) and external issues which are related to the cable tray and cable tray hanger designs. Specific references to ,

the criteria, procedures, engineering studies and tests which have  !

resolved the issue are provided.

To report the resolution of the Comanche Peak Response Teem (CPRT) and external issues, an individual Subappendix was developed for each issue.

Each subappendix includes: a definition of the issue;. issue resolution; and corrective and preventive action.  ;

The issues contained in Subappendices Al through A34 are included in the CYGNA Energy Services (CYGNA) Review Issue List (RIL) Revision 141 . The issues contained in Subappendices 30 and 31 were initially raised by the .

Comanche Peak Response Team (CPRT)2 The issue contained in Subappendix j

,, 35 was raised by the NRC Technical Review Team (TRT) in Inspection Report 4

( ) No. 50-445/84-16. j The preventive action is embodied in the procedures developed and used in l the cable tray and cable tray hanger Corrective Action Program (CAP). i These procedures resolve all CPRT and external issues. Implementation of these preventive actions will assure that the design and hardware for CPSES Unit 1 and Common will continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4.

l ICYGNA, " Cable Tray Support Review Issues List (RIL) Comanche Peak Steam Electric Station Independent Assessment Program - All Phases," Rev.14, July 31, 1987, transmitted to TU Electric by CYGNA Energy Services in letter No. 84056.114 dated August 10, 1987.

2TU Electric Comanche Peak Response Team Action Plan, DSAP VIII, Civil / Structural Discipline Specific Action Plan, Rev.1, January 24, 1986.

b A-1

l 1

9..

X 1 k[ . APPENDIX A l COMANCHE PEAK RESPONSE TEAM'(CPRT) AND EXTERNAL ISSUES l

l Comanche Peak Response Team'(CPRT) and external issues' contained in.  !

Appendix A are listed below:

Subanoendix' Issue Title Al Controlling Load. Case for Design- i

'A2 Seismic Response Combination Method.  :

j 2

.A3 Anchor Bolt Design T-A4 Design of Compression Members A5 Vertical'and Transverse Loading on Longitudinal Type ,!

Supports . . -

. I A6 Support Frame Dead and Inertial Loads- .

A7 Design of Angle Braces Neglecting Loading Eccentricity A8 Dynamic Amplification Factors-(DAF), Tributary.' Tray Support Reactions and Missing Mass Effects 1 A9 Reduction in Channel Section Properties Due to Clamp l

Bolt Holes 4 A10 System Concept- -

1 All Validity of NASTRAN'Models i O

V A12 A13 Horking Point Deviation Study Reduced Spectral Accelerations A14 Non-Conformance with AISC Specifications- 1 A15 Member Substitution A16 Held. Design and Specifications A17 Embedded Plate Design i A18 Tray Clamps I A19 FSAR Load Combinations A20 Differences Between Installation and Design / Construction Drawings Without Appropriate Documentation A21 Design Control _.

A22 Design of Support No. 3136, Detail "5",' Drawing 2323-S-0905 A23 Loading in STRESS Models A24 Design of Flexural Members A25 Cable Tray Qualification A26 Base Angle Design-A27 Support Qualification by Similarity A28 Critical _ Support Configurationsand Loadings A29 Cumulative Effect of Review Issues

'A30 Cable Tray System Damping Values A31 Modeling of Boundary' Conditions A32 Conduits Attached <to Cable Trays or Supports A33 As-Built Halkdown Procedures em f.34 System Analysis' Methodologies C.- A35 Failure.to Properly Inspect Cable Tray Hangers (NRC NOV 50-445/8416-V-01).

A-2

gfi 4_

P SUBAPPENDIX Al CONTROLLING LOAD CASE FOR DESIGN ~(CYGNA ISSUE NO. 1)~

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.j 1.0 Definition of'the Issue e 4

This issue was'that by designing catalog items.for the OBE event only, ,

the manufacturer's design factor of safety may not have been maintained:

for the SSE event. . The original. design of cable tray' hangers assumed" that a 60% increase in SSE allowables was. applicable to all hanger.

components' rather than only to structural . steel as specified in Section ,

g 3.8.4 of the CPSES'FSAR (Reference 4.12). Catalog items do not have such, l increased allowables.for the SSE event.

2.0 Issue Resolution J The design validation procedures (References 4.4, 4.5,L4.6, 4.7 and 4'.10)L require that cable tray hangers be evaluated for the. effects of.0BE and.

SSE loads separately. Cable trays and' cable tray clamps are design- . l validated by comparison of the higher SSE, loads to the factored component i ultimate strength. The factors which have been used are' appropriate for both the OBE and the SSE level.of earthquake.' Subsequently, the. higher SSE loads are considered in the design validation of these components A- since the SSE loads represent the maximum cable tray system response to' the postulated design basis earthquake. Design validation procedures (References 4.1 through 4.6:and 4.8 through 4.10) contain appropriate allowables for all cable tray and cable tray hanger components including structural steel, welds, anchorages -Richmond Inserts and Hilti q Kwik-bolts.

3.0 Corrective and Preventive Action No additional issues were identified during the review'and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant. Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated 0ctober 21, 1986 from TU Electric to the NRC-(Also see Subappendix'B2).

3.1 Corrective Action Cable tray hangers have been design validated for the effects of.0BE and SSE loads separately.in accordance with the procedures.in References 4'.1-through 4.10. Appropriate OBE and SSE allowables were used for. cable -

tray system components including structural steel,' welds ~, anchorages, Richmond Inserts and'Hilti Kwik-bolts. ' Cable' trays and cable; tray clamps are design validated by comparison of the higher SSE loads to the ;

.. factored component ultimate' strength. .The. factors which have been used..

are appropriate for both the OBE and the SSE. level of earthquake.

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k. SUBAPPENDIX Al-3 . 2' Preventive Action The criteria requiring a separate evaluation of OBE and SSE loads for cable tray hangers'have been established and: documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.11). The criteria used for the design validation of- cable trays and cable tray.

clamps have also been established and documented'in the DBD. These'-

requirements have been included in the_ cable tray.and' cable. tray hanger.

design validation procedures (References 4.1 through 4.10).

4.0 References 4.1 -Impell Instruction PI-03, Qualification-of Cable Tray Supports,"

Rev. 5, October 20, 1987.

4.2 Impell Instruction PI-06, " Tray and Clip Qualification," Rev.1, October 20, 1987, with Addendum. dated 02/02/87.

4.3 Impe11 Instruction PI-07, " Design Verification of Base Plates,. Base Angles, and Embedment Plates," Rev. 3, September 16, 1986, with Addenda dated 01/07/87, 01/19/87, and 09/30/87.

V 4.4 Ebasco Document SAG. CP3 " Seismic Design Criteria.for Cable Tray-Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1, 1987, i

4.5 Ebasco Document SAG.CP4 " Seismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 1," Rev. 6. July.1, 1987.

4.6 Ebasco Document SAG.CP34 " General; Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No. 1 and 2," Rev. 11, August 27, 1987.

4.7 Impell Instruction PI-02, " Dynamic Analysis of Cable. Tray Systems,"

Rev. 6, October 15, 1987.

4.8 Ebasco Document SAG.CP18 " Procedure for Qualification of Cable Trays for Comanche Peak SES Units l'and 2," Rev. 3, October 30, 1987.

4.9 Ebasco Document SAG.CP19 " Design Criteria and Procedures for Design Verification for Cable Tray Clamps for Comanche Peak SES Units 1 and 2," Rev. 4, October 30, 1987. -

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4 SUBAPPEllDIX Al

, 4.10 Ebasco Document SAG.CP11 " System Analysis for Cable Tray and Hanger Assembly for CPSES Units 1.and 2," Rev. 4 July 1 1987.- q 4.11 Comanche Peak' Steam Electric Station No. 1 and 2 " Cable Tray;and' Cable Tray Hanger 4 Design . Basis Document," DBD-CS-082,. Rev.' 0, July.

31, 1987. ')

4.12 CPSES Units 1.and 2 FSAR, with current' amendments'.

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.h SUBAPPENDIX A2 jq SEISMIC RESPONSE COMBINATION METHOD (CYGNA ISSUE NO. 2) 1.0 Definition of the Issue A. This issue was that the response spectra analyses, performed for the i Horking Point Deviation Study in support of the original design, did- 1 not combine responses considering closely spaced modes as required by the CPSES FSAR (Reference 4.'l) and NRC Regulatory Guide.l.92 -

2 (Reference 4.8). j B. This issue was that the original design calculations combined the )

deadweight loading and the seismic loadings ~ using the SRSS method. 1 A 1.0g deadweight acceleration was first added to the' vertical l seismic acceleration. This sum was then. combined with the two-horizontal seismic components using the SRSS method.

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2.0 Issue Resolution A. The design validation criteria and procedures (References 4.2, 4.3, 4.5 and 4.6) require that the response spectra. analyses combine responses considering closely spaced modes in accordance with the CPSES FSAR (Reference 4.1) and NRC Regulatory Guide 1.92,(Reference O- 4.8).

B. The design validation criteria and procedures (References 4.2 through 4.6) require that the deadweight load be added separately to I the SRSS resultant of the three orthogonal seismic loads. Both  ;

deadweight plus the resultant seismic load and deadweight minus the resultant seismic load were evaluated in'the design.

4 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions.of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, .

1986 from TU Electric to the NRC (Also see Subappendix B2). I 3.1 Corrective Action The response spectra analyses that were performed for the design validation of cable trays and cable tray hangers combined closely spaced modes in accordance with the requirements of.the CPSES FSAR (Reference 4.1) and Reg. Guide 1.92 (Reference 4.8). The dead weight load has been

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.a combined with the seismic loads by t'aking the algebraic sum'of the dead weight load and both'the positive and negative sign of. the SRSS j combination of the three orthogonal seismic load components. ,

3.2 Preventive Action- 1

l The criteria requiring response spectra combination methodsLto account:

i for closely spaced modes and direct summation of deadweight loading plus l and minus the resultant seismic loads have been established and .

. .1 documented in the cable tray'and cable tray hanger Design Basis Document! 1 (Reference 4.7). These requirements have been included in;the cable tray and cable tray hanger design validation procedures (References 4.2 through 4.6).

4.0 References ,c l 4.1 CPSES Units 1 and 2 FSAR,-with current amendments'.

4.2 Impe11 Instruction PI-02, " Dynamic Analysis-of Cabl.e Tray Systems,"  ;

Rev. 6, October 15, 1987, O 4.3 Ebasco Document SAG.CP4 " Seismic Design Criteria for Cable Tray i t

d Hangers for Comanche Peak SES Unit.1," Rev. 6, July 1, 1987.

4.4 -Ebasco Document SAG.CP34 " General Instructions for-Cable Tray Hanger .l Analysis for Comanche Peak SES No. 1 and 2," Rev. 11, August 27,. J 1987. ]

i 4.5 Ebasco Document SAG.CP11 " System Analysis.of Cable Tray and Hanger. ]

Assembly for CPSES Units 1 and 2," Rev.'4, July 1, 1987.  ;

4.6 Ebasco Document SAG.CP3 " Seismic Design Criteria fcr Cable Tray 3 Hangers for Comanche Peak SES Unit 2 " Rev. 9. July 1, 1987. 1 4.7 Comanche Peak Steam Electric Station'No. 1 and 2 " Cable Tray and. ~!

Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. O, July 31, 1987.  !

4.8 U.S. Nuclear Regulatory Commission, Reg. Guide 1.92, " Combining Modal Responses and Spatial' Components in Seismic Response Analysis," Rev. 1, February 1976.  ;

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SUBAPPENDIX A3-ANCHOR BOLT DESIGN (CYGNA ISSUE NO. 3) t 1.0 Definition' of the Issue '

This issue was that. incorrect assumptions and inconsistent ' design-criteria may have been.used in the original design of the cable tray' .

hanger anchorages. Specifically: 4

_ Base e.ngle/ base. plate geometry was not evaluated.to determine.

appropriate anchorage stiffness land prying action factors. i OBE was considered as the governing load case _for anchorage design without; sufficient justification.

Anchorage designs'did not adequately consider as-built conditions'  ;

(i.e., anchor substitutions and installation tolerances). <

Anchorage designs may have used inappropriate anchor bolt design .  ;

allcwables (i.e., expansion anchors in diamond cored holes, one inch '

diameter Hilti Kwik Bolts, and Richmod Inserts in clusters).

Inconsistent use of the ACI 349 76 Appendix B design specification.

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2.0 Issue Resolution-This issue has been resolved by the following:

The design validation procedures (Referentes'4.2, 4.3, 4.7 and 4.8 and 4.12) require that cable tray hanger anchorages be evaluated considering anchorage stiffness'and the additional anchor bolt tension resulting from prying effects. The anchorage stiffness and prying action factors incorporated in the procedures were developed in engineering studies (References 4.5,~4.6, 4.9, 4.10 and 4.11) which considered as-built base angle / base plate geometries.

The design validation procedures (References.4.2, 4.7, 4.8, and

, 4.12) require the evt.luation of cable tray hanger' anchorages for the l effects of OBE and SSE loads separately. Design validation l procedures (References.4.3, 4.7.and 4.12) contain the OBE and SSE design allowables used for design validation'of anchor: bolts (Hilti Expansion Anchors and Richmond Inserts).

The design validation procedures (References 4.2, 4.3, 4.7. 4.8,'and 4.12) require the.use of as-built data for the design validation of cable tray hanger anchorages.

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'SUBAPPENDIX A3

The design validation procedures'(References 4.3, 4.7, 4.8, and 4.12) require the use of anchor bolt designLallowables.as provided 3 in the concrete embedment design specification (Reference 4.13). i The validation of these design allowables is discussed in detail in. l the Civil / Structural Corrective Action Program Project Status Report j (Reference.4.4).  !

The ACI 349-76 Appendix B design-specification is not a CPSES licensing commitment.for the design of concrete anchor bolts.; The j requirements for the design of concrete anchor' bolts are based on. 1 capacities determined from tests and utilize appropriate factors of safety. These requirements:are incorporated into the concrete ,

embedment design specification (Reference 4.13). .These criteria are i discussed'in detail in the Civil / Structural Corrective Action- A Program Project Status Report (Reference 4.4), j

'l 3.0 Corrective and Preventive Action No additional issues were identified during the review and. i resolution of this issue.

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This issue was determined to be reportable under the provisions of ,

10CFR50.55(e). It was reported as Significant Deficiency Analysis i

j Report (SDAR) CP-85-35 in letter. number TXX 6048,. dated October-21, 1 1986 from TV Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action The cable tray hanger anchorages have been design validated for both OBE' and SSE loads considering.the as-built geometry to determine appropriate -

stiffness, prying action factors and anchor 'allowables in accordance with the design validation procedures (References 4.2, 4.3, 4.7, 4.8, and 4.12).

3.2 Preventive Action i

I The criteria for design validation of cable tray anchorages have been )

established and documented in the cable tray and cable tray hanger Design  !

Basis Document (Reference 4.1). .These requirements are included in the cable tray and cable tray hanger design validation procedures (References.

4.2, 4.3, 4.7, 4.8, and 4.12).

• 4.0 Refereng11 4.1 Comanche Peak Steam Electric Station No. I and'2, " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev.0, O

July 31, 1987.  !

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() SUBAPPENDIX A3 I 4.2 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems," Rev. 6, October 15, 1987.

4.3 Impell Instruction PI-07, " Design Verification of Base Plates, Base Angles, and Embedment Plates," Rev. 3, September 16, 1986, l

with Addenda dated 01/07/87, 01/19/87, and 09/30/87.  !

4.4 TU Electric CPSES Unit 1 and Common, SWEC Civil / Structural Project Status Report, Rev. O. j 4.5 Impell Calculation M-04, " Base Angle Stiffness," Rev. 3 j July 20,1987.  !

4.6 Impell Calculation M-25, " Base Plate Prying Action Factors,"

Rev. 3, August 25, 1986.

4.7 Ebasco Document SAG.CP4, " Seismic Design Criteria for Cable .

Tray Hangers for Comanche Peak SES Unit 1," Rev. 6 July 1, l 1987.

n 4.8 Ebasco Document SAG.CP34, " General Instructions for Cable Tray j i Hanger Analysis for Comanche Peak SES No. I and 2," Rev. 11,

'v' August 27, 1987.

4.9 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 3,

" Prying Action," Rev 1, April 24, 1986.

4.10 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 11

" Concrete Compressive Stresses Under CTH Anchorage Shims and Base Plates," Rev. O, May 30, 1986.

4.11 Ebasco Comanche Peak Ses Cable Tray Hanger Volume I, Book 12 "CTH Anchorage Base Plate Flexibility Study," Rev. O, June 16, 1986.

4.12 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1, 1987.

4.13 CPSES Structural Embedments Specification No. 2323-SS-30, Rev. 2, June 13,1986.

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SUBAPPENDIX A4 DESIGN OF' COMPRESSION MEMBERS:(CYGNA ISSUE NO.'4) s 1 1 1.0 Definition of the Issue 7 A. This issue was that. original design-calculations used improper l _. ,h member. lengths-and end' conditions for. determining the: slenderness?  !

ratio of channel section compression. members in trapeze type hangers. ,

'B. This issue was.that original design: calculations for. determining.the' ,

slenderness ratio of compression members in. trapeze: hangers..did noti verify the effectiveness of in-plane _ sidesway. restraint;for various j designs.

C. This issue was that original design _ calculation's'for, cantilever l hangers used a distance from the concrete face to the. tray centerline for cantilever length, i.nstead of the distance.to.the:

outside clamp.

• Additionally, original.. design' calculations'forTdeterminingthe'. ,

slenderness ratio of members in cantilever hangers. assumed the cable'. H tray provided. lateral bracing at the: tray' clamp. location without i proper justification.

D. This issue was that for. trapeze hangers .. original design

calculations did not consider a reduction in section properties due to weld undercut at in-plane. brace.. attachment points.

E. Installation specifications allo ~w a tolerance'on p1'mbness u of vertical members. This issue was that the.effect of axial: load on' compression members due to out-of-plumbness-was'not-considered in' the original design.

F. This issue was that in the original . working point deviation: study,'a ,

reduced unsupported length for trapeze. hangers was used based on an-

, invalid assumption of rigidity.of the base angle leg. relative to L hanger.

G. This issue was that. original design calculations for~ braces in' . l compression found the highest load as a function of brace; slope, and' j checked for this slope without considering cases with . lower loads '

where capacity is reduced due to: longer member length.. .

l 2.0 Issue Resolution- ,

A. Design validation procedures(References 4,4, 4.11-and 4.21) provide- ~j requirements -for. the appropriate unsupported-lengths of cable tray j

/ hanger members to be used to calculate compression member '

i slenderness ratios (KL/R). Engineering studies have been performed j

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i tol establish effective length factors for cable' tray hangers

-representative of the installe'd. configurations.: Effective; length j factors'-("K values) for transverse trapeze type cable. tray hangersi

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were developed'in References 4'.5.and 4.6.These effective length j

factors are used in cable tray hanger validation in.accordance withz design validation: procedures (References 4.4,'4.8; 4.11 Land!4.21)..

Similarly, effective. length factors"for longitudinal trapeze type cable . tray hangers were developed in: References 4.5 'and 4.14.- These.

effective length factors are also used.in cable > tray. hanger designi validation in accordance with design validation procedures (References 4.4,.4.8,'4.11,l4.21).' Effective-length factors have been used'with appropriate unsupported member lengthsito calculate the slenderness ratios of compression members.

The provisions of Section l.8.4 of the AISC' Specification (Reference 4.22) have been applied in the following. manner:

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1) Classification of-a vertical post member.in a cable t' ray . hanger as a compression or tension member is based upon-the magnitude-of the axial load component. In. particulars if there:is any static compressive force or if the combined static plus; dynamic p

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load exceeds 50% of the design compressive. strength, the member is classified as a compression member. A maximum slenderness

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H ratio (KL/R) limit of 200 is applied to these members.

2) If a vertical post member is subject to static tension, and if the combined static plus-dynamic load doeslnot. lead to a'. '

compressive force greater than 50% of the' design. compressive 1 strength, the member is classified as a tension member. The. j maximum slenderness ratio (L/R) limit of 300 is applied to these members. ,

3) Regardless of the member classification, a full compressive  ;

stress check is performed in accordance with the AISC '

Specification for members subject to a compressive load  !

regardless of the magnitude' of the load and regardless of whether it is a static or dynamic load.- 1 A more detailed discussion of the slenderness ratio limits as applied to the CPSES cable-tray hangers is provided in References 4.4 and 4.7. ,

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, u-s SUBAPPENDIX A41 >

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B.t - Engineering studies (References 4.5,i4~.6:and.4.14)-have been .

i performed,to develop effective length:factorsffor. cable. tray hangers..-

representative of the installed configurations _._ Thesefstudiesl g .

include consideration ~of sidesway restraint foriboth..transverseLan'd.. -

longtitudinalstrapeze type hangers. mThese. effective {1ength~ factors. j are used.in! cable tray hanger validationLin.accordance with design , i validation procedures.(References 4.4,.4.8, 4.11,1and 4:21.)J(also; seejItem A'above);

i C. DesignLvalidationprocedures(Reference'4i4',[4'.8,?4511ahdI4121');'

provide requirements forfthe appropriate' unsupported length;off ,

hanger members to be.used to' calculate compression' member > H slenderness ratios. In addition, engineering studies have been .

H performed to develop: effective: length factors for cable tray l hangers) representative of.the installed configurations. :These effective.. . ,

-length factors are.used'in cable. tray hanger validation in

.accordance with design; validation procedures;(References /4'.4,14.8,3 4.11, and 4.21)~(also.see: Item A above).

c D. Reference 4.1, the Nuclear Construction: Issues Group " Visual: Weld J Acceptance Criteria" (VHAC), has been' accepted;by:the.NRC;for:use at l

l O CPSES. Helds not satisfying th'e VHAC: Undercut. requirement.

identified in' accordance with References 4.2'and'4.3, ..were,.

evaluated and,.where necessa'ry..-repaired..

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i E. Tests and studies performed by Impell/Ebasco'(References 4.12 and .

4.18) demonstrated that the two.(2)' degree out-of-plumbness +

tolerance for cable tray hangers'has no'effect on. design adequacy. . ,

Out-of-plumbness greater than.two (2) degrees._was noted on as-built - 1 hanger drawings per References'4.9, 4.15, and 4.16'and.was , .

i considered in design. validation as required in References 4.4~and ,

4.13.

F. In design validation, the appropriate. length of' cable tray hanger! ,

members was used as required in References 4.4, 4.11,4and 4.13 3 4 s

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G. The design validation of bracing members'has been performed using? l as-built information (References 4.4, 4.10, 4.11,:'4.13, and'4.20).. j 3.0 Corrective and Preventive Action _l i

No additional findings were identified during review and resolution- 1 of this issue. j u

-This issue was determined to be reportable'.under the provisio'ns of; 10CFR50.55(e).- It was reported'as Significant Deficiency Analysis ,

Report (SDAR) CP-85-35 in letter number TXX 6048 . dated October 21; j O- 1986 from TU Electric to the'NRC (Also see Subappendix B2).

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, m 3.1 . Corrective Action The cable ~ tray hangers have been design validated in;accordance withithe.

1 design validation procedures (Reference 4.4, '4. 8,l 4.10, . 4;11, 4 13, . ,

4.19 and:4.20): which require the use;of. as-built; corifigurationsifor1the des.ign.of; hanger: compression members. The procedures 8 provide the. , p. q requirements.for evaluation of member effectiveilength.andrslendernessi i 1

The cable tray. hangers have.been-inspected.per the Visual! Held:

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Acceptance Criteria (VHAC) (References 4.1, 4.2'and 4.3); Helds not?

1 satisfying the VHAC requirements.-have.been evaluated and, where: I necessary,' repaired.'

• 3.2 Preventive Action The cable tray and cable tray. hanger: design: validation; criteria have t been established and documentedlin the cable tray'and; cable tray hanger; Design Basis Document.(Reference'4.17).- These requirements:have been included in the cable tray hanger design validation procedures (References 4.4, 4.8,-4.10, 4.11, 4.13, 4.19, 4.20 and 4.21)'. j 4.0 References 4.1 NCIG-01, " Visual Held Acceptance Criteria," Rev. 2, May. 7.1985. .'

4.2 TU Electric Procedure, QI-QP 11.10-9, " Modification, . Rework abd l

'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1," Rev. 8, May.7, 1987.

D 4.3 TU Electric Procedure, QI-QP 11.10-2A, " Inspection of Unit'II Cable.

Tray Supports," Rav. 11, October 22, 1986.

4.4 Ebasco Document SAG.CP34 " General Instructions for Cable Tray-Hanger Analysis for Comanche Peak SES No. 1.and 2," Rev. 11, August 27, 1987.

4.5 Ebasco Comanche Peak SES Cable Tray Hanger Volume'I,. Book 6

" Buckling Study," Rev 2, July 24. 1987.

4.6 Impe11 Report 01-0210-1470, " Effective-Length Factors for Buckling '

of Cable Tray Supports," Rev. 1, May,'1986.

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4.7 Impell Report 09-0210-0018. " Slenderness Ratio Limits for CPSES :

Cable Tray Supports, Rev. O, May,1986.

o 4.8 Ebasco Document SAG.CP.9, " Instruction for.Re-Evaluation of. Cable;  :) ~

Tray. Hangers Affected by the Longitudinal Tie'of Transverse Hangers b to the Tray for CPSES Unit 2," Rev. O, March 17, 1986- .

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' 4.9 TU Electric Procedure CPE-FVM-CS-001, " Field' Verification ~ Method' <

Unit 1 Cable Tray Hangers As-Builting.and Design Adequacy -

. Verification. Program," Rev.'8' August 24, 1987.

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4.10 Ebasco Document SAG.CP4, " Seismic Design' Criteria.for. Cable ' Tray

. Hangers'for Comanche Peak SES Unit 1,".Rev. 6. July'1, 1987..

4.11 Impe11 Instruction PI-03,':" Qualification of.CableiTray Supportsd' Rev. 5, October 20, 1987.

4.12' Impell Report,- 09-0210-0017. "CPSES Cable Tray l Analysis / Test Correlation Final Report," Rev. O, February. 1987.

4.13 Impell' Instruction PI-02, " Dynamic' Analysis of Cable Tray Systems,"'

Rev. 6,- October 15.-1987.

4.14:Impe11 Calculation B-04, " Effective Length: Factors for. Longitudinal Cable Tray Supports," Rev.:0, July-23, 1987.

4.15 TV Electric Procedure TE-FVM-CS-036, " Field Verification Method

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ps As-Built Verification of Attachments to the-Main Structural V Framework in the Cable Spread Room-Supporting Unit;1-Designated-Cable Trays and Selected Attributes of Unit 1. Cable' Trays," Rev.;0,-'

February 19, 1987.

4.16 TU Electric Procedure TE-FVM-CS-003, . " Field Verification' Method' Unit ' ^

2 Cable Tray Hanger As-Builting.and Design Adequacy Verification Program," Rev. 2, November 21, 1986.

4.17 Comanche Peak Steam Electric Station No.1 and 2, " Cable Tray and Cable Tray Har.ger Design Basis Document," .DBD-CS-082, Rev. O, July 31, 1987.

4.18 Ebasco Comanche Peak SES Cable Tray Hanger Volume I,. Book 16

" Dimensional Tolerance," Rev. 2, June 18, 1987.

4.19 Ebasco Document SAG.CP11 " System Analysis for Cable' Tray and Hanger Assembly for CPSES Units 1 and 2," Rev. 4 July 1,.1987.

4.20 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray

' Hangers for Comanche Peak SES Unit 2 " Rev. 9, July!1, 1987.

- 4.21;Impell Instruction PI-11, " Cable Tray System Analysis-and-

. Qualification Closeout," Rev. 3, October 15, 1987.

4.22 AISC, " Manual of. Steel Construction," 7th. Edition including.

O Supplements 1,.2, and 3.

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SUBAPPENDIX A5 VERTICAL AND TRANSVERSE q LOADING ON LONGITUDINAL TYPE SUPPORTS (CYGNA ISSUE NO. 5) l 1

1.0 Definition of the Issue j The issue was that the calculations for longitudinal trapeze type cable f tray hangers (i.e. supports) considered only the longitudinal-loads in; the design. Since cable trays are rigidly connected to these. hangers with " heavy duty" three directional clamps, these hangers should have also been designed for the vertical and the transverse seismic cable tray- j loads.

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2.0 Issue Resolution 7 Design validation criteria and. procedures (References'4.1.through 4.5)'

require the simultaneous application of seismically induced loads in three orthogonal directions on all cable tray hangers.

3.0 Corrective and Preventive Action No additional issues were identified during the review and 'i Q

V resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1 1986 fron TV Electric to the NRC (Also see Subappendix B2).  !

3.1 Corrective Action l All cable tray hangers have been design validated for the simultaneous application of the seismically induced loads in the three orthogonal directions at; required in References 4.1 through 4.5.

3.2 Enymtive Action The design criteria requiring the simultaneous application of seismically induced loads in three orthogonal directions on all cable tray hangers have been ef;tablished and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.6). This. requirement has been included in the cable tray and cable tray hanger design validation.

procedures (References 4.1 through 4.5).

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SUBAPPENDIX A5 4.0 . References 4.1 Ebasco Document SAG.CP34. " General Instructions-for Cable Tray Hanger Analysis.for Comanche Peak SES No. 1.'and 2," Rev. 11, August 27, 1987.

4.2 Ebasco Document SAG.CP11. " System Analysis for Cable Tray and Hanger'-

Assembly for CPSES Units 1 and 2," Rev. 4. July 1 .1987.

4.3 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1,'1987'.

4.4 Ebasco Document SAG.CP4, " Seismic Design Criteria for Cable Tray-Hangers for Comanche Peak SES Unit 1," Rev. 6, July 1, 1987.

4.5 Impell Instruction PI-02, " Dynamic Analysis.of Cable Tray Systems,"

Rev.'6, October 15, 1987.

4.6 Comanche Peak Steam Electric Station No. 1 and 2 " Cable. Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev 0, July 31, 1987.

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( SUBAPPENDIX A6 SUPPORT FRAME DEAD AND INERTIAL LOADS (CYGNA ISSUE NO. 6) I 1.0 Definition of the Issue

.. 1 A. This issue was that the out-of-plane inertial loads (i.e.11oads .;

parallel to the cable tray) were not considered in the original design of transverse type cable tray hangers. This issue was also-that out-of-plane loads transmitted from transverse type cable tray hangers through cabis trays were not considered in member and I anchorage design for longitudinal cable tray hangers. H B. This issue was that the original design did not properly' consider the contribution of.the weight of the cable tray hanger members.

2.0 Issue Resolution A. Out-of-plane inertial loads due to cable tray hanger dead weight has. )

been considered in the design validation of all cable tray hangers j as specified in References 4.1 through 4.5. Further discussion is contained in Subappendix A18 regarding the distribution of load between hangers.

O v B. The entire cable tray hanger dead weight has been-explicitly and consistently considered in design validation as specified in References 4.1 through 4.5.

3.0 Corrective and Preventive Action No additional issues were identified during the review and' resolution of this issue.

This issue was determined to be reportable under the provisions.of 10CFR50.55(e). It was reported as Significant Deficiency Analysis-Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TU Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action Cable tray hanger design validation was performed considering the out-of-plane inertial loads and hanger dead weight as specified in References 4.1 through 4.5.

3.2 Preventive Action The design validation criteria and procedures (References 4.1 through 4.5) which specify the loads considered for cable tray hanger-design.

validation have been established and documented in the Design Basis

[. Document (Reference 4.6).

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, 3 SUBAPPENDIX A6 4.0t References-4.1 .Ebasco Document SAG.CP34,:" General. Instructions for_ Cable Tray.

l.

Hanger Analysis for. Comanche Peak SES No.1.and: 2," Rev. - 11, August 27, 1987.

4.2 Ebasco Document. SAG.CPil, " System' Analysis.for Cable Tray and-Hanger Assembly for CPSES Units 1;and'2," Rev 4,' July'l..1987;

4.3 Impell Instruction PI-02, " Dynamic Analysis-of-Cable Tray. Systems,"

l Rev. 6, October, 15,'1987.

4.4 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray.-

Hangers for Comanche Peak.SES Unit 2," Rev. 9, July l',11987.

4.5' Ebasco Procedure SAG.CP4, " Seismic Design Criteria.for Cable Tray Hangers for Comanche Peak SES Unit l~," Rev. 6, JulyL1,'1987.

4.6 Comanche Peak Steam Electric Station ~No. 1 and 2, " Cable Tray'and' Cable Tray Hanger. Design Basis Document," DBD-CS-082,:Rev..O, July 31, 1987.

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SUBAPPENDIX A7- .

DESIGN-0F ANGLE BRACES NEGLECTING' LOADING ]

' ECCENTRICITY '(CYGNA ISSUE NO. 7). J

];

1.0 ' ' Definition of' the Issue . '

a A. The. issue was that-in the' original l design the induced bending- 3 stresses in double angle braces due toieccentric end! connections. l were not considered,tand double angle braces.without filler plates j were incorrectly considered as< composite. members.

j; B. The issue was'th'at'.in the original design the' induced ~bendingL stresses in single angle braces.due to eccentric.end. connections j

1 were not considered, and. design calculations did not evaluate'the; design-stress considering the principal axesisection' moduli.

C. The. issue was that-in the original. design some' single angle brace..

designs for longitudinal. hangers provided welding on.one. leg.of:the-section, at opposite ends of.the brace, potentially resulting in .

twist buckling.

2.0 Issue Resolution O)

( A. The design validation procedures;(References 4.1 and 4.4) r0 quire that double angle braces be analyzed as composite members if the-requirements of AISC Specification 'Section 1~.18.2.4 (Reference 4.5)'

regarding intermittent filler plates are satisfied. 'The. design validation procedures-(References 4.1Lthrough 4.3)iconsider-eccentric member end connections on all' hanger members.

B. In addition to the resolution discussed in Item A above, the: design-validation requires that principal. axes flexural stress be. accounted 1 for in checking member stresses (References 4.1-through 4.3). '

C. Design validation (References 4.1 through 4.3) requires the ,

evaluation of the potential for flexural buckling, torsional i buckling, and combined torsional-flexural buckling resulting from eccentrically applied axial loads, q 3.0 Corrective and Preventive Action ,

No additional issues were identified during the review and 1 resolution of this issue. j q

This issue was determined to be. reportable under.the provisions of-  !

10CFR50.55(e). It was reported as Significant" Deficiency Analysis .

Report (SDAR) CP-85-35 in letter number'TXX 6048,-dated October 21,-  !

1986 from TU Electric to the NRC (Also;see Subappendix B2). .j A7 q

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-SUBAPPENDIX A7~

3.1 Corrective Action Cable tray. hanger angle braces.have'been design validated considering the effects of eccentric end connections, principal axes flexural stress, composite action of double angles, and torsional- buckling ascrequired in References 4.1 through 4.4.- '

i 3.2' Preventive-Action The. criteria requiring the evaluation:of principal axes. flexural stresses, effects of eccentric end connections, compositeLaction of.

double angles.and potentialttorsional buckling have been established and:

documented in the cable. tray-and cable tray hanger Design BasisLDocument'-

(Reference 4.6). These requirements have been included in the cable tray.

hanger design validation procedures-(References.4.1 through 4.4).

4.0 References t

4.1 Ebasco Document SAG.CP3'4 " General Instructions.for Cable Tray Hanger Analysis for Comanche Peak SES No. 1 and'2," Rev. 11 August 27, 1987.

4.2 Impell Calculation M-12, " Qualification Procedures for Cable Tray Support Evaluations," Rev. 4, October. 16, 1987.

4.3 Impell Instruction PI-03, " Qualification of Cable Tray Supports," u Rev.'5, October 20, 1987.

4.4 Impe11 Instruction PI-02, " Dynamic Analysis of Cable Tray-Systems,"

Rev. 6, October 15, 1987.

1 4.5 AISC, " Manual of Steel Construction," 7th Edition including  !

Supplements 1, 2 and 3. ,

4.6 Comanche Peak Steam Electric Station No.1 and 2. " Cable Tray and i Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. O, July 31,-1987.

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e-SUBAPPENDIX'A8

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DYNAMIC AMPLIFICATION' FACTORS-(DAF)i '

TRIBUTARY TRAY' SUPPORT REACTIONS "AND MISSING MASS' EFFECTS-(CYGNA ISSUE ^NO.-8)-

g.j 1.0 pefi ni tion ' of 'th'e ' Issue- '

' A .1 In the origina1Leablettray h' anger design which.used theLequivalent static method,-the cable tray; dead weight load on;a~ hanger (i'.e.,-

support) was: calculated by:Using the tributary span method.1 This; issue was that for. cable tray. hangers.' designed by the equivalent l..  ;

static method - the seismic load was? not increased to account;for az l dynamic amplification factor -(DAF). An; additional,effect which should have been considered.-is the ratio.of the static reaction for. '

a-continuous beam to the reaction calculated;by.the-tributary span-Lmethod, s B. This issue was that the original design' did not include the effects.

of the " missing mass" for higher frequency response.

2.0 Issue Resolutirn

! A. The design validation / procedures for cable trays and cable tray-hangers (References 4.1 through 4.'4 and 4.18-through 4.20). require the use of a 1.25'Multimode~ Response Multipliers (MRM), when the.

equivalent. static method is.used,-to. account for' dynamic-amplification effects and continuous system load distribution effects.

The validity of this multiplier has been. established by engineering studies ~ documented in References 4.5 through.4.15. Design validation procedures (References 4.I through 4.4 and 4.18 through .

4.20) were developed to assure the proper use of th.is. multiplier in l conjunction with spectral accelerations, tributary. cable ~ tray span '

i and hanger dead weight. ,

i Review procedures (References 4.4 and 4.19). and 'a load distribution ~  !

procedure.(Reference 4.3) were developed?to; properly analyze the cable tray system configurations for which the. engineering studies have shown that the l.25 MRM is not sufficient to account.for the o load distribution effects in. addition to the multiple mode effects..

1 B. The design validation procedures (References 4.1, 4.2, 4.16, and 1 4.18) require a missing mass correction for response spectra '

analyses performed for cable' tray hanger design validation.  ;

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1 SUBAPPENDIX AB

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3.0 Corrective and Preventive Action- q s '

No additional issues were' identified during the' review and resolution of this issue.- .

This issue was determined to.be reportable under the provisions of.

10CFR50.55 (e).- It was reported ast Significant Deficiency Analysis.

Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, j) 1986 from TU Electric.toithe NRC (also see Subappendix B2). ]

.1 3.1 Corrective Action  !

.1 A. In the design validation of cable tray hangers using the equivalents l static method of analysis, a 1.25 Hultimode. Response Multiplier' (MRM).was used (Reference 4.1 through 4.4 and 4.18 through 4.20).

B. For all cable tray hangers design ~ validated using the response.

spectra method a missing mass correction was' applied-(References.-

4.1, 4.2, 4.16, and 4.18 through 4.20) to' account for. higher frequency modes.

3.2 Preventive Action The criteria requiring consideration of dynamic amplification effects and.

continuous system load distribution effects in equivalent. static method analysis and consideration of missing. mass effects.in. response' spectra analysis have been established and documented in the Design. Basis Document (Reference 4.17). These requirements have been include'd in'the cable tray and cable tray hanger design validation procedures.(References 4.1 through 4.4, 4.16, and 4.18.through 4.20).

4.0 References ,

4.1 Ebasco Document SAG.CP4, " Seismic Design Criteria for, Cable Tray Hangers for Comanche Peak SES Unit 1," Rev.-6,~ July 1, 1987.

4.2 Ebasco Document SAG.CP3, " Seismic Design Criteria for. Cable Tray Hangers for Comanche Peak SES Unit 2," Rev. 9,' July'1,-1987.

4.3 Ebasco Document SAG.CP34 " General Instructions for.-Cable Tray Hanger Analysis for Comanche Peak.SES No. 1 and 2," Rev. 11, August 27,

~

1987. ,

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. . 1 4.4 Ebasco Document SAG.CP28 " Procedure for Screening ofLCable Tray; " -.

Hangers ~ to Assess .the Applicability of a ~l.25 MRM in Equivalent',

Static Method Analysis in Hanger Design Verification for Comanche

. Peak Steam Electric Station Units _ l_ and 2," Rev; .3, l August _19,1987.

'4.5 Ebasco. Comanche Peak SES Cable Tray Hanger VolumeLI, Book 9, . ,4

" Organization & Original Scope Summary. Report for MnM and Relatedi Load Distribution Studies," Rev;ci,) April 30 1987'- . .

-q 4.6 Ebasco Comanche Peak.SES' Cable Tray Hanger,; Volume I,_Booki9 ~Part 1 1, "Multimode Response' Multiplier. . Studies," Rev.'2, April 30,.1987; 4.7 Ebasco. Comanche Peak SES Cable Tray Hanger, Volume I,.. Book 9, Part; I ?) #

2, "Multimode : Response Multiplier -.' Studies," Rev.11, June :16.1986.

4.8 Ebasco Comarche Peak SES Cable Tray Hanger,_ Volume I, Book 9, Part.

3, "Multimode Response Multiplier - Studies',".Rev. 1,~ June 16,;1986.

4.9 Ebasco Comanche Peak SES Cable' Tray Hanger, Volume I, Book 9, Part 4 "Multimode Response Multiplier - Studies," Rev. 2,-l April:30, .1987.

O D 4.10 Ebasco Comanche Peak SES Cable Tray Hanger,-Volume I, Book 9, Part.

5. "Multimode Response Multiplier - Studies," Rev. O, April 10, 1986.

4.11 Ebasco Comanche Peak SES Cable' Tray Hanger, Volume I, Book 9,.Part

6. "Hultimode Response Multiplier at Stress Leval," Rev. 0, June 16, 1986.

4.12 Ebasco Comanche Peak SES Cable T. ray Hanger, Volume'I' Book-9, Part

7. "Multimode Response Multiplier for Cable Tray Clamps," Rev. 2, June 16, 1987. .,

4.13 Ebasco Comanche Peak SES Cable Tray Hanger, Vol'ume I,; Book 10, "Multimode Response Multiplier ~- Studies,"'Rev. 2 Apri1~30, 1987. (

4.14 Ebasco Comanche Peak'SES Cable TrayLHanger.lVolume I, Book _15

" Cable Tray Dynamic Load Redistribution Effects," Rev. 4, l October 30, 1987. l

't 4.15 Ebasco. Comanche Peak SES. Cable Tray Hanger,. Volume I,. Book 23,L"MRM.

Studies for an Actual. Complex CPSES Cable Tray.. System," Rev. 0,x April 30,1987. .;

I 4.16 Impell Instruction PI-02, " Dynamic Analysis of LCable Tray Systems,"

Rev. 6, October 15, 1987.

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.i SUBAPPENDIX A8L q

4.17 Comanche Peak. Steam Electric Station No. l' an' d 2', ." Cable Tray and -

Cable Tray. Hanger Design Basis Document'".DBD-CS-082, Rev. 0,-

July 31, 1987. )

1 4.18 Ebasco Document SAG.CP11, " System Analysis.for Cable Trayand Hanger- .;

Assembly;for Comanche Peak SES Units.1 and 2,." Rev. 4, July 1, 1987.

~

4.19 Ebasco Document. SAG.CP18,." Procedure'for' Qualification ~of. Cable-Trays:for Comanche Peak SES Units.11and.2," Rev. 3; October 30, 1987.-

i 4.20 Ebasco Document SAG.CP19, " Design' Criteria.and Procedures for Designi Verification of Cable Tray Clamps for Comanche Peak SES. Units 1:and 2," Rev. 4, October:30, 1987. .

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1 SUBAPPENDIX'A9-REDUCTION IN CHANNEL SECTION PROPERTIES DUE TO CLAMP BOLT HOLES (CYGNA ISSUE NO. 9) .J J

1.0 Refinition of the Issue j The issue was that the original design calcul.at. ions'for channels did not- y properly consider the reduction. in moment of inertia due to bolt holes, j as required by the AISC Specification (Reference 4.1). l 2.0 Issue Resolution l

Reduced member section properties resulting from bolt hol'es with a maximum size of 3/4 in. were developed'in References 4.3, 4.6, and.4.7.

These reduced properties developed in.accordance with the AISC Specification. were used in.the. design . validation of cable tray hanger . ,

tiers to account for the presence of both used and unused. bolt holes as' ]

required in References 4.2 and 4.4.

3.0 Corrective and Preventive Action l

No additional issues were identified during the-review and

, resolution of this issue.

This issue was determined to be reportable under the provisions of l 10CFR50.55(e). It was reported as Significant Deficiency. Analysis Report (SDAR) CP-85-35 in letter number.TXX 6048, dated October 21, l 1986 from TV Electric to the NRC (Also see Subappendix B2). )

l 3.1 Corrective Action l I Cable tray hanger tiers have been design validated using redu'ced section i

properties in order to account for the presence of bolt holes as required in References 4.2 and 4.4.

3.2 Preventive Action The criteria established in the cable tray and cable tray hanger Design j l Basis Document (Reference 4.5) and its referenced procedures (References 1 l 4.2 and 4.4) provide assurance that the reduction in section properties of cable tray hanger tiers due to bolt holes are accounted for in 1 accordance with the requirements of Reference 4.1.

4.0 References 4.1 AISC, " Manual of Steel Construction," 7th Edition including Supplements 1, 2 and 3.

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=SUBAPPENDIX A9 q I _. ,

5

=4.2 Ebasco Procedure SAG.CP34 "GeneraliInstructions for Cable Tray.-

Hanger Analysis,for. Comanche Peak SES No. 1'and 2," Rev. 11,'

August 27,'1987..

.4.3' Ebasco Comanche Phak SES Cable. Tray' Hanger. Volume I Book 25,- _

" Reduced Section Properties for' Channels," Rev. 0, February 24,.1987.

q

. 1 4.4 Impe11~ Instruction.PI-11; " Cable Tray System Analysis,and J Qualification Closeout," Rev. 3. October. 15, 1987.- 4 e

4.5. Comanche Peak Steam Electric Station'No.,1.and'2,." Cable Tray and H Cable Tray Hanger Design Basi s' Document, 'DBD-CS-082, Rev. -'0,

' July 31, 1987. ,

.q 4.6 Impell Calculation M-65, " Evaluation of^ Potential Bolt Holes.in Tier' 'I Members , Rev. : 2, July 16,1987.

l l 4.7 Ebasco Comanche Peak.SES Cable: Tray Hanger . Volume _I, Book 22, l " Statistical Analysis of Bolt Hole / Edge Distance in. Cable Trayi l Hangers," Rev. 1, October 23, 1987.

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SUBAPPENDIX A10 1

SYSTEM CONCEPT (CYGNA ISSUE NO. 10) )

b' 1.0 Definition of the Issue A. This issue was that the " system concept," which was used to justify s

the original cable tray hanger design, assumed.the. moments in the cable tray and the cable tray hanger are balanced.by load couples between adjacent cable tray hangers. _

y J

i B. This; issue was that in the " system concept," cable _ trays were assumed to provide lateral bracing for the' cable tray hangers with no justification. 1 I

C. This issue was that transverse and vertical loads wer'e not I

. considered for the original design of longitudinal trapeze type cable tray hangers. 3 i

D. This issue was that in the original cable tray hanger design, )

additional. tensile forces in anchor bolts due to the rotation of I base angles about.the bolt pattern axis were assumed to be minimized by the attached cable tray.. l E. This issue was that the. original longitudinal cable tray hanger design did not consider out-of-plane seismic inertial loads for trapeze type cable tray hangers.

F. This issue was that the original cable tray hanger design did not adequately address additional moments introduced by the eccentricity between the neutral axes of cable tray hanger tier members and post members joined in lap joint connections.

2.0 Issue Resolution A. The design validation of cable tray hangers was performed considering the loading eccentricities specified in References 4.1 through 4.7. Engineering studies (References 4.11, 4.12, and 4.16),

justify the modeling techniques contained in References 4.3 through 4.7. Behavior of cable tray clamps is discussed in Subappendix A18.

B. Detailed engineering studies developed effective length factors and established the effectiveness of bracing provided by the cable trays to the cable tray hangers. These studies are documented in' References 4.9 and 4.13. Design validation procedures (References 4.3 and 4.15) incorporated the results of the engineering studies._ .

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3 SUBAPPENDIX A10 LC. Cable tray hanger design validation was: performed considering.the ,

simultaneous application of seismically induced loads in three (3): 4 orthogonal' directions on each hanger as described _.in References.4.l~

Lthrough 4.6.

'D. Detailed engineering stu' dies-(References 4.14 and'4.17) developed-  :

, prying action' factors:and modeling procedures to-effectively account for anchorage eccentricities'and~ additional tensilecforces caused by.

anchorage rotation. Results of;these studies were incorporated into! ".;

the: design validation procedures;(

References:

4.3 and 4.7).:  !

4 E. Cable tray. hanger design validation was; performed consideringithe-simultaneous application ~of seismically induced loads in three (3) orthogonali directions on'.each ~ hanger as . described in;

References:

4.1: ,

through 4.6.- $

F. CabletrayhangerdesignvalidationwasLperformedconsideringLthe I hanger joint eccentricities:specified in. References ~4.1Lthrough t :i 4.7. Engineering studies (References 4.11,14.12 and:4.16) justify. 1 the modeli'ng techniques in References 4.3 through'4~7. .

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3.0 Corrective and Preventive Action-No additional issues were identified during theireview and-resolution'of this issue. l This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency! Analysis Report (SDAR) CP-85-35 in letter number TXX 6048,cdated October 21, 1986 from TV Electric to the NRC (Also see:Subappendix B2)..

1 3.1 Corrective Action n ,

Cable tray hangers and their components'were design validated using 1 procedures which require the simultaneous applicationfof' seismically ,

induced load in three,(3) orthogonal directions-(References ~4.1 through -

4.6). The procedures also contain requirements which reflect the'results.

of-engineering studies:(References 4.8, 4.9,;4.11 through4.14and?4.16) . '

which were performed to: 1) establish longitudinal', transverse, and vertical. load application methods and modeling techniques, 2) develop 1 effective length factors for cable tray. hanger members, 3)' assess the' p .,

effectiveness of cable trays in providing. lateral ~ support for hanger- '

l members, 4)-develop prying action factors for anchorages, and'5) develop '

modeling procedures to. effectively account for; anchorage eccentricities.

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.SUBAPPENDIX A10..

1 3.2. Preventive' Action' ,

The criteria... requiring consideration;of loading eccentricities, c- ,,

effective length factors,. simultaneous' application of_ seismically induced' loads in three (3)lorthogonal. directions prying action factors.:and-hanger joint eccentricities have been. established.and documented.:in .the -

cable tray and cable l tray hanger Design Basis. Document.-(

Reference:

4.10). 1

-These requirements.are inclu'ded.in.the-cable tray'and cable tray.. hanger

~~

-design validation procedures (References 4.1 through 4.7). ,. ,

4.0 4 References ,

4.1 Ebasco Prot:edure SAG.CP4', " Seismic Design Criteria for Cable Tray-Hangersfor: Comanche Peak SESiUnitL1,";Rev. 6, July 1, 1987.;

]j q

4.2 Ebasco Procedure SAG.CP3, '" Seismic Design Criteria: for:. Cable Tra'y I Hangers'for' Comanche Peak SES Unit 2," Rev. 9, July 1, 1987. l 4.3 'Ebasco Procedure SAG.CP34, " General: Instructions for Cable Tray Hanger Analysis for Comanche Peak SES'No.-1 and.2," Rev. 11, August 27, 1987.  : e 4.4 Ebasco, Procedure SAG CP9, " Instruction for Re-Evaluation of Cable.

Tray Hangers Affected by the Longitudinal Tie of Transverse. Hangers to the Tray for CPSES Unit 2," Rev. 0, March 17, 1986..

4.5 Ebasco Procedure SAG.CPil,'" System Analysis for' Cable Tray and Hanger Assembly for CPSES Units 1 and 2," Rev. 4, July'.1, 1987. ,

4.6 Impe11 Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"

Rev. 6, October 15, 1987.

4.7 Impe11 Instruction PI-07, " Design Verification of Base Plates', Base Angles, and Embedment Plates," Rev. 3, September 16, 1986 with Addenda dated 01/07/87, 01/19/87, and 09/30/87. .

4.8 Impe11 Calculation M-12. " Qualification Procedure for- Cable. Tray.

Support Evaluations," Rev. 4, October 16, 1987.

4.9 Impell Report 01-0210-1470,." Effective-Length Factors'for Buckling-of Cable Tray Supports," Rev. 1, May 1986.

J 4.10 Comanche Peak Steam Electric Station No.1.and 2, " Cable . Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. 0,. 1 July 31, 1987.

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-SUBAPPENDIX A10.

4.11 Ebasco Comanche' Peak ~SES Cable Tray Hanger Volume I, Book 2,-

" Computer Related Information,".Rev. 3, July 11, 1986.

4.12'EbascoComanchePeakSESCable.TrayHangerVolume:I,:Bobk7,i" Cable Tray Hanger Load Application Studies,".Rev. 1, February 20, 1986.

4.13 Ebasco Comanche Peak SES. Cable Tray Hanger Volume I,. Book 6, l '" Buckling l Study,".Rev. 2, July 24, 1987.:

4.14 Ebasto-Comanche' Peak'SES Cable' Tray Hanger Volume'I, Book 3, " Prying' .

Action," Rev. 1,' April 24, 1986. j 4.15 Impell Instruction PI-03, " Qualification.of Cable Tray ' Supports,'

Rev. 5, October 20, 1987.

4.16'Impell Report 09-0210-0017 "CPSES' Cable. Tray Analysis / Test Correlation Final Report," Rev. 0,- February 1987.

4.17 Impell Calculation M-25, " Base Plate Prying Action Factors, Rev. '3, August 25, 1986.  ;

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'SUBAPPENDIX All '

l VALIDITY OF NASTRAN MODELS(CYGNA ISSUE NO.~ 11)'

1.0 Definition of the' Issue This issue was that the NASTRAN models used in support of the origihal-cable tray hanger design may not have included sufficient variation (in i hanger type and tray span) to. represent'as-built conditions. 1 2.0 Issue Resolution The NASTRAN models discussed above were not used in:the cable tray and q cable tray hanger design validation. Design-validation.was'. performed: l using as-built hanger configurations and span lengths in accordance-with  ;

the design validation procedures-(References 4.1:through,4.4). j i

3.0 Corrective and Preventive Action No additional issues were identified during review and resolution of' this issue.

This issue was determined to be reportable under:the provisions.-of O 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21,

{

1986 from TU Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action Cable tray and cable tray hanger design validation was performed using as-built hanger configurations and span lengths in accordance with the procedures (Reference 4.1 through 4.4). .The engineering studies, used.'to develop the design validation procedures, are representative of actual plant configurations.

3.2 Preventive Action i The criteria requiring the use of as-built hanger configuration and span lengths for. design validation have been established and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.5). l This requirement has been included in the cableLtray and-cable tray hanger design validation procedures (References 4.1 through 4.4)'.

4.0 Rftferences j 4.1 Ebasco Document SAG.CP4, " Seismic Design Criteria for Cable Tray  :

Hangers for Comanche Peak SES Unit 1," Rev. 6. July 1, 1987.

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SUBAPPENDIX All__

-q 4.2 :Ebasco Document SAG.CP3, " Seismic' Design Criteria for Cable Tray" ,

' Hangers for Comanche Peak'SES Unit 2," Rev. 9, July 1.L1987. < ,)

4.3 -Ebasco Document SAG.CP34 " General Instructions-for Cable Tray Hanger l Analysis for Comanche Peak SES No. I and 2," Revision 11'1 August 27;.

1987.

1 4.4L Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,".

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')

Rev '6, October. 15,-1987. j

'1 4.5 Comanche Peak Steam Electric Station.No. 1 and.2 " Cable' Tray and i

Cable Tray Hanger Design Basis Document,".DBD-CS-082, Rev. 0,.

> July _31, 1987.

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.,h SUBAPPENDIX A12_

HORKING POINT DEVIATION STUDY (CYGNA' ISSUE NO. 12) 1.0 Definition of the Issue This issue was.that the " Working Point Deviation Study." which was intended to provide. allowable tolerances on the working point locations.

for the original cable-tray hanger; designs..(i.e., account for:

eccentricities at connections which were not considered in the. original design) may not have included sufficient variation'(including hanger 1 type, tray type',' number of trays) to represent the as-built configuration. Additionally, sufficient justification was: not'provided in the study for modeling assumptions (such as. tray and hanger boundary R conditions and tray / hanger connectivity) or for selection of particular ' l '

hanger configurations and components.to develop' general working' point:

location tolerances.

2.0 litte Resolution Results of the "Horking Point Deviation Study" were.not used.in the design validation of cable tray hangers. . Cable tray hangers have been design validated using as-built configurations in accordance with the

/7 design validation procedures (References 4.1 through.4.6). These . .

U procedures provide the requirements for consideration'of eccentricities l at connections (i.e., work point locations).

3.0 Corrective and Preventive Action i No additional issues were identified during the review and resolution of this issue.

1 This issue was determined to.be reportable under the provisions of  !

10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TV Electric to the NRC (Also see.Subappendix B2).

3.1 Corrective Action Cable tray and cable tray hanger design validation was performed using as-built data in accordance with the procedures (References 4.1 through' 4.6).

3.2 Preventive Action The criteria requiring the use of as-built. data for' cable tray hanger .

design: validation have been established and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.7). .This requirement.has been included in the cable tray and cable tray hanger O design validation procedures (References 4.1 through 4.6).

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.SUBAPPENDIX A12, j

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4.0 References q

4.1' ' Ebasco Document SAG.CP34, "GeneraliInstructions for; Cable Tray.

Hanger Analysis'for Comanche Peak (SES No. 1 and 2," Rev. 11,.

~ .)

August 27,.1987. ,

4.2 Impell. Instruction PI-02,;" Dynamic Analysis of Cab 1'e Tray Systems;"; '

<l Rev. 6. October 15, 1987.'

c,"i L4.3 Impe11 Instruction PI-03, " Qualification of' Cable' Tr' y. a Supports, o. .

Rev. 5, October 20, 1987.

- 4 j, 4.4 Impe11 Instruction PI407, " Design Verification of.BaseiPlates,: Base-

' Angles, and' Embedment Plates,": Rev. 3,? September:16,1986, with. .

)

Addenda dated 01/07/87,l01/19/87,;and_09/30/87.- 1 4.5 Ebasco Document SAG.CP3,'" Seismic Design Criteria for' Cable Tray.

Hangers for Comanche Peak SES Unit 2," Rev.l9, July 1,.1987... A  ;

j 4.6 Ebasco Document SAG.CP4, " Seismic Design Criteria 1for Cabl' e Tray-Hangers for. Comanche Peak SES Unit.1," Rev. 6 July 1,11987.

4.7 Comanche Peak Steam Electric Station No.1 and 2, " Cable. Trayand-Cable Tray Hanger Design Basis Document," OBD-CS-082,_Rev.-0.. '] '

July 31, 1987.

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REDUCED SPECTRAL ACCELERATIONS (CYGNA ISSUE NO. 13) 1 1.0 Refjnition of the Issue -1 The issue was that reduced seismic accelerations were used.in the ,

original design. based on, calculated frequencies of cable tray system -  !

models which were not representative of as-built configurations. '

2.0 Issue Resolution. I Results of the original design calculations which used reduced spectral accelerations were not used in design validation. Cable' tray-hanger ,

design validation procedures-(References-'4.1, 4.2, 4.4. 4.5 and 4.7) i require the use of as-built data as design input. Appropriate seismic a: celebrations are now determined for each cable tray and cable tray hanger using as-ballt data. As-built data include actual ^ cable tray ,

spans, cable tray weight (per Reference 4.10), and eccentricities between I the cable' trays and cable' tray hangers. Engineering studies (References-4.3, 4.8, 4.9 and 4.11).were performed to generate the~ anchorage stiffnesses and load application techniques used for cable. tray hanger design validation. '

3.0 Corrective and Preventive Action No additional issues were discovered'during the review and ,

resolution of this issue,. i This issue was determined to be reportable under'the provisions of-10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B2).,

3.1 Corrective Action Cable tray and cable tray hangers have'been design validated using as-built conditions including cable tray spans-and weight,. axial tray stiffness, cable tray and cable tray hanger eccentricities, and anchorage flexural stiffness-in accordance with the design validation procedures ,

(4.1, 4.2, 4.4, 4.5 and 4.7).  ;

3.2 Preventive Action The criteria requiring the use of as-built data for design validation has been established and documented in'the cable tray and cable tray hanger  ;

u)

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Sj)1 APPENDIX A13 h

Design Basis Document (Reference 4.6). These requirements'have been.

, included in the cable tray and cable; tray hanger design validation

-procedures (References 4.1, 4.2, 4.4, 4.5,'and 4.7).

4.0 References 4.1- Ebasco Document SAG.CP4, " Seismic Design ~ Criteria for. Cable Tray '

Hangers for Comanche Peak SES Unit 1," Rev. 6, July 1, 1987.-

4.2 Ebasco' Document SAG.CP34, " General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No.1 and 2," Rev.11, August 27, 1987.

4.3 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book-2,

" Computer Related Information," Rev. 3. July 11, 1986.

4.4 Ebasco Document SAG.CPil, " System Analysis for Cable Tray and Hanger Assembly for CPSES, Units 1 and 2," Rev.4, July 1, 1987.

4.5 Impe11 Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"-  !

Rev. 6. October IS, 1987.

4.6 Comanche Peak Steam Electric Station No. I and 2. " Cable Tray and Cable Tray Hanger Design Basis' Document," DBD-CS-082, Rev. O, July 31, 1987.

1 4.7 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray -

Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1, 1987.

4.8 Ebasco Comanche Peak SES Cable Tray Hanger, Volume I, Book 7. " Cable j Tray Hanger Load Application Studies,"' Rev.1, February 20, 1986. l 4.9 Ebasco Comanche Peak SES Cable Tray Hanger,' Volume I, Book 12. "CTH Anchorage Base Plate Flexibility Study," Rev. O, June 16,-1986. j 4.10 CPSES Cable Schedule 2323-EI-1700, " Report Section 30 - Raceway Percent Fills," December 3, 1985.

4.11 Impell Calculation M-04, " Base Angle Stiffness," Rev. 3. July 20, 1987.

4

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~Q SUBAPPENDIX A14

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1 NON-CONFORMANCE WITH AISC SPECIFICATIONS (CYGNA ISSUE NO. 14) 4 1.0 Definition of the Issue This issue was that the design of cable tray hangers.did not conform to. I the AISC Specification (Reference 4.1) requirements as summarized below:

A. The slenderness ratio limit of 200 for cable tray hanger compression )

members, may have been exceeded.

I B. AISC equation 1.5-7 for determining bending stress 'allowables in i

! channels was improperly used.

C. Reductions in section properties of beams due to bolt holes 1in flanges were not' considered.

1 D. Double angle braces were designed as composite members, but adequate J filler plates were.not provided.

E. Design'of cable tray hangers using single angle braces did not-consider connection eccentricities. <

U F. Oversized bolt holes were used for anchor bolts and tray clamps  !

without adequate justification.

G. Longitudinal braces may have been improperly. designed for compressive stress as a secondary member. i l H. Cable tray hanger members, subjected to axial and flexural loads, may not have been properly evaluated in accordance with the AISC Specification. '

2.0 Issue Resolution The design validation resolved these issues in accordance with the AISC Specification as follows:

A. The provisions of Section 1.8.4 of the AISC. Specification have been J applied in accordance with the design validation procedures-(Reference 4.4 and 4.7) in the following manner:-

1) Classification of a vertical post member in a cable tray hanger as a compression or tension member is-based upon the magnitude i of the axial load component. In particular, if there is any .  :

static compressive force or-if the combined static plus dynamic ,

load exceeds 507. of the design compressive strength, the member is classified as a compression member. A maximum slenderness

i. ratio (KL/R) limit of 200 is applied to these members.

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-2)- If a-vertical post member is subject toistatic tension, Land 1fI the combined' static plus-dynamic load.does~notLlead to au * ,

compressive force greater than 50% of'the design compressive 1 strength,'the member is classifled as'a. tension' member. The.

maximum. slenderness ratioL(L/R) limi.t of 300.'is;appliedito thesel i members.

3) 'Regardless..of;the~ member classification, a'fullicompressivei stress. check-is performed'in~accordance.wi_th the AISCt ' H' Specification lfor members. subject to a compressive, load.. . 'o ,

regardless of the magnitude of the:. load and regardlessfof? o whether it is-a static or dynamicLload.~'

A more detailed discussion of-the slenderness ratio limits'as' applied to the CPSES cable:. tray hangers'is provided in~ References 4.4 and'4.8 (also see.Subappendix A4).

B. The design validation procedures (ReferencesL4.4, 4.7.and:4112); '

require the appropriate use'of'AISC Eq. l'.5-7 for. validation of cable tray hanger channel members..

O C. Reduced member section properties resulting:.from bolt holes with a .

maximum size of 3/4 in., were-developed.in References 4.5', 4'.15,'and.

4.16. These reduced properties, in accordance with th'e AISC' Specification,. were used in the design validation of tcable tray 1 j hanger tiers to. account for the' presence of-both used and unused; j bolt holes as required in-References 4.4 and 4.12.- ,

j D. The design validation procedures ~(Referen'ces 4.4 and 4.6) require a that double angle braces be analyzed'as composite ' members if the'. .

requirements of AISC' Specification Section'.1..18.2.4 regardingl l intermittent filler plates are satisfied. '

j E. Eccentricities have been considered' as specified'in References' 4.2, ,

4.3, 4.4 and 4.6 in the design' validation ~of.all cable' trays and l cable tray hangers. ~

F. The effects of oversize bolt- holes have been evaluated .through the use of analytical methods and. test data.: This evaluction'has confirmed that the methodology used in the. designi validation is' ,

appropriate'(also see Subappendix A31).-

.i References 4.9 and 4.10 have'shown that oversize bolt holes had an'  !

insignificant effect on cable tray system dynamic characteristics: '

and seismic response. It'was demonstrated that'the-same modeling-

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SUBAPPENDIX A14 g procedure was. appropriate.'whether.or.not oversize. bolt holes were-present. References.4.11 and 4.14 are. engineering studies which ~

' demonstrated' that anchorage design margin is not significantly affected by the presence'of oversize bolt holes.

s G. The design validation procedures (ReferencesL4.4.and 4.71 require l that all bracing members be validated using'AISC Specification j primary member stress allowables. .3 a

H. The'designvalidation' procedures (ReferencesI4.2,'4.3,and4.7)- d require that members subjected to axial and bending 11oads,be- i evaluated in accordance with the AISC Specification.

]

3.0 Corrective and Preventive' Action No additional: issues.were identified .during the review.and resolution of this issue.

This issue was determined to be reportable under'the' provisions of- 1 10CFR50.55(e). It was reported as Significant Deficiency Analysisi j Report (SDAR) CP-85-35 in letter. number TXX 6048, dated October 21, . '1 1986 from TU Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action s ,

Cable tray hangers have been design validated in.accordance'with th'e.AISC Specification using appropriate limitations, equations and applications, l) including those discussed in Section 2.0 of- this subappendix. ' '

3.2 Preventive Action

. . i The criteria requiring adherence to the AISC Specification, including the applications discussed in Section 2.0, have'been established =and-documented in the cable tray and cable tray hanger Design Basis Document' (Reference 4.13). These requirements have been included in the cable-  ;

tray hanger design validation procedures (References'4.2, 4.3, 4.4,~4~.6.- , i 4.7, and 4.12).

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4.0 References  ;

4.1 AISC, " Manual of Steel Construction," 7th Edition including.

Supplements Nos. 1, 2 and 3. g 4.2 Ebasco Document SAG.CP4 " Seismic Design- Criteria for Cable Tray 1 ,i Hangers for Comanche Peak SES Unit 1," Rev.! 6, July 1,1987. l 4.3 Ebasco Document SAG.CP3 " Seismic Design Criteria'for Cable Tray

'O Hangers for Comanche Peak'SES Unit 2," Rev. 9, July 1. 1987.

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c4.4 Ebasco Document. SAG.CP341" General Instructions' for! Cable cTray Hanger l Analysis for. Comanche Peak SES No.-1 andl2;".Rev. 11,. August 27 - a 1987. J 4.5 Ebasco Comanche Peak'SES Cab 1e Tray Hanger Volume;I,-Book'25,. t '

" Reduced.Section Properties for. Channels',".Rev. O, February 24, 1987.  ;

4.6: Impe11 Instruction PI-02, " Dynamic. Analysis of ~ Cable _ Tray Systems,":

Rev. 6, October- 15,~1987, t-4.7. Impe11 Instruction ~PI-03,'" Qualification of; Cable Tray Supports,"

Rev. 5 October 20. 1987.:

v.

1 4.8 Impell' Report 09-0210-0018.. " Slenderness Ratio Limits for CPSES - l Cable. Tray Supports," Rev. O, May,1986.' . '

. . 1 4.9 Impell. Report 09-0210-0017, "CPSES: Cable' Tray: System Analysis / Test j Correlation Final Report," Rev.t0, February,'1987. R 4.10." Final Summary Report - Comanche Peak Cable Tray Tests " Rev.-1,1 ,

May 1987 . Prepared by ANCO Engineers. ,

q 4.11 Impell Calculation M-73, " Acceptability ofL0versized Bolt Holes,"

Rev. O,' June 22, 1987. _,

4.12 Impe11 Instruction PI-11 " Cable Tray System Analysis'and

~

Qualification Closecut,"'Rev. 3, October 15,,1987.

4.13 Comanche Peak Steam Electric. Station'No.~1 and 21" Cable Tray andi> j Cable Tray Hanger Design Basis Document,":DBD-CS-082, Rev.(0,. 1 July 31, 1987.

4.14 Ebasco Position Paper-TO Electric, Comanche : Peak Steam Electric Station Units -1 and 2, " Effects'of Bolt Hole Oversizes in CTH and-Conduit SystemLAdequacy,".Rev. 4, October 16, 1987. :1 4.15 Impe11 Calculation M-65, " Evaluation of Potential Bolt Holes in Tier-Members," Rev. 2, July 16, 1987. q

. . . i 4.16 Ebasco Comanche Peak SES Cable Tray Hanger Volume:I,-Book'22, j

" Statistical Analysis of Bolt Hole / Edge Distance in Cable' Tray - .J Hangers," Rev. 1, October 23, 1987. '

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( SUBAPPENDIX A15 MEMBER SUBSTITUTION (CYGNA ISSUE NO. 15) 1.0 Definition of the Issue This issue was.that the original cable tray hanger installation specification allowed the substitution of a structural member with' lower section moduli for members specified by.the design. Documentation of member substitutions'was inadequate.

2.0 Issue Resolution 1

The cable tray hanger design validation procedures (Reference 4.1 and <

4.2) require the use of as-built information for design validation. . 'In addition, an engineering' study was performed-(Reference 4.5) which!

determined the acceptability'of using-the as-designed member. size when 'j the as-built size was inaccessible. The results of the study were. l incorporated in'the design validation procedures (References 4.1 and 4.2). Member substitutions that. may have resulted in lower-section moduli are accounted for in these procedures.

3.0 Corrective and Preventive Action

-* No additional issues were identified w'hile resolving-this issue.

This issue was determined to be reportable under_the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048,' dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action Cable tray hangers have been' design validated using member sizes.

obtained from as-built hanger drawings in accordance with design validation procedures (References 4.1, 4.2, and 4.3). The. design validation procedures for members which were inaccessible conservatively considered the permitted member substitutions that resulted in design validated member sizes having lower section moduli. ,

3.3 Preventive Action The criteria requiring that as-built member sizes be used for design i validation have been established and documented in the cable tray and cable tray hanger Design. Basis Document (Reference 4.4). These requirements have been included in the cable tray and cable tray hanger  ;

design validation procedures (References 4.i through 4.3) ano evaluate the originally permitted member substitutions when the member is

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SUBAPPENDIX A15-

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-inaccessible. InLaddition, the validat'ed cable. tray hanger installation:

specification,-2323-SS-16B (Reference.4.6), and inspection-procedures'

(References ~4.7 and 4.8) assure the installation of the member size.

. required by'the design and does not permit member substitution.

4.0- References a d 4.1 Impe11 Instruction PI-11. " Cable Tray System Analysis andl Qualification Closecut," Rev. 3, .0ctober 15,1987. .

4.2 Ebasco Document SAG.CP34, " General 1 Instructions for Cabli Tray .

HangersAnalysis for' Comanche Peak SES No.: .1'and 2," Revision'11, ,j August 27,-1987. <

l q

4.3 Impe11 Instruction PI-02, " Dynamic AnalysisTof Cable Tray Systems, .

.Rev. 6, October 15, 1987.-

4.4 Comanche Peak Steam Electric Station No. l'and 2,." Cable Tray and Cable Tray Hanger. Design Basis Document,"'DBD-CS-082, Rev. 0, July 31, 1987. q 4.5 Ebasco Comanche-Peak SES' Cable Tray Hanger Vol'ume I, Book-l'8,-

" Hidden Attributes,"' Rev.1, September 30, 1987'- . . ,

4.6 CPSES Unit 1 and 2, Specification 2323-SS-16B, " Structural Steel / Miscellaneous Steel-(Category.I and II)," Rev.:1, July 114,<

1987.

4.7 TV Electric Procedure QI-QP-11.10-9, " Modification, . Rework,- and- . . _

l

' As-Built' Inspection / Verification Lof Cable' Tray Hangers in' Unit..1," '

Rev. 8, May 7.' 1987.

1 4.8 TU Electric Procedure, QI-QP-11.10-2A, " Inspection of. Unit'II Cable' 1 Tray Supports,"'Rev. 11, October 22, 1986'.'

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j SUBAPPENDIX A16 1

HELD DESIGN AND SPECIFICATIONS (CYGNA ISSUE NO. 16)

]

1 i

1.0 Definition of Issue A. Tnis issue was that weld details were not provided on the original 1 design drawings for several cable tray hangers.

B. This issue was that weld sizes shown on the original' assembly drawings differed from those on the design drawings and those used  ;

in the original weld calculations. -

C. This issue was that eccentricities were not considered in the l original design of welded connections.  !

l D. This issue was that. base metal thicknesses of connected members were not considered in the original weld designs. Specific designs may have considered excessive weld throat.

E. This issue was that original design calculations assumed an incorrect minimum weld length for beam / hanger base angle connection l because the radius of the angle leg was neglected.

i F. This issue was that several cable tray hangers were found to have l welds which violated the minimum weld size requirement as specified by the AISC Specification (Reference 4.5).

G. This issue was that several cable tray hanger designs employed composite sections joined using intermittent fillet welds which were not evaluated in the design calculations.

H. This issue was that original cable tray hanger design calculations did not evaluate the welds used to attach base angles to embedded plates.

I. This issue was that the cable tray hanger calculations evaluated partial penetration groove welds assuming configurations that may not be representative of as-built conditions.

2.0 Issue Resolution A. The design validation of cable tray hanger welds was performed using as-built weld data as required in References 4.1 through 4.3, and 4.6. As-built hanger drawings have been developed for each cable tray hanger.

B. Design validation of hanger welds considered as-built data as

(~] discussed in Item A above.

V A16-1

SUBAPPENDIX A16'.

C. Design validation procedures (References 4.1 through 4.3 and 4.6),

which were established by engineering studies (Reference 4.9) using as-built data, address the effects of eccentric-loads on welds.

D. The design validation procedures (References 4.1 through 4.3 and 4.6) were developed in accordance with the AISC Specification and:

require appropriate consideration of base metal thickness.

E. Design validation of hanger welds considered as-built data as discussed in Item A above.

F. The cable tray hanger welds'were installed per the CPSES welding procedure (Reference 4.8) which. complies with the requirements of AWS D).1-79.(Reference 4.7) and provides assurance that weld sizes greater than or equal to 1/8 inch have' structural integrity.

G. The design validation procedures (References 4.1 through 4.3 and 4.6) require welds, including intermittent. fillet welds connecting ~

components of a composite section, to be design . validated using as-built weld data.

(^)

V H. The design validation procedures (References 4.1 through 4.3 and-4.6) require welds, including welds between base angles and embedded plates, to be design validated using as-built weld data.

I. Since the weldability and joint accessibility conditions of the prequalified weld test (Reference 4.8) and the~ weld of a 30* minimum angle joint of gusset plates are equivalent,.the prequalified test results are applicable to both weld conditions.. Therefore, the cable tray hanger calculations are based on weld configurations that are representative of the as-built conditions, j 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, j 1986 from TU Electric to the NRC (Also see Subappendix B2). . '

3.1 Corrective Action Cable tray hanger welds have been design validated using as-built' data, including weld length and size, in accordance with References 4.1 through Al6-2

_ _ _ - - - - - _ - _ - _ - - - _ - - - _ _ - . - - - _ - . - - - _ _ _ - - - - - - - - - - -- l

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I 4.3 and:4.6. Design validation procedures require appropriate: . . . ,

}j consideration of base metal thickness, . effects ofl eccentricities,: and

~

lprequalified partial penetration welds. - ,:

3.2~ Preventive Action--

The criteria requiring;the use of as-built' weld dataLfor design input' 1 have been established and documented in the cable tray and cableLtray. j hanger: Design Basis Document (Reference 4.4). These criteria include.

requirements.for consideration of base metal thickness,: effects._of l eccentricities, welds joining composite members,. welds attaching' base i angles to embedded plates, and prequalified partia.1. penetration welds.  :. j

, Cable tray and cable tray hanger design validation procedures:(References' 1 L4'.1 through 4.3, and 4.6) include these' criteria; 1

4.0 References 4.1 Ebasco Document SAG.CP34 " General Instructions'for Cab 1'e Tray Hanger y Analysis for Comanche' Peak SES No.1 ^and' 2, Rev.-l11, August 27,  ;

'l 1987.

4.2 Impe11 Instruction PI-03, " Qualification of Cable; Tray Supports,"

\ Rev. 5, October 20, 1987. ,

4 '. 3 Ebasco Document SAG.CP4,'"SeismicLDesign Criteria for Cable Tray. j Hanger for' Comanche Peak SES. Unit l1," Rev. 6. July 1,,1987.

4.4 Comanche Peak Steam Electric Station.No. I and 2'" Cable Tray and j Cable Tray Hanger Design' Basis Document," DBD-CS-082', Rev. O, 1 July 31, 1987. ,

4.5 AISC, " Manual of Steel Construction," 7th Editioncincluding. i Supplements No. 1, 2 and 3. I 4.6 Ebasco Document SAG.CP3,'" Seismic Design Criteria'for Cable Tray -

Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1,:1987. .

4.7 AHS D1.1-79, " Structural Helding Code - Steel," 1979.- 1 4.8 CPSES Helding Procedure Specification HPS-10046, Rev.18, 1 October 16, 1986.  ;

4.9 Impe11 Calculation M-12~ " Qualification Procedures for_ Cable" Tray Support Evaluation," Rev. 4, October 16, 1987.- ,

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I SUBAPPENDIX A17 <

EMBEDDED PLATE DESIGN'(CYGNA' ISSUE NO. 17) 3

>: l E 1.0 Definition of the Issue ' ,

A. This issue was that the original design' calculations which generated: j the capacity of cable _ tray. hanger attachments to embedded strip > 1

.]

. plates.may have ignored the effect of: prying l action on the tension ~ '

load in the Nelson studs. ]q B.- This issue was.that in the original. design l calculations'4for'pipei

~

j supports and cable tray. hangers,-inconsistent design practice was' j used for stiffening:of moment attachments:to embedded plates. In' pipe support design, it was assumed that-attachments'act asi

" stiffeners for moment- connections; in cablet tray' hanger design iti ' > d was indicated that moment attachments'must be stiffened or.

sufficiently analyzed.

~

C. This issue was that original design: calculations-for hangers attached to embedded plates did'not' consider: capacity reductions., q given in original design specifications.for somellocations.-

D. This issue was that minimum separation > requirements for attachments'

!'

• to embedded' plates were. violated. Cable tray hanger installation; '

criteria provide requirements for minimum separation:of embedded plate attachments but: original cable' tray hanger inspection d procedures did not require-a, check'of attachment: separation. - . 1 E. This issue.was that some cable tray hangers may resist loadsHfrom larger tributary cable tray" spans than.were assumed in original:  !

design' calculations, due to design ~ specifications-for.. embedded plate I attachments, j l

F. This issue was that'. anchor specifications .containing.requirementsion minimum spacing do not' address cases where Hilti expansion anchors! y are installed on a concrete surface _ perpendicular to'a surface '.

containing an embedded plate.

q 2.0 Issue Resolution l These issues'are no longer addressed in the cableLtray:and cable ~ .

tray hanger Project Status Report (PSR).- This issue'is' addressed by .! '

the CPSES Civil / Structural Corrective Action: Program (CAP);

(Reference 4.1). The loads on embedded plates gereratedLas'a result.

of. cable tray and cable tray hanger designLvalidation are beingi transmitted to.SHEC.(lead contractor 1for;the Civil / Structural: CAP)'

,for validation of the embedded plates.- g O 1 j

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SUBAPPENDIX A17 i

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' ;j 3.0.' Corrective an'd Preventive Action No additional issues were. identified during'the review and.

resolution of this, issue.z ,

i q

.This' issue was determined,to be' reportable under the provisions ofL l 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report,(SDAR)~CP-85-35'in letter number TXX16048, dated October.21, 1986 from TU Electric to:the NRC.(Also see Subappendix B2)-

c 3.1 Corrective Action Design offembedded plates isLaddressed by the'CPSES Civil / Structural?

Corrective Action Program (CAP) (Reference 4.1). . j 3.2 Preventive Action -

'The criteria for the design of concrete embedments h' ave'b'een est'blished.

a and documented in the cable: tray and cable tray hanger Design. Basis Document (Reference 4.2).- '

4.0' References .

4.1 TU Electric CPSES Unit'l and Common, SHEC Civil / Structural Project.

Status Report, Rev. O.

4.2 Comanche Peak Steam Electric' Station-No.1 and 2 " Design Basis' -l Document, The Qualification'of Embedments in Concrete," DBD-CS-015, .l Rev. 1, June 10, 1987. j tj i

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SUBAPPEND1X All n TRAY Cb % '(CYGNA 13 SUE NO. 18) l j

l 1.0 Definition of the' Issue . '

This issue was that the. assumptions of fu11'connectivity.(i.e., transfer of forces'and moments in three orthogonalJdirections)'between cableLtrays and cable tray hangerstmay be invalid:due to the_ existence of; j installation gaps and inadequate: rotational and displacement.- - .

i compatibility of both " friction" and " heavy duty" clamps. The additional g

assumptions listed below are based'on the initia1Lassemption of' full' u connectivity. ,  ;

'l Cable' trays provi6e'the out-of-plane bracing which can reduce.

buckling length on posts, reduce longitudinal hanger displacement.

and provide. transfer of the: hanger's out-of-plane:inertfal load:

(self weight- excitation)_ to ' longitudinal- hangers.-

)

J Cable trays provide lateral' bracing for the compression flahge of' l the horizontal tiers (beams).  !

Cable trays provide moment resistanceLcapability;between the trays l and the horizontal: tiers.

2.0 Issue Resolution ,

1 Impe11/Ebasco performed engineering studies (References 4.5,'4'.6, and. 3 4.8) which developed the. procedures and methodology used for modeling the' '

connectivity between cable trays'_and cableLtray hangers. These criteria-and methodology are incorporated into design validation procedures 1 (References 4.1 through 4.4). The, assumption of fullconnectivity-between cable trays and cable tray _ hangers'was confirmed-through a full <

scale testing program (Reference 4.9) and_ engineering studies"(Reference  ;

4.8). Reference 4.11 provides a' summary discussion of-the development and confirmation of the tray clamp' assumptions.  ;

3.0 Corrective and Preventive Action No additional issues were identified.during' the. review and- 1 resolution of this issue. I This issue was determined to be reportable under the provisions of 1 10CFR50.55(e). It was reported as Significant Deficiency Analysis. '!

Report (SDAR) CP-85-35 in letter number TXX 6048;' dated.0ctober 21' ,

1986 from TU Electric toLthe NRC (Also see Subappendix B2).

O A18-1

SUBAPPENDIX A18 l

3.1 Corrective Action Design validation criteria considered local compatibility and global distribution of load throughout the cable tray systems. In ESM-(Equivalent Static Method) analysis, full connectivity effects were-considered per Reference 4.1. In RSM (Response Spectra Method) analysis, the same effects were incorporated per Ref erences 4.2, 4.4, and 4.12.

Clamps were modeled as linear-elastic three-dimensional beam elements.

Transverse and longitudin'al clamp stiffnesses were developed'in References 4.5, 4.6, and 4.7.

Tray clamp.modeling was based ~on engineering studies and confirmed by i testing studies. The full scale cable tray system tests performed at the ANCO test facility (Reference 4.9) confirmed that the assumption of full connectivity between cable trays and cable tray hangers was appropriate for both friction and heavy duty clamps regardless of ..

installed gaps. . References 4.7, 4.8, and 4.11 further substantiate.this conclusion. Because full.connectivity between tray and hanger was established, the additional assumptions discussed in Section -1.0 of this

/ subappendix were also substantiated. .; i 3.2 Preventive Action The criteria requiring the consideration of local compatibility and 1 global distribution of load throughout a' cable tray system due to. full connectivity between cable trays and cable. tray hangers have been .]

1 established and documented in the cable tray and cable tray ha'nger Design Basis Document (Reference 4.10). These requirements are also included in the cable tray and cable tray hanger design validation y procedures (References 4.1 through 4.4, and 4.12). ]

4.0 References k 4.1 Ebasco Document SAG.CP34, " General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No. 1 and 2," Rev. 11, August 27, 1987.

4.2 Ebasco Document SAG.CP11. " System Analysis _for Cable Tray and Hanger Assembly for.CPSES Units 1 and 2," Rev. 4, July 1, 1987. '

4.3 Ebasco Document SAG.CP19, " Design Criteria and Procedures for Design Verification of Cable Tray Clamps for Comanche Peak SES Units I and <

2," Rev. 4, October 30, 1987.

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SUBAPPENDIX'A18 1

y 4.4. Impell Instruction PI-02, " Dynamic Analysis'of Cable: Tray Systems,"

-Revt 6, October 15, 1987. ' '

'3 1

4.5 LImpell Calculation M-10,." Cable Tray Clip Angle. Stiffness," Rev. 3,'

j

. September'15,.1987.

j q

4.6 :Impell Calculation =M-19, " Clip Stiffness Production Values,"  ;

Rev. 2, November.7, 1986.

4.7. Impe11 Calculation M-28c." Justification of Clip Modeling Procedure. 1 Tray C1anp-Behavior;":Rev. 3, September 11, 1987.

l 4.8. . Impell ' Rr. port 09-0210-0017, "CPSES Cabis Tray System Analysis / Test' [

Correlation Final Report," Rev. O, February, 1987. 1 4.9 " Final Summary Report - Comanche Peak. Cable Tray Tests,"'Rev.fi,: .

May, 1987, prepared by ANCO Engineers.

L 4.10 Comanche Peak Steam Electric Station No. I and 2, " Cable.-Tray'and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. 0,- .

i July 31, 1987. .j 4.11 Impell Position Paper IM-P-013. " Justification for th'e Use of Rigidf Clamp Stiffnesses,"' Rev. 0, September 11,1987.

4.12 'Impell Instruction. PI-11, " Cable Tray System A'nalysis and '

Qualification Closeout," Rev. 3, L0ctober 15,1987. >

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SUBAPPENDIX A19 FSAR LOAD COMBINATIONS (CYGNA ISSUE NO. 19) 1.0 Definition of the Issue The load combinations of Section 3.8.4.3 of the CPSES FSAR (Reference 4.1) are applicable to the design of cable trays and cable tray hangers in the Reactor Building. This issue was that the Loss of Coolant 4 Accident (LOCA) associated loads, such as pipe whip, jet impingement and. j thermal loads may be, applicable for the design validation of.the cable trays and cable' tray hangers.

2.0 Issue Resolution LOCA pipe whip and jet impingement loads are addressed by the'CPSES-System Interaction Program. The results of the System Interaction portion of the Corrective Action. Program (CAP) are included in the Mechanical Project Status Report (PSR) (Reference 4.2). This' Project Status Report indicates that safety related cable trays and cable tray hangers identified as pipe whip or jet impingement targets have either been relocated or shielded from the pipe whip and jet impingement load.

A The effects of accident thermal loads were considered in a detailed b engineering study (Reference 4.3). . Analyses were performed which determined that the maximum operating thermal displacements were small 1

1 and would not induce thermal loads in the. cable trays and cable tray hangers. Using the recommendations provided in NUREG-0800 Chapter 3 (Reference 4.5) additional analyses were performed to provide assurance ,

that the cable trays and cable tray hangers, including the hanger- 1 anchorages, could accomodate the displacements associated with the accident temperatures without loss of function. The' analyses considered the largest postulated accident thermal displacements (i.e., resulting from thermal expansion of a 40 foot straight tray run) and the cable tray.

system configurations most susceptible to an applied displacement.(i.e.,

very stiff cable tray hangers). The results showed that the cable tray hangers are sufficiently ductile to accomodate the postulated accident thermal displacements without reduction in seismic load resistance or loss of function.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TU Electric to the NRC (Also see Subappendix.B2).

A19-1

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'SUBAPPENDIX A19-g, 3.1 Corrective Action' Cable tray and cable tray hanger CPSES. licensing commitments (

Reference:

.I 4.1) require that the effects of LOCA associated loads :be included:in j cable tray system' design. The CPSES System Interaction Program. . .

i determined that.there.are no cable: trays or cable, tray hangers which are

. targets for pipe whip or jet. impingement (Reference.4.2). .An' engineering

-study'(Reference 4.3) demonstrated that cable tray systems'are i sufficiently ductile to'accomodate the postulated accident thermal.

displacements without reduction in: seismic load . resistance or. loss 'of .

function.

3.2 Preventive Action 1

TU Electric procedure ECE 5.09-01 (Reference 4.4) requires an' .. 'l interdisciplinary review of' Design Chang'e Authorizations (DCAs). .The. N requirements'of ECE 5.09-01 have been incorporated into the Impell/Ebasco j procedures which control the issuance of cable tray and cable' tray hanger j DCAs.(Reference 4.7-and.4.8)-and provide assurance.that interdisciplinary 0 review .is.' performed when required. . Per Reference 4.'4' DCAs are reviewed .!

by the CPSES System Interaction Program. This'reviewiidentifies whether '

~'s or not pipe whip. and jet impingment loads are applicable to the area in l (V which the cable tray and cable. tray hangers.are located. 'The criteria.

for' evaluation of the effects of LOCA loads on. cable. trays:and' cable' tray ,;

H hangers has been established and documented in the cabie tray hanger Design. Basis' Document (Reference 4.6). l q

4.0 References '

.i 4.1 CPSES Units 1 and 2 FSAR, Section 3.8.4.3, with. current amendments. j i

4.2 TU Electric CPSES Unit 1 and Common',.SHEC Mechanical Project Status  !

i Report, Rev. O.

4.3 Impell Calculation M-27, " Thermal Load Evaluation," Rev. 3, October 26, 1987. .

4.4 TU Electric procedure ECE_5.09-01,. " Design Verification and-Interdisciplinary Review of Design Change Authorizations and Non-Conformance Reports," Rev. 1,. September-14, 1987. i 4.5 .U.S.-Nuclear Regulatory Commission,: Standard Review ~ Plan,: ' l NUREG-0800, Section 3.8.4, July 1981.  :

I 4.6 Comanche Peak Steam Electric Station No.1: and.2, " Cable Tray and '

Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. 0,-

July'31, 1987.

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SUBAPPENDIX A19 4.7 Impel 1' Instruction PI-12. " Control of Design Change to Cable Tray-Hanger," Rev.1, April - 30,1987.

4.8 Ebasco Manual of' Procedures Comanche Peak SES,' October 26, 1987.

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( , SU'3 APPENDIX A20 ,

DIFFERENCES BETHEEN INSTALLATION AND DESIGN / CONSTRUCTION DRAHINGS HITHOUT APPROPRIATE DOCUMENTATION (CYGNA ISSUE NO. 20)

.i l

1.0 Definition of the Issue '

l This issue was that CYGNA walkdown inspections of cable tray hangers identified discrepancies between as-built hanger configurations and.

original hanger. design documentation. In addition,. violations in.the i requirements for clearance between cable tray systems and other  ;

commodities were identified.

2.0 Issue Resolution j l

Cable tray and cable tray hanger design validation was based on as-built. -1 information (References 4.1 through 4.9), thus resolving the issue of- d discrepancies between as-built hanger configuration and hanger design J documentation. In addition, clearance requirements between cable tray hangers and other commodities are being addressed by SHEC in the Mechanical Corrective Action Program (CAP) under the Post Construction Hardware Validation Program (PCHVP) (Reference 4.11). 'Any clearance, 3 discrepancies identified for cable tray and cable tray hangers:will.be  !

~ resolved by Impell/Ebasco. '

3.0 Corrective and Preventive Action No additional issues were identified during the review an'd resolution of this issue.

This issue was determined to be reportable under the provisions .of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number.TXX 6048,-dated October 21, 1986 from TU Electric to the'NRC (Also see Subappendix B2). -

3.1 Corrective Action Cable trays and cable tray hangers have been design validated using as-built data as design input in accordance with References 4.1- through 4.9. Clearances between-hangers and other commodities are being addressed by SWEC in the Mechanical Corrective Action Program (CAP). Any clearance discrepancies identified forl cable tray and cable tray hangers will be resolved by Impell/Ebasco.

3.2 Preventive Action The criteria requiring the use of as-built information for design input )

have been established and documented in the cable tray and cable tray-i

p ^

A20-1

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, /~'N SUBAPPENDIX A20  ?

7

. hanger Design Basis' Document (Reference 4 10).

. These requirements 1are, 1 incorporated;in the. design val,idation proceduresL(References 4.7 through: 1 4.9) . for.- cable trays: and cable tray hangers. , Design ' validation ' '

procedures: include the methodology for control and implementation'ofL . .g cable tray land cable tray hanger design modifications to assure thatLthe-validated _ designs reflect new or modified configurations: Cable tray and=

cable tray hanger new installations and: modifications are QC inspected l and! approved-(Reference 4.12 and 4.13)' prior'to' incorporation in the design documentsL(e.g. design calculations, drawings): eliminating the1 potential, for discrepancies between as-built' hanger configurations and ' -

hanger design documentation. ..TU Electric Procedure.ECE 5.09-01<

(Reference 4.14) requires an interdisciplinary review of Design = Change" Authorizations (DCAs). :The requirements of ECE:5.09-01 have been.

incorporated..into the Impell/Ebasco. procedures whichscontroluthe issuance of. cable tray and cable tray hanger DCAs'_(References 4.15'and 4.16)land provide assurance that interdisciplinary review is. performed when required. Per Reference 4.14 Design Change Authorizations'(DCAs).are reviewed by the'SHEC Commodity Clearance. Program ^(Reference 4 17). . ,

M 4.0 References H 4.1 TU Electric Field Verification' Procedure 'CPE-FVM-CS-001,," Field - . -

Verification Method Unit 1. Cable Tray Hanger As-Builting_ and Design:

Adequacy Verification Program," Rev. 8,' August 24 W1987.

4.2 TU Electric Field Verification Procedure TE-FVM-CS-003, " Field' Verification' Method Unit 2 Cable Tray Hanger 4 As-Builting'and Design -

Adequacy Verification Program," Rev. 2, November 21, 1986. 'j 4.3 TU Electric Field Verification Procedure CPE-EB-FVM-CS-019

" Supplemental Procedure for Unit 2 Halkdown ?- Selected Cable Tray'  ;

Attributes Data Collection Unit-2," Rev.-2,1 June 3,~1987.-

l 4.4 TU Electric Field Verification. Procedure TE-FVM-CS-036, " Field Verification Method As-Built Verification' to the' Main' Structural ,'.

Framework in the Cable Spread Room' Supporting Unit.1 Designated Cable. Trays and Selected Attributes of Unit 1 Cable Trays,": Rev. 0, February 19, 1987.

t 4.5 TU Electric Field Verification Procedure.TE-FVM-CS-048, " Field ,

Verification Method Unit 1 Cable Tray Selected Attributes As-Built-Program,"-Rev. O,. December 31,~1986.- I 4.6 TU Electric Field Verification 3 Procedure TE-FVM-CS-050, " Field. >

Verification Method T. J. Cope Flat'LadderiTee. Fittings Selected 1 .

Attributes Data Collection," Rev._0, January.5,;1987.- -

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SUBAPPENDIX A20- 9

.j 4.7 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable' Tray; .m Hangers for Comanche Peak SES Unit 2," Rev. 9,-July 1,,1987.

4.8. Ebasco. Document SAG.CP4, " Seismic: Design Criteria forLCable Tray 1 Hangers for Comanche Peak SES Unit;1," Rev. 6,-JulyD1., 1987..

4.9 ~ Impell Instruction PI-02, " Dynamic Analysis of Cable' Tray' Systems,"

Rev. 5, October 10, 1986,'with Addenda dated 01/28/87, 04/30/87'and 06/02/87..

l. 4.'10 Comanche Peak Steam Electric Station No.1 and 2. " Cable Tray and i Cable Tray Hanger Design BasisLDocument," DBD-CS-082, Rev. O, July 31, 1987.

4.11 TV Electric.CPSES Unit.1 and Common, SWEC ' Mechanical: Project' Status Report, Rev. O. .I 4.12 TU Electric Procedure - QI-QP-il .10-9,; " Modification, Rework and

.As-Built' Inspection / Verification of. Cable' Tray Hangers in' Unit 1,"

j Rev. 8 May 7,.1987.

~

l 4.13 TU Electric Procedure, QI-QP-11.10-2A', " Inspection'.of Unit 2 Cable i O Tray Supports," Rev. 11, 0ctober 22,-1986.' j 4.14 TU Electric Procedure ECE 5.09-01,." Design Verification and .

Interdisciplinary Review of-Design. Change" Authorizations'and Non-Conformance Reports,".Rev...l. Septemberil4,'1987.

4.15 Impell Instruction PI-12, " Control of' Design: Change to Cable: Tray.

Hanger," Rev.1, April ' 30,1987.

4.16EbascoManualofProcedures,ComanEhe'PeakSES, October 26,-1987; 4.17 TV Electric Procedure CPE-SHEC-FVM-CS-068,'" Field Verification Method - Commodity Clearance,"'Rev. 0,' July 30,.1987.

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I SUBAPPENDIX A21 DESIGN CONTROL (CYGNA ISSUE NO. 21) 1.0 Definition of the Issue f A, B, This issue was that as-built information was not properly considered C, E, in the original evaluation of cable tray hangers in the following i

I. areas:

Implementation of design change documents l Limiting hanger dimensions and loadings ~ determined in-the-original design calculations i l

Design review of standard cable tray hanger designs which- J required case-by-case. reviews j Design and installation limits on cable tray spans Discrepancies between cable tray hanger design and assembly l drawings q D. This issue was that in the original evaluation of cable tray hangers y with thermolag fire protection material: '

Cable tray cover weights were not addressed in determining cable-tray allowable span length' tables.

Original design of longitudinal cable tray hangers did not consider the weight of fire protection material.

Cable tray spans with cable tray weights in excess of the weight-considered in the original cable tray hanger design were not evaluated as required.

j 1

Evaluations for cable tray side rail extensions were not performed. l Original cable tray hanger design capacities used in comparison to cable tray loads were overestimated.

F, G. This issue was that certain cable tray hanger design calculation sets were not complete (e.g., calculations justifying some design i change notices were not inchtad).

H. This issue was that the original cable tray hanger design criteria j documentation was insufficient to assure consistency and compliance l I

v A21-1

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q SUBAPPENDIX A21-i

.a' with the FSAR- . There was no documentation on the use of AISC ..

(Reference 4.2) supplements.-by' designers...Also,: improper cable' tray tributary span criteria were used'for field design review.

, 9 2.0 Issue Resolution ~

A,B,. The cable: tray'and~ cable trayLhanger design validation; procedures:

C, E, .(References- 4.3, 4.4,~4.12, 4.'16, and 4.'17) require the.use,of.. 9 I. :as-built'information (obtained per; References _4.6'through 4;11).as design input.

1D. Cable tray and cable tray hanger, design validation. procedures (References.4.3, 4.4, 4.12,cand 4.16) require that thel weight"of ,

cable tray' covers and ifire protection material be considered in thei evaluation of-cable trays and hangers, including cable tray _ hanger-design capacities. The effect of cable. tray side rail' extensions'.is' also> addressed in References 4.4 and 4.13. These' actions combined.

with the use of as-built information for-design validation of. cable trays and hangers resolve-this item. j L F, G. Cable tray and cable tray.. hanger design validation' procedures 1 )

require that' calculations and drawings be controlled in'accordance -

j

-O '

with appropriate Quality Assurance'(QA)' procedures -(References 4.5 -

and 4.14). In addition, procedures (References 4.5~and 4.18) have been developed to control design changes and to assure thatl cable--

tray and cable tray hanger modifications'are incorporated in~ design.-

calculations.

H. Cable tray and cable tray hanger design criteria and procedures (References 4.3, 4.4, 4.'12, 4.16,.and 4.17) used for design:

i ?

validation are consistent with the requirements of the CPSES' FSAR' 1 including the application of the AISC Speci_fication.

3.0 Corrective and Preventive Action ,

No additional issues were identified during 'the review and.

resolution of this issue.

This issue was determined to be' reportable under.the provisions of.

10CFR50.55(e). It was reported as Significant Deficiency Analysis ,

, Report (SDAR) CP-85-35 in letter number TXX 6048, dated' October 21, l 1986 from TU Electric to'the NRC (Also see Subappendix B2).

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SUBAPPENDIX A21- J (

'3.1. Corrective Action-Cable trays and. cable tray hangers'and theirl components have been' design.

validated including effects;of the;following:- <

, q As-built information was used'as, design; input per References 4.3, 1 4.4, 4.12, 4.16'and'4.17.

Components.of the cable' tray systems were considered per the' design;

. validation procedures in References 4.3,~4.4, 4;12 and 4.16.

j A comprehensive QA program (References 4.5'andL4.14) was, implemented:

to control' calculations and' drawings... .

q The design validation procedures control' the.use of;the AISC L Specification and its supplements and >therefore assure : compliance.

with the CPSES FSAR-(Reference 4.1). . .

3.2 Preventive Action The criteria, requiring the use of as-built information asidesign. input;- ,

y compliance with the CPSES FSAR (Reference 4.1); consideration of cable 1

( tray system components; and implementation of a QA program to control l calculations and drawings,sare established and' documented.in the. cable-tray and cable tray hanger Design Basis: Document (Reference 4.15). . These requirements are also included'in the cable tray and cab 1_e tray hanger design validation procedures'(References 4'.3,.4.4,i4.12, 4.16 and:4.17).1

~

4.0 Referentss '

4.1 CPSES Units-'1 and 2 FSAR, with current amendmens, t l

4.2 AISC, " Manual of. Steel Construction," 7th Edition including Supplements No. 1, 2, and 3.

4.3 Ebasco Document SAG.CP4, " Seismic Design Criteria for Cable Tray

Hangers for Comanche Peak SES Unit 1," Rev.26, JulyL1, 1987.

4.4 Ebasco Document SAG.CP34, " General Instructions for Cable Tray.-

Hanger Analysis for Comanche Peak SES No. I and 2," Rev. 11,.

August 27, 1987.  :

4.5 .Ebasco Manual of Procedures, Comanche Peak-SES, October'26, 1987.

4.6 .TU Electric Procedure CPE-FVM-CS-001, " Field Verification Nethod-Unit 1 Cable Tray Hanger As-Builting and Design Adequacy Verification Program," Rev.' 8, August 24,:1987'.

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SUBAPPENDIX'A214 4 r

L

- 4.7 .TU Electric Procedure TE-FVM-CS-003, " Field Verification Method Unit:

2 Cable, Tray Hanger As-Builting and. Design Adequacy Verification Program," Rev. 2, November 21, 1986..

~ 4.8' TV Electric Procedure CPE-EB-FVM-CS-019. " Unit-2. Cable, Tray Selected Attributes As-Builting Program,"=Rev. 2, June'3,il987. y

~4.9 TV Electric Procedure. TE-FVM-CS-036, " Field Verification Method '

As-Built Verification.of' Attachments to the Main 1 Structural'

-Framework in the Cable Spread Room Supporting-Unit 1 Designated Cable Trays and' Selected Attributes of. Unit 1: Cable: Trays," Rev.LO,: 1 February.19,.1987.

4.10 TU Electric Procedure.TE-FVM-CS-048,'" Field Verification Method' Unit ,

1 Cable Tray Selected.. Attributes As-Built Program,":Rev.'0, j

December 31, 1986.- '

~~~._.

4.11 TV Electric Procedure TE-FVM-CS R SfteTETerif1 cation Method- 1 T. J. Cope Flat 1ttings Selected Attributes' Data- q Collection," REv,. O, Ladhr-h January;5,.1987. 1 l

4.12 Impell Instruction PI-02, " Dynamic: Analysis lof Cable Tray Systems," '

Rev. 6, October'15, 1987.

i 4.13 Impell Calculation M-39, " Side Rail Extensions' Study,"'Rev. 2,.

July 27, 1987.  ;

4.14 Impell Quality Assurance' Manual, Rev.17, July' 15, '1985. .

4.15 Comanche Peak Steam Electric Station No. 1 and'2,-" Cable Tray-and' Cable Tray Hanger Design Basis: Document," DBD-CS-082,'Rev. 0,.  :

July 31, 1987.

4.16 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray '!

Hangers for Comanche Peak SES Unit'2," Rev. 9;. July)1, 1987. .

4.17 Impell Instruction PI-03, " Qualification of Cable. Tray Supports,"

Revision 5, October 20,.1987. .

4.18 Impell Instruction PI-12. " Control of Design Change to Cable Tray.

Hangers," Rev.;1, April 30, 1987. i l

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1 SUBAPPENDIX A22  :

%)

DESIGN OF SUPPORT'NO. 3136. DETAIL "5";

ORAHING 2323-S-0905 (CYGNA ISSUE NO. 22)

)

~

1.0 Definition of the Issue -

The original. design calculatio'ns for.thisl cable tray hanger containedi .

errors in the: finite element model used to represent the hanger,'and:did- ,

4 r.ot consider tornado'depressurization loads on the firewall. This. issue j was that hanger number 3136 is a Seismic Category'I: structure JLitached.to. :q a Seismic. Category IILfire wall. H i

2.0 Issue Resolution q

___ -IT6Tated cases of' cable tray hangers attached to, Seismic Category IIL '

structures were identified and evaluated'on'a. case-by-case. basis... Hanger number:3136 is supported from ' Seismic Category I: steel embedded inL the.

Category II' wall. The Seismic Category II. wall was not assumed to: 1 provide support for the cable tray system, however the seismic inertial 1 effect of the' Seismic' Category'II Wall was' considered'in the design-validation. The structural adequacy.of Seismic Category II walls.,

including tornado depressurization' load effects, wastaddressed, by. SHEC in the Civil / Structural. Corrective Action Program'(CAP) (Reference 4.1)^  !

3.0 Corrective and Preventive Action i No additional issues were identified during the review and .

resolution of this issue. i This issue was determined to be reportable under the provisions ~of-10CFR50.55(e). It was reported as:Significant: Deficiency AnalysisL Report (SDAR) CP-85-35 in. letter.humber'.TXX~6048, dated October 21,  ;

1986 from TU Electric-to'the NRC (Also.see Subappendi,x B2).  !

3.1 Corrective Action j Isolated cases of cable tray hangers attached to Seismic Category II-structures have been identified and the effects of Seismic Category II structures on cable tray systems have'been considered.

1 The design validation of Seismic Category II: structures was performed as.

a part of the SHEC Civil / Structural Corrective Action' Program (CAP) as i reported in the' Civil / Structural Project Status Report:(Reference 4.1).

3.2 Preventive Action '

The criteria requiring that loads from cable trays and cablestray i

hangers on Seismic Category II structures be reported to the SHECL . .. .

Civil / Structural group have been: established and documented.in the Design A22-l' '

j SUBAPPENDIX A22 Basis Document (Reference 4.2). The design validation of Seismic' Category II structures was performed by SHEC in the Civil / Structural-~ .y Corrective' Action Program (Reference =4.1).. ~-

4.0 References ,,

4.1 TU Electric CPSES' Unit 1.and Common, SHEC' Civil / Structural Project Status Report, Rev. 0. q 4.2 Comanche Peak ' Steam Electric Station' No.1, and 2. :" Cable Tray'and Cable Tray Hanger Design Basis' Document," DBD-CS-082, Rev. O.

July 31, 1987. -i

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'J SUBAPPENDIX A23 1 f

LOADING IN STRESS H0DELS (CYGNA ISSUE NO. 23) .j 1

1.0 Definition of the Issue This issue was that the original finite element analyses of standard. i unbraced cable tray hangers applied loads at incorrect locations, j calculated loads based on span lengths which did not consider i installation tolerances, and modeled the frame post members shorter than i actual lengths. 1 2.0 Issue Resolution Design validation procedures for cable tray hangers (References 4.1 l through 4.3, 4.5 and 4.6) require the use of as-built information as i design input. The finite element modeling techniques used in design j validatio- *opriately represent the as-built hanger configuration i including u.noer lengths and location of tray / hanger connections. j 3.0 Corrective and Preventive Action I

No additional issues were identified during the review and fm resolution of this issue.

(V)

• This issue was determined to be reportable under the provisions of i

10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action Cable tray hangers have been design validated using as-built information l (References 4.1 through 4.3, 4.5, and 4.6) which provides hanger configuration including member lengths and cable tray load location.

3.2 Preventive Action .

The criteria established in the cable tray and cable tray hanger Design Basis Document (Reference 4.4) and its referenced design validation procedures (References 4.1 through 4.3, 4.5, and 4.6) provide assurance l that as-built configurations are used for design validation with appropriate consideration being given to member length and cable tray location.

4.0 References 4.1 Ebasco Document SAG.CP34, " General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No. 1 and 2," Rev. II, f] August 27, 1987.

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SUBAPPENDIX A23-4.2 Ebasco Document SAG.CPil, " System Analysis'for Cable Tray and Hanger I Assembly.for.CPSES Units 1 and 2," Rev. 4, July'1,11987,

. '. .d i

4.3 Impell Instruction PI-02,." Dynamic Analysis'of Cable Tray Systems," I Rev. 6, October 15, 1987..

4.4. Comanche Peak Steam Electric Station. No. 'l and 2, " Cable' Tray and Cable Tray Hanger Design Basis Document," DBD-CS-'082,.Rev. O, July 31,-1987.

i 4.5 Ebasco Document SAG.CP3, " Seismic Design Criteria'for Cable Tray 1 Hangers for Comanche Peak SES' Unit.2,".Rev. 9,' July 1, 1987.

4.6 Ebasco Document SAG.CP4,'" Seismic Design Criteria for Cable Tray.

Hangers for Comanche Peak SES Unit 1,":Rev. 6, July 1,.1987.

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, . o SUBAPPENDIX A24 ))

DESIGN OF FLEXURAL' MEMBERS (CYGNA' ISSUE NO. 24)- .-

d 7

1.0' Definition of the Issut A.- This issue was' tha't in the design of, flexural' members,' addit'ional - .

moments in the. cable-tray l hanger beams, due to eccentricities at the: j cable tray / beam connection were~not-considered properly.  ;

B. This issue was:thatLthe methods used in the original designs did not account for the effects of. eccentricities which may. result in.

additional torsional loads in;the cable. tray hanger beams..

C. This issue was-that. original:: design calculations for flexural .

members. inconsistent 1y' considered reduction:in section. properties l due to flange bolt holes and weld undercut; D. ~This issue was that original' design calculations for: flexural members did not include shear stress. effects 4due'to: direct shear, St. Venant shear from torsional loads, and;the. combination of.the- ,

two. 1 p E. This issue was that in the' original design of flexural members,.

V capacity reduction due to the unsupported. length of;the compression flange. per AISC Equation 1.5-7, was not' properly considered.

F. Some design calculations of flexural members performed by response spectra analysis included an increase factor,of 1.30:to account for the under prediction of warping normal = stresses'when using the-STRUDL computer program. This issue was that this' practice was not specified in the design validation ' procedures.

2.0 Issue Resolution ,

A. Design validation procedurfs (References 4.3, 4.9, 4.12,'and 4.13) require that moments resulting from tray / hanger connection eccentricities be appropriately considered.

B. The design validation procedures require thatithe' eccentricities's which may result in' additional torsional loads in cable tray. hanger:

beams be considered per References 4.3, 4.12, and 4.13..

,F C. - Reduced member section properties resulting from bolt holes with a maximum size of 3/4 in., were developed in References 4.2,.4.4, and' 4.8. These reduced properties,. in accordance' with the AISC O

A24-1

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l O SUBAPPENDIX A24-

)

V l

Specification, were used in the design validation of cable tray.  !

hangers tiers to account for the presence of both used and unused i bolt holes as required in References 4.3 and 4.11.. 1 l

Reference 4.1,.the Nuclear Construction Issues Group " Visual' Held Acceptance Criteria" (VHAC),' has been accepted by the.NRC for: Use at j CPSES. Welds not satisfying'the VWAC undercut ~ requirement i identified 'in accordance with References 4.5 and 4.6, were, 1 evaluated and,'where necessary, repaired.

]-

D. The design validation procedures require that shear stresses du'e to I direct shear and St. Venant -shear, be considered as described in j References 4.3 and 4.9. j E. The design validation procedures' require that in the design.of flexural members, capacity reduction based on the unsupported. length'  ;

of the. compression flange be considered per the AISC Specification ]

(Reference 4.7) Equation 1.5-7 as specified in References 4.3.and J 4.9.

i F. Harping normal stresses are considered in' cable tray hanger design -]

validation procedures as specified in Reference 4.3, 4.9 and 4.13. l s.- ) 3.0 Corrective and Preventive Action j

No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of j 10CFR50.55(e). It was reported as Significant Deficiency Analysis- I Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21, 1986 from TU Electric to the NRC (Also see Subappendix B2).

3.1 Corrective Action Cable tray hangers have been design validated'per the procedures (References 4.3 4.9, 4.11, 4.12,.and 4.13), with appropriate consideration of the following conditions: .1) horizontal and vertical eccentricities which occur at the connection of the tray and hanger; 2) reduction in beam section properties'due to flange bolt holes and weld undercut; 3) shear stresses due to direct shear, St..Venant shear and a combination of the two; 4) capacity reduction based on the unsupported:

length of the compressive flange; and 5) appropriate warping normal stress calculations.

(G,1 A24-2

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'SUBAPPEND'IX-A24' J

3.2 Preventive Action' ],

The criteria', requiring' the' consideration.of:.' 1) horizontal and vertical-1

. eccentricities which ' occur at the connection'of.the tray and. hanger; 2) j reduction in beam'section. properties-due-to-flange: bolt. holes and.welda .

undercut; 3) shearcstresses due to direct shear,.St. Venant shear..and a-

"J combination of.the.two; 4), capacity.reductionibased on'the unsupported  ;

length of the compressive flange; and 5) Appropriate warping normal: , y stress calculations, have been established and documented in the cable.

tray and cable. tray. hanger Design-Basis Document (Reference.4'.14). These requirements have'been included in the cable' tray and cable tray-hanger i design validation procedures (References 4.3, 4.9, 4.11,14.12, and.4.13). f '

l 4.0 References 4.1 NCIG-01, " Visual Weld Acceptance Criteria," Rev. '2, May.7,11985.

4.2 Impell Calculation M-65, " Evaluation'of Potential Bolt Holes in Tier =

Members,". Rev. 2, July 16,1987.

4.3 Ebasco Document SAG.CP34, " General Instructions 1for. Cable Tray Hanger Analysis for Comanche Peak SES No.'1 and 2," Rev. 11, August 27, 1987.

4.4 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 22,

" Statistical Analysis of. Bolt; Hole / Edge. Distances in Cable Tray Hangers," Rev. 1, October 23, 1987.

i 4.5 TU Electric Procedure QI-QP 11.10-9 R8, May 7,'1987, " Modification, Rework' and 'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1." 'l 4.6 TU Electric Procedure QI-QP 11.10-2A R11', October 22, 1986,-

" Inspection of Unit II Cable Tray Supports."

4.7 AISC, " Manual of Steel Construction," 7th' Edition including Supplements No. 1, 2, and 3.

4.8 Ebasco Comanche Peak SES Cable Tray Hanger Volume'I, Book 25

" Reduced Section Properties for Channels," Rev. O, February 24' 1987. ,

1.

I 4.9 Impell Instruction PI-03, " Qualification of Cable-Tray Supports,"

Rev. 5, October 20, 1987.

l 4.10 Impell Calculation M-12 " Qualification Procedure for Cable Tray:

Support Evaluations,"'Rev. 4, October 16, 1987.-

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SUBAPPENDIX A24 l 4.11 Impel 1 ' Instruction PI-11. "CableITray System Analysis and ;

Qualification Closecut," Rev. 3, October 15,.1987. -,

4.12 Impell . Instruction PI-02, ." Dynamic Analysis of Cable Tray. Systems," {

Rev. 6, October 15, 1987.

4.13 Ebasco Document SAG.CPil, " System Analysis for Cable Tray and Hanger Assembly for CPSES Units 1 & 2," Rev.'4, July 1, 1987.

4.14 Comanche Peak Steam Electric Station No. 1'and 2, " Cable Tray and' Cable Tray Hanger Design Basis Document,"'DBD-CS-082, Rev. O, July 31, 1987.

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SUBAPPENDIX A25 CABLE TRAY QUALIFICATION (CYGNA' ISSUE'NO. 25)- ,

i l'.0 Definition of'the Issue

This issue was that. cable. tray designs were not performed-properly because:i A. Adequate justification for the use.of a Dynamic: Amplification ~ Factor (DAF) of 1.0 with peak _ spectral accelerations;was not provided.

B. Cable tray allowables were based on testing of eight (8)-foot-spans. ..For spans other:than eight-(8) feet the allowables:were not.

. considered properly with variation.in span' length.

C. Modifications to vendor.. supplied hardware were not' documented or -.

considered in.the design.

D. Cable tray moment of. inertia calculations--did not consider shear deformations under transverse loading of-ladder-type trays..

1 2.0' Issue Resolution )

A. Design' validation of cable trays' by the Equivalent._Statih Method:

considered that tray. spans (including' straight trays, bends,' tees, and crosses) were'either subjected to_ peak seismic accelerations or to seismic accelerations at.the system. frequency in each direction from the Amplified Response Spectra'(ARS). . In-all cases these accelerations were increased by at least 25 percent...The 1.25 .

factor is justified by engineering studies documented in Reference 4.14. Design validation performed using the response spectraEmethod (RSM) inherently includes the effects of dynamic amplification.

B. The. design validation of tray spans greater than'8 feet is based'on l comparisons of tray bending. moment (which inherently considers' variation in span length) with'the bending moment capacities obtained from testing (References'4.3 through 4.6.and,4.8).

C. The effects of modifications to vendor supplied hardware are evaluated using'as-built data (Reference 4.1 and 4.10) (also see Subappendices 83 and B5).  !

D. The design validation procedures _(References.4.2 and 4.10) consider: 1 cable trays -as pure flexural members. An engineering study' ,

(Reference 4.7) has shown that_this procedure is appropriate.and.

that shear behavior does not.need to be explicitly considered.

3.0 Corrective and Preventive Action No additional issues were identified while resolving these issues.

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A25-1

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SUBAPPENDIX A25 This issue was determined to.be reportable under the provisions of; 10CFR50.55(e). It was reported.as Significant Deficiency Analysis.

Report (SDAR) CP-85-35.in letter-number TXX'6048, dated October 21 .

1986 from TU Electric to the NRC. (See Subappendix B2).

3.1 - Corrective Action Cable tray and cable tray. hanger have been design validated.using

- appropriate Dynamic: Amplification Factors.for equivalent static-load' methods, appropriate. tray capacities, as-built data and appropriate

~

modeling techniques to adequately-predict tray response.

3.2 Preventive Action The criteria requiring dynamic application factors-for equivalent static.

load methods, appropriate tray capacities,-the use of'as-built datalfor- -

a design validation, and appropriate modeling'techinques to adequately, J prediet tray response have been' established.and documented'in the: cable: 1 tray and cable tray hanger Design Basic Document (Reference 4.11). . These 1 requirements have been included in the cable tray and cable tray hanger- 1 design validation procedures (References 4.1, 4.2, 4.9, 4.10 -4.12,-and l 4.13).

i 4.0 References 4.1 Impell Instruction PI-06, " Tray and. Clip Qualification," Rev.1, 'q October. 20, 1987, with Addendum dated 02/02/87.

4.2 Impe11 Instruction PI-02, " Dynamic. Analysis _of Cable Tray Systems,"

Rev. 6. October 15, 1987.

4.3 Impell Calculation M-03, " Cable Tray Properties," Rev. ' 4, November 11, 1986.

4.4 Impe11 Calculation M-34, " Straight Cable Tray' Moment Allowables,"

Rev. 2, June 22, 1987.

1 4.5 Impe11 Calculation M-35, " Allowable Loads .for Cable Tray Elbows," l Rev.1, December 5,1986.

4.6 Impell Calculation M-36, " Cable Tray Allowables for Tee and f

. Crosses," Rev. O, October 14,1986-d 4.7 ImpelllCalculation M-66, " Transverse Behavior of Cable Trays," i Rev. 2, June 30, 1987. j .

i f

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SUBAPPENDIX A25- ,

4.8 Ebasto Comanche Peak SES-Cable-Tray Hanger Volume'I Book 1, " Cable. ,

Tray Properties and Qualification":.

Part 1, Rev. 3,. January 15, 1987 Part 2,.Rev. O,' January 15,.1987'.

Part 3,~Rev. 0, January.15. 1987 Part 4, Rev. 5. September .15,1987 .,

Part 5, Rev. 3, August 4, 1987 {

Part 6. Rev. 0 ! June ~18, 1987

. . 1 Part 7, Rev. O, September. 15, 1987 4.9 Ebasco Procedure SAG.CP34.'" General! Instructions for Cable Tray Hanger Analysis for-Comanche Peak SES No. 1 and-2," RevD 11, 1 August 27, 1987. >T 4.10 Ebasco Procedure SAG.CP18. " Procedure for Qualification'of Cable Trays'for Comanche Peak SES Units 1 and 2," Rev. 3, October 30,11987...

4.11 Comanche Peak Steam Electric Station-No. 1 and 2, " Cable' Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082,4Rev. O, July 31, 1987.

4.12 Ebasco Document SAG.CP11, " System Analysis for Cable Tray.and Hanger.

Assembly for CPSES Units 1 and-'2," Rev. 4, July 1, 1987. ' a 4.13 Ebasco Document SAG.CP19. " Design Criteria.and Procedures for Design, Verification'for Cable Tray Clamps:for Comanche Peak SES Units l'and- ,

2," Rev. 4,-October 30, 1987.

4.14 Ebasco Comanche Peak SES' Cable Tray Hanger, Volume I,.. Book.15

" Cable Tray Dynamic Load Redistribution Effects," Rev. 4, October 30, 1987.

j 1

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i SUBAPPENDIX'A26-BASE ANGLE DESIGN (CYGNA' ISSUE NO.'26).

1.0 Definition of the Issue -

A. This issue was thatlin the original base. angle designf angles were modeled as simply supported beams, . ignoring stiffening effects <of -

concrete bearing at. angle ends.

B. This issue was'that in the origt'nal design of base angles,'thes principal axes werefnot considered' for? calculation of flexural stresses.

C. This issue was'that inithe. original' design,;the "HorkingLPoint Deviation Study" for' brace. connection eccentricities did not. address 6 the most. critical spacing of Richmond Inserts;in' determining base :

angle lengths. ,

D. This issue was.that for some hangeritypes, the original designi calculations did not' include an evaluation of basetangles.

2.0 Issue Resolution A. Design validation. procedures (References 4.1Lthrough 4.4) account for the stiffening effect of the concrete in the' development of-boundary stiffnesses used in cable tray hanger models. The-development of the boundary stiffnesses is discussed in Subappendix H

A3.

B. Design validation procedures (References 4.3 and.4.4). require tha't.

base angle principal axes be cons.idered;in the design-validation of-base angles. j C. Thedesignvalidationprocedures(References 4.'1through4M) ~

require that as-built.information (including member lengths and.

actual spacing of Richmond Inserts) is'used in'the design validation of base angles. 1 D. Design validation procedures (References 4.3 and'4.4) require that- ,

all base angles of each cable tray hanger.are design validated. 'l 3.0 Corrective and Preventive Action-No additional issues were identified during.the. review and' R resolution of this issue.

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, SUBAPPENDIX A26 ,

This issue 1was determined.to be reportable underLthe' provisions of m-

'10CFR50.55(e)L It'was reported 'as Significant Deficiency. Analysis

. Report (SDAR):CP-85-35 in-letter number TXX 6048,; dated October 21 b 1986 from TU. Electric'to the NRC (Also see SubappendixLB2).

3.1 Corrective Action

~

q

Thecable' tray,.andcabletray.hangershavebeendesignlvalidatedforthe. g effects of concreteibearing at baseLangle

ends and?for effects of. base L p

angle principal axes (Refere.nces14.1 through '4.4). InLaddition, the-design validation.is based on as-built' data for each individual base' vi j 1

. angle.

a 3.2 Preventive Action The' criteria, requiring consideration of. the.' effects /oficoncrete bearing; at base angle ends, the use of principal axes?in base angle validation 7.,

andLthe use of as-built. data- for ' design input, have been established ands documented in the cable tray and. cable.. tray < hanger Design l Basis Document!

'(Reference 4.5). These requirements are included in:the. cable tray.and cable tray hanger design validation procedures (References 4.1 through.

4.4).

4.0 References 4.1 Ebasco Document SAG.CP4, " Seismic Design Criteria for. Cable Tray Hangers for Comanche Peak'SES Unit 1,"-Rev. 6, July 1,.1987.

4.2 EMmo Document SAG.CP3, " Seismic Design Criteria for Cable Tray 0 g rs fc Comanche Peak SES-Unit 2," Revi 9. July 1,H1987.

4.3 Impell Instruction PI-07, " Design Verification of Base Plates, Base Angles, and'Embedment Plates," Rev. 3, September 16, 1986,'with'-

Addenda dated 01/07/87, 01/19/87, and 09/30/87.

.I 4.4 Ebasco Document SAG.CP34, " Genera 1' Instructions lfor Cable' Tray-.  ;

Hanger Analysis for CPSES No. I and:2," Revision 11, August 27,:1987. j 4.5 Comanche Peak Steam Electric' Station No.1 and 2, . " Cable Tray and ' 'I Cable Tray Hanger Design 8 asis Document," D8D-CS-082, Rev. O.,

July 31, 1987.  ;

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.N- SUBAPPENDIX'A27 A/ . .s SUPPORT 00ALIFICATION BY SIMILARITY?(CYGNA' ISSUE NO. 27)

N

, l' . 0 Definition'of the I u gg {

This issue wasithat in the original design . calculations.c some; cable tray: ,

hangers (i.e. supports) were validated'by si_milarity without proper

~

' justification. , .g i

l 2.0 Issue ~ Resolution Design validation was performed using as-built information .which. a

l. adequately accounts for.significant hanger attributes; including brace h l connection eccentricities. The majority of the hangers:have been desigri validated individually. In the limited number of' instances- where . hangers l q were grouped, the grouping was performed in accordance with' References; Q 4.1 and 4.2. "

l 3.0 Corrective and Preventive Action' H

,)

o No additional issues.were identified'during the review and-resolution of.this issue..

o This issue was determined to be reportable under the' provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis' E o Report (SDAR)LCP-85-35 in letter number TXX 6048 -dated October 21, l

1986 from TV Electric to the NRC:(Also see Subappendix.B2).

3.1 Corrective Action a

Cable tray hangers have.been design validated usingias-built information (including brace connection eccentricities) as design input to determine the applicability of the grouping procedures for~similar hangers.

Validated grouping procedures (References 4.1 and'4.2) have been.used when applicable.

l 3.2 Preventive Action

The criteria requiring the use of as-built information as design: input Lto' the cable tray hanger design.have been established and' documented in the- j cable tray and cable tray hanger Design Basis Document (Reference 4.3).

This requirement has been included in the cable tray'and cable: tray y hanger grouping procedures-(References 4.1 and-4.2). ,

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1 SUBAPPENDIX~A27 j

4 .'O References 4.1 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 4,~" Cable: a Tray. Hanger Geometry Grouping,".Rev. 3, February 20, 1986.  !

4.2 Eba'co' s Comanche Peak SES-Cable Tray Hanger Volume I, Book.8 '" Cable Tray Hanger Geometry Grouping," Rev. 2. March 12,'1987.

4.3 Comanche Peak Steam Electric Station No. 1 and 2, " Cable Tray..and.

Cable Tray Hanger Design Basis-Document," DBD-CS-082, Rev. O,

' July 31, 1987.

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SUBAPPENDIX A28- J fg CRITICAL SUPPORT. CONFIGURATION AND LOADINGS (CYGNA ISSUE NO.'28):

y 1.0 Definition of the'Iisue - ,l This issue wastthat original design calculationsLfor trapeze. type: cable-tray-hangers (i~.e., supports);-considered:symmetricyload. patterns:and-'a; . . a limited number of hanger aspect ratios ~ which may not have represented- the!

bounding as-built configurations'.- 4 q

2.0 Issue Resolution' '

n Design' validation.was performed using~as-built information whichl , . . ,

j adequately accounts for significant hanger: attributes including actual . ,

tray locations. The majority of.the hangers have been design validated' '!

individually. In the: limited number of instances where hangers. were . .. I grouped, the grouping was' performed in accordanceLwith References'4.'11and; 4.2. '

l i

3.0 Corrective and Preventive Action - ,

No additional issues w~ere identified. during the review and resolution of this issue..

O

• This issue was determined-to be reportable under.the provisions-'of' 10CFR50.55(e). It was -. reported.as Significant Deficiency Analysis .

Report (SDAR) CP-85-35 in letter number TXX 6048, dated October 21,. 1 1986 from TU Electric to the NRC.(Also'see Subappendix B2).. '

3.1 Corrective Action i

Cable tray hangers have been design validated using as-built information (including actual tray locations on the hangers)'as input to determine j the applicability of the grouping procedures. Validated grouping procedures (Reference 4.1 and 4.2) have been used when applicable. '

3.2 Preventive Action d

The criteria requiring the use of as-built information.(including' actual 'i tray location) as design input to the cable tray hanger design ~have beent  ;

established and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.3). -This requirement has been included in' i the cable tray.and cable tray hanger grouping 3 procedures (References 4.lc i and 4.2).

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1 SUBAPPENDIX A28 4.0 References ,

4.1 Ebasco. Comanche Peak SES Cable Tray Hangers Volume I; Book 4,_'.'. Cable -l Tray: Hanger Geometry Grouping," Rev.'3; February 20, 1986'. ln 4.2 Ebasco Comanche Peak SES; Cable Tray Hangers-Volume.I;: Book 8,." Cable- j Tray Hanger Geometry. Grouping," Rev. 2, March-12; 1987.-  !

.1 4.3 Comanche Peak Steam Electric Station No; 1 and 2 " Cable' Tray and- i Cable Tray Hanger Design Basis Document " DBD-CS-082, Rev. 0,-

July 31, 1987.-

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+ v: y SUBAPPENDIX A29 CUMULATIVE EFFECT OF REVIEH ISSUES (CYGNA ISSUE NO. 29) 1.0 Definition 'of the Issue This; issue'.wasthatanumberof'smallunconservatismsres'ltingjfrom u

separate issues.may have significant. cumulative effect.for cable tray-hangers affected.by-more than one issue. A; number of-issues discussed-

-in Subappendices Al through:A28_may. lead to small unconservatisms when occuring singly in.a~ cable tray hanger designa Several of.these' issues are applicable.to many cable tray hangers. and their;effectl can be.

cumulative.

2.0 Issue Resolution This issue is resolved by the cable tray'and cable tray hanger' Corrective Action Program (CAP) and its comprehensive engineering i

approach to design validation;of. cable trays and cable tray hangers and by the implementation of extensive as-built analysis, validation and.

test activities.- g l . The cable. tray and cable tray. hanger _ design validation procedures-include consideration of variances between the original' design and as-built cable tray hanger systems, control of design documents, analysis assumptions and methods, and design. assumptions _and methods.

The as-built information necessary to verify compliance of. cable trays-and cable tray hangers with design: criteria.was obtained by~walkdowns conducted by experienced Ebasco personnel trained in-accordance'with the-walkdown procedures. The results were used to create as-built drawings of the cable tray _and cable tray hangers. To provide additional assurance of the_ accuracy of the as-built drawings, TV Electric QC personnel verified these drawings-to. the as-built hardware inLaccordance with approved QC procedures.

The issues related to control of design' documents have been' cumulatively addressed by implementation of a QA program which covers as-built design documentation, support drawings, and design validation. calculations.for

, cable trays and cable. tray hangers in Unit l' anc' Common.

m Analysis assumptions-and methods and' design assumptions and criteria have been addressed by the development of procedures >and. instructions, supported by engineering studies, which have systematically: considered each issue.

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SUBAPPE'NDIX A29

' Additionally,ian extensive tsst: program which included component tests ,

.and full _. scale system dynamic tests has provided data showing'the' design t 1

validation approach lis: conservative.e Thus; the actualimargins of. safety-  ;

in the cable tray systems'have been demonstrated to be much. larger thans n

.the margins calculated in-the design' validation program.

In summary,2the design. validation, program has resolved the. technical

' issues.both individually and. collectively, provided'as-built ,

documentation ~ of- the cable tray system designs and' confirmed- the :

conservatism'of:the' design validation. approach through extensive' .

' testing..zThe design validation program assures:that.the designioficable , l tray systems'.is. in conformance with the AISC, Specification: and. licensing, commitments and therefore the margin.of; safety is. acceptable.

1 l 3.0 Corrective and Preventive Action No additional issues ;werel identified during the: review and , ]

l resolution'of this issue.

This' issue was determined.to'be reporfable-under.the provisions of.

<10CFR50.55(e). dIt was reported as Significant. Deficiency AnalysisL.

Report (SDAR) CP-85-35 in letter number TXX 6048, ' dated October.'21,-

O 1986 from TV Electric to the NRC.

3.1 Corrective Action The cable trays and cable tray hangers have_been design validated.using the criteria and procedures discussed in Appendices Al through A28.

3.2 Preventive Action The design validation criteria and procedures discussed in Appendices Al l through A28 have'been established and are documented in the cable-tray 4 and cable tray hanger Design Basis Document (Reference'4.1).-  :

l; 4.0 Referencet 4.1 Comanche Peak Steam Electric Station No'.-1.'and 2. " Cable Tray and:

Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. 0..

July 31, 1987.

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SUBAPPENDIX A30.. U

' CABLE TRAY ~ SYSTEM DAMPING VALUES (CYGNA ISSUE NO. 30/CPRT ISSUE).

1.0- Definition of the' Issue-

~

j Damping values of 4% and.7% have.been used for the evaluation 'of the n Operating Basis' Earthquake:(OBE) and Safe Shutdown. Earthquake:-(SSE) seismic inertial 11oads-respectively, in the design.of.CPSES cable tray ,1 systems. This issue was that these. damping. values may not be: applicable. J to the cable tray systems.

2.0 Issue' Resolution 4 Full-scale dynamic t'ests of. representative cable. tray systems (References ,

4.1 and.4.2) have demonstrated;the validity of using 4% and:7% damping in- -)

the evaluation of OBE and SSE. seismic. loads, respectively.

3.0 Corrective and Preventive Action No additional issues were identified;during the review and resolution of this issue.- j l

This specific issue was determined to be not reportable, in 1 Os1 accordance with 10CFR50.55(e). l 3.1 Corrective Action i None required. >

l 3.2 Preventive Action-The design validation criteria req'uire the' use of.4%-and 7% damping for -

the evaluation of OBE and SSE seismic inertial loads,'respectively. This requirement was established and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.6) and its referenced.

procedures (References 4.3 through 4.5). "

4.0 References >

4.1 ANCO,." Final Summary Report'- Comanche Peak' Cable Tray Tests," ' 0 Rev. 1 May 1987'..

4.2 Impell Report 09-0210-0017, "CPSES Cable Tray Analysis / Test '

Correlation Final Report," Rev. O, February 1987. >

4.3 Impell Instruction PI-02, " Dynamic Analysis .of Cable Tray-Systems," q Rev. 6, October 15, 1987.

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O SUBAPPENDIX A30 CABLE TRAY-SYSTEM DAMPING VALUES (CYGNA ISSUE NO. 30/CPRT ISSUE) 4.4 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray-Hangers for Comanche Peak SES' Unit 2," Rev. 9 July 1,1987.

4.5 Ebasco Document SAG.CP4,_" Seismic Design Criteria for Cable. Tray '-

Hangers for Comanche Peak SES Unit 1," Rev. 6 July 1.1987.:

4.6 Comanche Peak Steam Electric Station No.1 and 2. " Cable Tray and i Cable Tray-Hanger Design Basis Document," DBD-CS-082, Rev. O, fj l July 31, 1987. , Jl l

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l SUBAPPENDIX A31 MODELING OF BOUNDARY CONDITIONS (CYGNA ISSUE NO.'31/CPRT ISSUE) I l

1.0 Definition of the Issite l

The. original cable tray hanger designs-for CPSES~used Hilti Kwik-bolts and Richmond Inserts for anchorage to concrete structures. The design

. drawings specify~that holes in base plates or base angles are to be 1/8 inch larger in diameter than the nominal diameter of.the anchor bolt.- l This issue was that the modeling techniques used to represent anchorage' .

boundary conditions may not have been appropriate due to the presence of l oversize bolt holes. 1 2.0 Issue Resolution Appropriate boundary conditions were determined in References 4.9 and 4.11 and further confirmed by the. Dynamic Testing Program (References 4.1 i and 4.2). The cable tray system dynamic tests demo.nstrated that variance j in bolted anchorages did not significantly influence dynamic response of ~ '

the cable tray systems. In addition, engineering studies (References 4.3 and 4.6) showed that the oversized bolt holes have insignificant effects on the behavior of the base angles. Additional assurance concerning the adequacy of the anchorages was provided by a review of the level of O stress in the, design validated anchorages (References 4.3 and 4.6)..

3.0 Corrective and Preventive Action No additional issues were identified during the review and I resolution of this issue. i This specific issue was determined to be not reportable, in accordance with 10CFR50.55(e). '

3.1 Corrective Action l The oversized bolt holes have insignificant effect on the dynamic characteristics and seismic behavior of cable tray. systems as confirmed l by.the Dynamic Testing Program. The design' validation procedures (References 4.7, 4.8 and 4.10) provide the criteria and methodology for appropriate representation of boundary conditions.

l 3.2 Preventive Action The validated cable tray hanger installation specification (Reference 4.4) has established the requirements for installation of concrete anchorages, including the requirements for base-angle / baseplate hole IO v

1 A31-1 l

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'SUBAPPENDIX A31' size. In-addition, the criteria for modeling of anchorage boundary conditions have been' established'and documented in the cable tray.and'.

cable-tray hanger Design Basis' Document (DBD) (Reference 4.5). .The.

procedures referenced by the DBD.(Reference 4.7, 4.8 and'4.10) provider the methodology ~.for modeling of anchorage boundary: conditions.

Implementation of these procedures by CPSES will assure that. future cable-

' tray and_ cable tray hanger. design modification is performed in.accordance

-with. licensing commitments. LTherefore,'the recurrence of this issue is-precluded.

4.0 References-4.1 Impell Report. 09-0210-0017,:"CPSES Cable Tray System Analysis / Test-Correlation Final. Report," Rev.,0, February 1987.

4.2 ANCO, " Final Summary Report -' Comanche PeakHCable Tray Tests,"

Rev. l', May 1987.

4.3 Impell Calculation M-73, " Acceptability of'0versized. Bolt Holes,."

Rev. 0,' June 22,.1987.

4.4 CPSES Unit 1 and 2, Specification.2323-SS-168, " Structural .

( Steel / Miscellaneous Steel (Category I and II)," .Rev.1, July 14,-

1987.

4.5 Comanche Peak Steam Electric Station No. I and'2, " Cable Tray and-Cable Tray Hanger Design Basis Document,"'DBD-CS-082, Rev.0, July 31, 1987.

4.6 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book'22,... 1 Part 2 " Effects of Bolt Hole Oversize on CTH and Conduit System  !

Adequacy," Rev. 1,' October 23, 1987..

4.7 Ebasco Document SAG.CP34, " General Instructions for! Cable Tray Hanger Analysis for Comanche Comanche Peak SES No. 1 and 2,"

Rev. 11, August 27, 1987.

4.8 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"  ;

Rev. 6. October 15, 1987 .

1 4.9 Impell Calculation M-04,." Base Angle Stiffness," Rev. 3 July 20, 1987.

4 4.10 Ebasco Document. SAG.CPil, " System Anal'ysis.for Cable Tray and' Hanger Assembly for CPSES Units 1 and 2," Rev. 4,' July 1,31987.-

4.11 Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 12, "CTH:

Anchorage Base Plate Flexibility Study," Rev. 0,' June 16, 1986.

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r SUBAPPENDIX A32 ,

CONDUITS ~ ATTACHED TO CABLE TRAYS OR SUPPORTS (CYGNA ISSUE-NO. 32)-

l.0~~ Definition of the Issue?

This issue was that conduit. attached;to cable trays and: cable' tray.

hangers (1-'e. supports) may not have(been properly; included'in design.

7 validation. + ' '

~ 2.0 Issue Resolution The.designvalidationprocedures'forcable. trays'and.cablestrayhangers require that the. effects of attached conduit be. included.in the .

evaluation. The' appropriate conduit"modelling!and evaluation techniques-are'specified'in References 14.liand 4'.2; For the equivalent =statica analysis, the system frequency was evaluated'basedzon:massiparticipation as:specified in Reference 4.1.

3.0 Corrective and Preventive Action

'- No~ additional issues.were identified-during:the review and-resolution of this issue.

A This specific issue- was determined 'to bef not' reportable, in'-

U accordance with 10CFR50.55(e).

' 3.1 Corrective Action Cable trays and cable tray hangers have 'been design validated for the

~

\

effects.of attached conduit, using appropriate' techniques.to determine-cable tray and cable tray hanger response'as-required in ReferencesJ4.1 .

and 4.2.

3.2 Preventive Action

'The design validation proced'ures used to model the conduits attached =to cable trays or cable tray hangers have been developed and documentedLin the cable tray and cable. tray. hanger Design Basis Document (Reference

'4.4). Cable tray and cable tray hangers.have been design validated in accordance'with these procedures (References 4.1.through:4.3).

4.0 References 4.1 Ebasco Document SAG.CP34, "GeneralcInstructions-for Cable-Tray' A Hanger Analysis:for Comanche Peak SES No;;1.and 2,"-Rev. 11 August 27, 1987.

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SUBAPPENDIX'A32

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' 4.2 Impe11' Instruction PI-02, " Dynamic: Analysis of' Cable' Tray Systems,"

Rev. 6,: October: 15,;.1987.

' 4.3 Ebasco Document SAG.CP18,'" Procedure 'for' Qualification 'of Cable '

Trays.for:. Comanche Peak SES Unitc1 and1 2,"'Rev; 3,: October 30, 1987.c-4.4 Comanche Peak Steam Electric' Station No.'I and 2,'" Cable Tray and.

Cable. Tray Hanger. Des.ign. Basis Document," DBD-CS-082,.:Rev. 0,-

July 31, 1987..

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')~ ; 7 fiJ . SUBAPPENDIX A33 J AS-BUILT WALKDOWN PROCEDURES (CYGNA ISSUE NO. 33) a lf 1.0 ' Definition of the Issue.

~

A. This issue.was that it was unclear how the measurement tolerances- f contained.in'the.TU Electric Field Verification Methods (References-4.1 though'4.3) were established and how they were addressed.in the cable tray hanger validation.-

B. This issue was that concerns were raised regarding the cable tray. .

hanger walkdown and inspection procedures with regard to the following areas:

Held acceptance criteria ,

I Measurements of member lengths 4 Determination of the effective throat of penetration ~ welds l'

• Identification of anchor type and embedment -

g Attachment of other items to the cable tray supports C. This issue was that questions-were raised concerning the cable tray span walkdown procedures'(References 4.1 through'4.3) regarding locations of modified connection plates, siderail extensions, and ,

other cable tray components. '

i l 2.0 Issue Resolution JA. Cable tray validation procedures require the use of as-built:  !

information obtained per References 4.1 through 4.3. Measurement i tolerances were addressed in. engineering studies documented in References 4.8 and 4.10. These studies determined that the tolerances Osed in the'walkdown were acceptable.

B. QC inspections were conducted at CPSES in accordance with QI-QP-11.10-9 and QI-QP-11.10-2A (References 4.5 and 4.7)', with

, walkdowns'of cable. tray hangers performed in accordance with l References 4.1 through 4.3. In addition, for design validation of v welds, TU Electric has received NRC approval (Reference 4.21, Section'3.8.3) to use Visual Held Acceptance. Criteria (VHAC)-

(Reference 4.4);at CPSES. In situations where it was not possible.  ;

to determine weld penetration depth, it was assumed ,that the  !

effective throat of full and partial penetration welds was'40% of-the beveled member's thickness based on engineering studies (Reference 4.16). Expansion anchor type and.

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SUBAPPENDIX A33.

p embedment-length,-when unidentified or obscured from view during a-walkdown, were treated as inaccessible attributes in;accordance with References 4.9;and 4.14. The type of attachment and its method of connection to a cable tray hanger were .identifedLin valkdowns .

(References 4.1 and 4.2). Conduits were noted as well!asotheirispan- <

1engths. Thermolag;was assumed:to. extend over.the entire span of the conduit.

C. Modified tray splices;have been located:and design validated as .

specified in References 4.11 and'4.17. (Also.see Subappendix A25).-

Also, sids rail extentions;were located and design validated as in.

~

i

-References l4.12'and 4.13. Tray weights used in the. design-validation of cable.traysiconservately. included the' tray cov,er ,

weight as specified in ReferencesL 4.13, 4.15,^ 4.18,: and 4.19. These .

tray covers are identified as part:oflthe post raceway QC inspection-and separation inspection per Reference-4'.20.

L 3.0 Corrective and' Preventive Action-No additional issues were identified during the'. review and'-

resolution of this issue.

'This specific issue was~ determined to be not reportable.--in:

accordance with 10CFR50.55(e).

3.1 Corrective Action Cable tray hangers-have been design validated using approved.walkdown and QC inspection procedures (References 4.1 through 4.3.-.4.5, and 4.7).

These procedures have addressed the following:.11) as-built measurement tolerances-(References 4.8 and 4.10) -2) approved weld inspection.

-criteria (Reference 4.4), 3) effective throat of full and partial-penetration welds-(Reference 4.16), 4) inaccessible expansion anchor type-and embedment length (References 4.9 and 4.14), 5) externalfattachments,

'their connection and extent of thermolag, 6) modified tray splices (References 4.11 and 4.17), 7) side rail extensions (

References:

4.12.and 4.13) and, 8) tray cover' weights (References 4'.13, 4.15,14.18, and 4.19).

3.2 Preventive Action Thecriteria,requiringconsiderationof'effectsfromitemsasstatedjin- ,

2.0, have been established and documented in the cable tray and. cable tray hanger Design Basis Document (Reference'4.6). (These requirements' have also been included in the cable tray and cable. tray hanger design validation procedures'(References 4.1 through:4.3, 4.5,.4.7, 4.11, 4.13 through 4.15. and 4.17.through:4.20).

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SUBAPPENDIX A33 i

I 4.0 References

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4.1 TV Electric Procedure CPE-FVM-CS-001, " Field Verification Method-Unit 1 Cable Tray Hanger As-Builting and Design' Adequacy. L Verification Program," Rev.' 8,' August -24,1987. ]

4.2 .TU Electric Procedure TE-FVM-CS-003, " Field Verification Method Unit <

2 Cable _ Tray As-Builting and Design Adequacy, Verification Program,"-

Rev. 2, November 21, 1986., q 4

4.3 TV Electric Procedure CPE-EB-FVM-CS-019, " Unit 2. Cable Tray Selected Attributes As-Builting Program," Rev. 2, June 3,:1987.

[ >

1 4.4 NCIG-01, " Visual Held Acceptance Criteria,"' Rev. 2, ' Hay 7,1985.

4.5 TU Electric Instruction QI-QP-il.10-9, ." Modification,' Rework and L As-Built Inspection / Verification of Cable Tray Hangers.in Unit'.1 "

p Rev. 8, May 7, 1987, 1

4.6 Comanche Peak Steam Electric Station No. I and 2, " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev.10,;

July 31, 1987.

4.7 TU Electric Instruction QI-QP-11.10-2A, " Inspection of Unit'II. Cable Tray Supports," Rev. 11, October 22, 1986. U 4.8 Impell Report, "Effect of Measurement Tolerances Used-for Collection- I l of As-Built Data," IM-P-009, Rev.-0, May 15, 1987.

.l l 4.9 Joint Impell/Ebasco Approach Towards Design Verification of Inaccessible Attributes, IM-T-0210-040-238, May.15, 1987..

4.10 Impell Calculation M-69, " Cable Tray As-Built Measurement Tolerances," Rev 1, July 17, 1987.

4.11 Impell Instruction PI-06, " Tray'and Clip Qualification," Rev. 1, j October 20, 1987, with Addendum dated 02/02/87.  ;

4.12 Impell Calculation M-39, " Side Rail Extensions Study," Rev. 2,  !

July 27, 1987. '

4.13 Ebasco Document SAG.CP34,'" General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No. l'and 2,"-Rev. II, August 27, 1987. .

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I SUBAPPENDIX A33 4.14Impell'InstructionPI-il,"CableTraySystemAnalysisLand-

~

Qualification Closeout," Rev. 3, October 15, 1987.

4.15 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray-Systems,"'

Rev. 6, October 15,.1987.

4.16 Ebasco Volume 1,' Book-20, "CTH Held Related Studies,":Rev. 4,

October'8, 1987.

4.17 Ebasco Document SAG.CP18, '" Procedure .for Qualification of. Cable' Trays for Comanche Peak SES Units 1'and 2,";Rev. 3,' October 30, 1987.

4.18 Ebasco' Document SAG.CP3, " Seismic Design Criteria for Cable' Tray Hangers for Comanche Peak. SES Unit 2,":Rev. 9,; July l',1987.

4.19 Ebasco-Document SAG.CP4, " Seismic Design Crite ia' for Cable Tray- 3 Hangers for Comanche Peak SES Unit.1," Rev. 6, July 1,J1987.

4.20 TV Electric Instruction QI-QP-11.3-40, " Post Construction Inspection j' of Electrical Equipment and Raceway,":Rev. 26, February 3, 1987.

, p 4.21 U.S. Nuclear Regulatory Commission, Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units-1 and 2, NUREG-0797, Supplement No. 12, October, 1985.

l a

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SUBAPPENDIX A34 SYSTEM ANALYSIS METHODOLOGIES-(CYGNA ISSUE NO. 34) 1.0 Definition of the Issue A. SUPERPIPE Error.'SP-004 involved the incorrect assignment of lumped directional masses for static load cases. .The method to work around this error, provided in the Program User Notice SP-004, was-incorporated in:the validation. procedures (Reference,4.1). .The error was subsequently corrected in SUPERPIPE Version 21A and the

" work around" was no longer required.

This issue was that cable tray' system analysis number 176-063-02 .

l applied the " work around" for Error SP-004 in SUPERPIPE. Version 21A, a version in which the error had been corrected.

l B. Analytical decoupling methods were used to subdivide cable. tray I

systems that could not be divided at tray ends._ To eliminate boundary effects in the decoupled models, three cable tray hangers-past the analysis boundary were, included in the analysis. The region including the hangers past the analysis ~ boundary was termed l the " overlap region." This-issue was that cable trays and cable I

tray hangers in the " overlap region" of response spectrum analyses g were evaluated using a load factor of 1.1 without justification.

i 2.0 Issue Resolution .:

A. This issue was identified and documented in an internal Technical Quality Review (TQR) conducted in accordance with Impell-Quality  ;

Assurance (QA) procedures prior to identification of the issue by '

external sources. The response to this TQR required that cable tray i system analysis number 176-063-02 be reviewed to determine the impact of applying the correction to SUPERPIPE Error SP-004 in a  ;

version of SUPERPIPE not affected by that error. It was demonstrated that the results of' cable tray system analysis number '

176-063-02 were conservative despite the application of the correction for Error SP-004. In addition, the corrective action for ,

the Technical Quality Review (TQR) required that other cable tray i system analyses potentially impacted in the same way be reviewed for resolution. No other occurrences of.this issue were identified.

Thus, this issue was resolved through implementation of the Impe11 1 Quality Assurance Program. y B. Reference 4.3 documents an engineering study which developed the i overlap criteria using the results of partial models with overlap regions compared to the results of full models of the same cable tray systems. The criteria which was established by the' study did ,

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i not require the.use of a load ? increase factor in the overlap region -

to appropriately calculate the cable tray system response. However,- l to assure' conservative analysis results in the overlap region a -load factor of 1.1 was applied to the overlap trays and hangers. . This-factor was established-from a review of other structural overlap  :;l criteria (Reference 4.4).  :

3.0 Corrective and Preventive Action No additio'nal' issues were ' identified during the review and-resolution of this issue.

This specific issue was determined to be not reportable under 'i 10CFR50.55(e). 1 1 3.1 Corrective Action 1

A. None required. l t

B. None required.

p 3.2 Preventive Action .i V

A. None required.

B. None required.

4.0 References 4.1 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"  !

Rev. 6, October 15, 1987. <

4.2 Impell Position Paper IM-P-001, " Impact of SUPERPIPE Error SP-004 on i Evaluation 176-063-02," Rev. O, May 15, 1987.

4.3 Impe11 Calculation M-13. " Development of Seismic Overlap Procedures," Rev. 3, May 30, 1986.

4.4 Brookhaven National Laboratory Study, " Overlap Criteria in Piping,"

Rev. 0, March, 1981.

4.5 Comanche Peak Steam Electric Station No. 1 and No. 2, " Cable Tray I and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. O, ,

July 31,'1987.

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l SUBAPPENDIX A35 I]

v FAILURE TO PROPERLY INSPECT CABLE TRAY HANGERS (NRC NOV 50-445/8416-V-01) J 1.0 Definition of the Issue This issue was that QC inspectors failed to identify and document conditions where cable tray hangers were installed to conditions other than those specified by the original design documents.

2.0 Issue Resolution i Complete inspection of cable tray hangers of Unit 1 and Common has been performed in accordance with References 4.1 through 4.5. As-built, ,

information obtained by cable tray and cable tray hanger Corrective i Action Program (CAP) Engineering Personnel was independently reviewed by the TV Electric Quality Control Personnel. As-built conditions have been design validated in accordance with the criteria of References 4.7 through 4.17.

3.0 Corrective and Preventive Action No additional issues were identified during the review and n resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55 (e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-52 in letter number TXX 4657, dated December 20, 1985 from TU Electric to the NRC.

) 3.1 Corrective Action Cable tray and cable tray hangers have been design validated during the performance of the Corrective Action Program (CAP) using as-built information obtained from independent validation and inspection activities as required by design validation (References 4.1 through 4.5 and 4.7 through 4.17).

l 3.2~ Preventive Action The validated cable tray hanger installation specification (Reference 4.18) provides assurance that cable tray hanger installations conform with the design requirements. The criteria established in the cable tray and cable tray hanger Design Basis Document (Reference 4.6) and its referenced procedures (References 4.1 through 4.5 and 4.7 through 4.17) provide assurance that cable tray and cable tray hanger design validation are based on as-built information obtained from independent validation and inspection activities.

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SUBAPPENDIX A35 q

4.0 References 4.1 TU Electric Procedurei QI-QP-11.10-9, " Modification, Rework and. )

'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1," ~8 Rev. 8~, May 7, 1987. -f 4.2 TU Electric Procedure, QI-QP-11.10-2A,. " Inspection of Unit 2 Cable

~

Tray Supports," Rev. 11', October 22, 1986. j l

4.3 TU Electric Procedure, CPE-FVM-CS-001, " Field Verification Method' l Unit 1 Cable Tray Hanger As-Builting and Design _ Adequacy  ;

Verification Program," Rev. 8 August 24, 1987.

4.4 TU Electric Procedure TE-FVM-CS-003, " Field Verification Method Unit -

2 Cable Tray Hanger As-Builting and Design Adequacy Verification j Program," Rev. 2, November 21, 1986. '

4.5 TU Electric Procedure TE-FVM-CS-036, " Field Verification Method As-Built Verification of Attachments to the Main Structural Framework in the Cable Spread Room. Supporting Unit'l Designated l Cable Trays and' Selected Attributes of Unit 1 Cable Trays Rev. 0,_

, February 19, 1987.

4.6 Comanche Peak Steam Electric Station No.1 and 2, " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. 0,'

July 31, 1987.

l 4.7 Ebasco Document SAG.CP4, " Seismic Design Criteria for Cable Tray hangers for Comanche Peak SES Unit 1,".Rev 6,' July-1,1987.

4.8 Ebasco Document SAG.CP3, " Seismic Design Criteria for Cable Tray-Hangers for Comanche Peak SES Unit 2," Rev. 9, July 1, 1987. ,

4.9 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems,"

Rev. 6, October 15, 1987.

4.10 Impe11 Instruction PI-03, " Qualification of Cable Tray Supports,"

Rev. 5, October 20, 1987.

4.11 Impe11 Instruction PI-06, ~ " Tray and Clip Qualification," Rev.1, October 20, 1987, with Addendum dated 02/02/87. l l 4.12 Impe11 Instruction PI-07, " Design Verification of Base Plates, Base Angles, and Embedment Plates'," Rev. 3 September 16, 1986, with Addenda dated 01/07/87, 01/19/87, and 09/30/87.

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SUBAPPENDIX A35 .

4.13 Impell Instruction PI-11; " Cable Tray System Analysis-and Qualification Closeout" Rev. 3, October 15 .1987.

.4.14 Ebasco Document SAG.CP11, " System Analysis for. Cable Tray and Hanger -)

Assembly for CPSES Units 1_and 2," Rev. 4, July 1./1987. j l

4.15 Ebasco Document SAG.CP18. " Procedure for Qualification of' Cable' Trays.for Comanche Peak SES Units'1 and 2," Rev. 3, October.30 1987.

- ]

d 4.16 Ebasco Document SAG.CP19, " Design Criteria;and Procedures for.1 Design. i

. Verification for Cable Tray Clamps for Comanche Peak SES Units 1.and-2," Rev. 4, October. 30, 1987.

4.17 Ebasco Document SAG.CP34 " General. Instructions:for Cable. Tray Hanger.

Analysis for Comanche Peak SES No. 1 and 2," Rev..11.-August 27, 1987. i 4.18 CPSES Unit 1 and 2, Specification 2323-SS-16B, " Structural .

Steel / Miscellaneous Steel (Category I and;II)," Rev. 1, July:14,..

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nV APPENDIX B

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CORRECTIVE ACTION PROGRAM (CAP) ISSUES ~

This appendix describes the detailsLof resolutions of issues identified during the performance of the Corrective' Action' Program. Included in this Appendix. l are the cable tray and cable tray hanger. related Significant Deficiency '

Analysis Reports (SDARs). Impell/Ebasco have reviewed the Safety Evaluation j Report (SER) and its supplements (SSERs)'and determined that'the cable tray j and cable tray hanger design criteria, design procedures and validated  :

hardware are consistent with the NRC staff positions stated in the SER and its j supplements (SSERs). Specific' references to the criteria, procedures, l engineering studies,.and tests which have resolved the issue are provided.

]

To report the resolution of issues identified during performance of the I Corrective Action Program (CAP), an individual subappendix was developed for i each issue. Each subappendix includes: a definition of the issue; issue  ;

resolution; and corrective and preventive action. (

The preventive action is embodied in the procedures developed and used in the ,

cable tray hanger Corrective Action Program (CAP). These procedures resolve  !

the cable tray hanger Corrective Action Program (CAP) issues. Implementation of these preventive actions will assure that the design and hardware for CPSES  :

O Unit 1 and Common will continue to comply with.the licensing commitments throughout the life of the plant as described in Section 5.4.

Corrective Action Program (CAP) issues contained in Appendix B are listed ..

below:

Issue No. Issue Title B1 SDAR-CP-83 Bolting Haterial for Cable Tray Hanger Clamps.

B2 SDAR-CP-85 Cable Tray Hanger Design.

B3 SDAR-CP-85 Cable Tray Tee Fittings.

B4 SDAR-CP-85 Cable Tray Hanger Reverification Program. ,

B5 SDAR-CP-86 Cable Tray Splices / Connections.  !

B6 SDAR-CP-86 Cable Tray Hanger Splice Helds.

B7 SDAR-CP-87 Cable Tray Transverse Clamps.

B8 SDAR-CP-87 Improper Application of Construction Aids B9 SDAR-CP-87 Field Drilled Cable Tray Holes B-1

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'!%.I SLIBAP'PENDIX B1 SDAR CP-83-15. BOLTING MATERIAL FOR CABLE TRAY HANGER CLAMPS

.I 1.0 Definition of the Issue LThis issue was that the structural drawings showing. bolted attachments'of-5 cable trays to associated hangers required the..use of A-325 (high .

strength) bolting materials, _however, a field walkdown.of as-installed conditions (References 4.1 and 4.2). revealed that A-307 (mild steel) bolts were used. .This. type of bolting material was not acceptable per the design' detail requirements. Improper use .of, A-307. steel could result in the. separation'of the-tray from the hanger during a' seismic event.'

'2.0. Issue Resolution ,-

The Post Construction Hardware Validation' Program'(PCHVP) of cable? tray hanger attributes determined the as-built' bolt material..and diameter'used for connections of clamps to structural members. .This' data was- ..

identified and recorded on the as-built drawings and.was. considered in the validation of the clamp assemblies. Bolts'which do not' comply.with-the design requirements will be replaced.-

3.0 Corrective and Preventive' Action No additional issues were identified.during the review:and resolution of this issue.

This issue was determined to be reportable.under.the provisions of 10CFR50.55(e). It was reported as Significant~ Deficiency Analysis Report (SDAR) CP-83-15 in letter number TXX 4005, dated July 12, 1983 from TU Electric to.the NRC.

. 3.1 Corrective Action '

Replacement of A-307 bolts with A-325 bolts where necessary will be.

completed as part of the PCHVP.

L 3.2 Preventive Action The cable tray and cable tray hanger procedures (References 4.3 and 4.4) have been' established and are documented in the cable tray and. cable tray hanger Design Basis Document (Reference 4.5). The validated. installation?

specification (Reference 4.6) requires the use of A-307 or high . strength; bolting materials. The installed bolting' hardware is inspected per~

1 References 4.7:and 4.8.

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SUBAPPENDIX B1. i.

Li

. j 4.0 Referencesi i

~

4. l' TU Electric Procedure' CPE-FVM-CS-001, " Field Verification Method . '

Unit.1 Cable' Tray Hanger As-Builting and Design.Adequacys Verification Program," Rev..: 8, August 24, 1987.1

! '4.2 - TU Electric Procedure TE-FVM-CS-003,'" Field Verification ' Method Unit -

2. Cable Tray' Hanger: As-Builting and Design Adequacy Verification-

~

Program," Rev'J2,' November 21,'1986.

+

o 4.3- Impe11 Instruction PI-06, " Tray and. Clamp Qualification,".Rev.fl,~  !

October 20, 1987, with Addendum dated.02/02/87. '

{

4.4 Ebasco ProcedurelSAG.CP19.1" Design Criteria ~ and' Procedures form Design Verification lof Cable Tray Clamps ~.for CPSES UnitsLI. and.2," . ,

Rev. 4, October-30, 1987.

'~

'I 4.5 Comanche Peak Steam Electric Station No.1 and2, " Cable l Tray and: 1 Cable 1 ray Hanger Design Basis: Document;".DBD-CS-082,,Rev. 0,' July. l

.31, 1987. -

i 4.6 CPSES Unit I and'2; Specification Structural: Steel / Miscellaneous:

F 1 Steel-(Category I-'and II),'2323-SS-16B,-Rev. 1, August:14, 1987..

, 4.7 TU Electric Procedure. QI-QP-11.10-9 R8, May :7~,.1987,E " Modification, '

Rework, and 'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1."

4.8 TU Electric Procedure QI-QP-11.10-2A Ril,: October 22,.1986,

" Inspection of Unit'II Cable Tray Supports."

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e V SUBAPPENDIX B2 SDAR CP-85-35. CABLE TRAY HANGER DESIGN 1.0 Definition of the Issue This issue was that discrepancies may have existed between as-built and as-designed cable tray hanger configurations (Reference 4.1) and that original design criteria may not have appropriately addressed 'certain design requirements. A description of these concerns was provided in Subappendices Al through A29 of this report.

2.0 Issue Resolution To resolve this issue TU Electric initiated the cable tray and cable tray hanger Corrective Action Program (CAP). Under the Corrective Action Program (CAP), resolution of this issue was accomplished through identification of licensing commitments, establishment of design criteria and development of design validation procedures (Reference 4.2) that included the following:

Use of as-built data as design input for cable tray and cable tray

,S hanger validation.

Validation of cable trays and cable tray hangers to design criteria I' that is in compliance with CPSES licensing commitments, and responsive to all Comanche Peak Response Team (CPRT) and external issues.

Extensive state-of-the-art testing and engineering studies implemented to provide additional confidence in the conservatism of the design validation procedures used for cable trays and cable tray hangers.

l l Implementation of hardware modifications as necessary to assure that all cable tray and cable tray hangers comply with the validated design.

Resolutions to the related issues are discussed in Subappendices Al through A29 to this report.

3.0 Corrective and Preventive Action l No additional issues were identified during the review and l

resolution of this issue.

n i a Q)

B2-1

i b, SUBAPPENDIX B2 1

This issue was determined to be reportable under the provisions of a 10CFR50.55(e). It was reported as Significant Deficiency Analysis J Report (SDA.R) CP-85-35 in letter number TXX 6048, dated October 21, i 1986 from TU Electric to the NRC.

3.1 Corrective Action )

}

Cable trays and cable tray hangers have been design validated in i accordance with the design validation procedures (References 4.3 through 4.15). These procedures include the design criteria that comply with the 1 CPSES licensing commitments, and are responsive to the Comanche Peak Response Team (CPRT) and external issues. The cable tray and cable tray l hanger hardware is being validated in accordance with the Post Construction Hardware Validation Program (PCHVP) (References 4.16 through 4.24). I 3.2 Preventive Action The design criteria and procedures (References 4.3 through 4.15),

responsive to the Comanche Peak Response Team (CPRT) and external issues (Reference 4.1), have been established and documented in the cable tray

( ,)

1 and cable tray hanger Design Basis Document (Reference 4.2).

v 1

.I 4.0 References 1

4.1 Comanche Peak Response Team Action Plan, DSAP VIII, {

" Civil / Structural Discipline Specific Action Plan," Rev. 1,  ;

l January 24, 1986. j 4.2 Comanche Peak Steam Electric Station No. I and 2 " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. O, l July 31, 1987. .l i

4.3 Impell Instruction PI-02, " Dynamic Analysis of Cable Tray Systems," }

Rev. 6 October 15, 1987.

4.4 Impell Instruction PI-03, " Qualification of Cable Tray Supports,"

Rev. 5, October 20, 1987.

h 4.5 Impell Instruction PI-06, " Tray and Clip Qualification," Rev.1, l

October 20, 1987, with Addendum dated 02/02/87. ,

l 4.6 Impell Instruction PI-07, " Design Verification of Base Plates, Base j Angles, and Embedment Plates," Rev. 3, September 16, 1986, with j Addenda dated 01/07/87, 01/19/87, and 09/30/87. 4 i

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4.7 Impell Instruction PI-11, " Cable Tray System Analysis and Qualification Closeout," Rev. 3, October 15, 1987.

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. 1 r SUBAPPENDIX B2' 4.8 Ebasco Document SAG.CP4, " Seismic Design' Criteria for Cable. Tray ' I Hangers.for Comanche Peak SES Unit 1," Rev. 6, July 1,11987. ,

4.9 Ebasco Document. SAG.CP3, " Seismic Design Criteria for. Cable Tray Hangers for Comanche Peak SES Unit-2," Rev.'9.. July 1,;1987.

]

, 4.10 Ebasco Document SAG.CP34, " General Instructions for Cable Tray ,

l Hanger ~ Analysis for Comanch'e Peak SES No. I and 2," Rev.-11,

. August 27, 1987.

f-I 4.11 Ebasco Document SAG.CP09, " Instruction for Re-Evaluation of Cable Tray Hangers Affected:by the Longitudinal Tie of Transverse Hangers:  ;

to the Tray for-CPSES Unit 2," Rev. 0. March,17, 1986.

- 4.12 Ebasco Document SAG.CP18, " Procedure for Qualification of Cable Trays for Comanche Peak SES Units 1-and 2',"'Rev. 3, October ~30, 1987.

4.13 Ebasco Document SAG.CP28, " Procedure for: Screening of Cable Tray y Hangers to Assess the Applicability of a.l.25 MRM in Equivalent- '

Static Method Analysis in Hanger Design Verification forl Comanche.

Peak SES Units 1 and 2," Rev. 3,' August 19, 1987. ~

k 4.14 Ebasco Document SAG.CPil, " System Analysis for. Cable Tray and Hanger Assembly for CPSES Units 1 and 2," Rev. 4. July 1, 1987. i 4.15 Ebasco Document SAG.CP19, " Design Criteria and Procedures .for Design Verification of Cable Tray Clamps .for Comanche Peak SES Units 1;and 2," Rev. 4, October 30, 1987.

4.16 TV Electric Procedure CPE-FVM-CS-001~, " Field Verification Method-Unit 1 Cable Tray Hanger As-Builting and Design Adequacy Verification Program," Rev. 8, August 24, 1987. ,

4.17 TU Electric Procedure TE-FVM-CS-003, " Field Verification Method Unit-2 Cable Tray Hanger As-Builting and Design Adequacy Verification Program," Rev. 2, November 21, 1986.

4.18 TU Electric Procedure CPE-EB-FVM-CS-019, " Unit 2 Cable Tray' Selected l Attributes As-Builting Program," Rev. 2, June 3, 1987.  !

4.19 TU Electric Procedure TE-FVM-CS-036, " Field Verification Methot As-Builting Verification of Attachments-to the Main Structural' Framework in the Cable Spread Room Supporting Unit 1. Designated-Cable Trays and Selected Attributes of Unit 1 Cable Trays," Rev. O, ';

February 19, 1987.

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SUBAPPENDIX B21 1

~

4.20 TU Electric Procedure .TE-FVM-CS-048. " Field Verification Method.Uniti <

1 Cable Tray-Selected Attributes As-Built Program;" Rev.: 0, '

l l

December 31, ' 1986 ~. i 4.21 TU Electric Procedure.TE-FVM-CS-050, " Field Verification Hethod ,T.J. i

Cope; Flat Ladder.. Tee Fitting Selected Attributes Data Collection," <

Rev. 0, January 5, 1987.

4.22 TU Electric Procedure CPE-EB-FVM-CS-084, " Field Verification'Hetho'd: , 1 Engineering Halkdown:for Replacement of Cable Tray Fittings.in Unit; o' l'and 2," Rev. O, July 28,'1987.

4.23 TV Electric Procedure.'CPE-EB-FVM-CS-098,T" Field: Verification'Hethod -

Cable Tray Rung Spacing Walkdown Unit 'l 'and 2,"'Rev. 0, July l28, 1987.

.4.24 TU Electric Procedure CPE-EB-FVM-CS-100,o" Field Verification Method a Cable ~ Tray Hanger Walkdown:for Clamp Identification for Unit 1," _

i Rev.'0, September 9, 1987.-

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SUBAPPENDIX B3-:

SDAR:CP-85-500 CABLE TRAY TEE FITTINGS

,1.0 e Definition 'of the Issue "

d Thist issue was that as-built welds on tray-Tee fittings were not in l(

accordance with the welding: specified on vendoridrawings.. The. . ..

information provided in the vendor drawings,Lfor weld' symbols, spacing ofL d intermittent welds, weld length.and location, and members to be; joined . 4 was inadequate and,was' the cause of the occurrence of the discrepant (

i welds found in some Tee. fittings. '

'l 2.0 Issue Resolution M 1

As a part:of the Post Construction: Hardware Validation Program (PCHVP), l Tee fitting welds were as-built (Reference 4.1) andLeompared tol vendor-weld requirements. Helds which do not meet the minimum vendor' requirements will. be modified.to meet the requirements.. ,

jl j

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution 1 of this issue.

This issue was determined to'be reportable'under the provisions of- 0 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-50 in letter number TXX 6771',: dated SeptemberL30..

j 1987 from TV Electric to the NRC.

d 3.1 Corrective Action 1 The' Post Construction Hardware Validation Program has. inspected'the vendor Tee fitting welds (Reference 4.1).to determine which welds'do not conform to design requirements.. Those welds which dolnot' conform'to the design requirements are being modified to' meet the requirements.

3.2 Preventive Action The installation specification (Reference 4.2) provides. assurance that.- -l as-built cable tray. Tee fitting welds. match the Tee' fitting welds j specified on engineering or vendor: drawings. i 4.0 References 4.1 TU Electric Field Verification Method TE-FVM-CS-050, " Field Verification Method T.J. Cope' Flat Ladder Tee Fittings Selected.

Attributes Data Collection," Rev.;0,! January 5, 1987.

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                                             $UBAPPENDIX"B3 ,

4.2 Comanche Peak Steam Elebtric~ Station Units 11 and 2, " Cable Trays," Specification No. 2323-ES-19, Rev.1,: November 22',.1976. .with DCA No. 41204 l O ,

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O SUBAPPENDIX B4 SPAR CP-85-52. CABLE TRAY HANGER REVERIFICATION PROGRAM 1.0. Definition of the Issue A field verification' and inspection program was initiated for cable tray hangers for the purpose of gathering-as-built information which would be used to verify the' structural integrity of the cable tray hangers in CPSES Unit 1. This issue was that discrepancies existed in the: verification and inspection program. l-2.0 Resolution of the Issue Validation and. inspection activities.were performed for' t'he entire cable. tray and cable tray hanger system using personnel trained in Field- , Verification Methods and Inspection Procedures (References 4.1 through ' 4.11). Only walkdown and inspection information obtained by trained personnel was used as design input for.the design validation. 3.0 Corrective and Preventive Action-No additional issues were identified during the review and

   /7                                                         resolution of this issue.

IV

• This issue was determined to be reportable und'er'the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-52 in letter number TXX 4657, dated December.20, 1985 from TU Electric to the NRC.

3.1 Corrective Action ' The verification and inspection results of the original program were not used. The entire cable tray and cable tray hanger system was validated and inspected using personnel trained in'the TU Electric Field ~ Verification Methods (References 4.1'through 4.11). 3.2 Preventive Action The criteria, requiring validation and inspection of the cable trays and-cable tray hangers to be performed by personnel trained in the TU Electric Field Verification Methods (Reference 4.1 through 4.11), have been established and documented in the cable tray and cable tray hanger Design Basis Document (Reference 4.12).

  .(

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cV SUBAPPENDIX B4 4.0 References 4.1 TU Electric Procedure CPE-FVM-CS-001, " Field Verification" Method Unit 1 Cable Tray Hanger As-Builting and Design Adequacy-Verification Program," Rev. 8, August. 24,.1987. 4.2 TV Electric Procedure TE-FVM-CS-003, " Field Verification Method Unit 2 Cable Tray Hanger As-Builting and Design Adequacy Verification 1 Program," Rev. 2 November 21, 1986. 4.3 TU Electric Procedure CPE-EB-FVM-CS-019, " Unit 2 Cable Tray Selected- 1 Attributes As-Bullting Program," Rev.'2, June 3, 1987.

                                                                              ~

j 4.4 TU Electric Procedure TE-FVM-CS-036, " Field Verification Method l As-Built . Verification of Attachments to the Main. Structural-Framework in the Cable Spread Room Supporting Unit 1 Designated Cable Trays and Selected Attributes of Unit 1 Cable Trays," Rev. O, February 19, 1987. 4.5 TU Electric Procedure TE-FVM-CS-048, " Field Verification Method Unit 1 Cable Tray Selected Attributes As-Built Program,"' Rev. O, December 31, 1986.

                                                                                           )

4.6 TU Electric Procedure TE-FVM-CS-050, " Field Verification-Method T.J. Cope Flat Ladder Tee Fitting Selected Attributes Data Collection," ' Rev. O, January 5, 1987. 4.7 TU Electric Procedure CPE-EB-FVM-CS-084, " Field Verification' Method Engineering Halkdown for Replacement of Cable Tray-Fittings in Unit , 1 and 2," Rev. O. July 28, 1987. 4.8 TU Electric Procedure CPE-EB-FVM-CS-098, " Field Verifictdion Method Cable Tray Rung Spacing Walkdown Unit 1 and 2," Rev. O, July 28, 1987. 4.9 TV Electric Procedure CPE-EB-FVM-CS-100, " Field Verification Method - Cable Tray Hanger Walkdown for Clamp Identification for Unit 1," Rev. O, September 9, 1987. 4.10 TU Electric Procedure, QI-QP-11.10-9, " Modification, Rework and

               'As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1,"

Rev. 8, May 7, 1987.  ! 4.11 TV Electric Procedure, QI-QP-11.10-2A, " Inspection of Unit. II Cable Tray Supports," Rev. 11, October 22, 1986. (O v B4-2. L

y,~ g 4 4

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      ;                                                                SUBAPPENDIX B4 4.12 Comanche Peak Steam Electric. Station No~. 1 and.2'"'
                                                                                                  , . Cable Tray and Cable Tray Hanger Design' Basis Document," DBD-CS-082, Rev. O, July 31, 1987..

O ;I a O B4-3 .j

O SUBAPPENDIX B5 SDAR CP-86-52. CABLE TRAY SPLICES / CONNECTIONS 1.0 Definition of the Issue  ! This issue was that cable tray splices were not installed in accordance  ; with approved splice configurations, as summarized below.  ; Cable tray splice connections in Unit 1 and Common Area may have used splice plates that were not approved designs or may have incorrectly used approved. splice plates. Installation of splice plates that were not design approved may have resulted in unused bolt holes in cable trays. Original design calculations did not consider unused holes in cable trays. l l Improper installation of splice plates may have resulted in unused i bolt holes in the splice plate. Original design calculations did l not consider unused holes in splice plates. , Splice plates may have been installed in placa .of reducer fittings (special splice plates for use with reducer) on Unit 2 and Common

  ,             cable trays. Original design calculations did not consider the use

{3j of splice plates in place of reducer fittings. 2.0 Issue Resolution Cable tray splice connections installed using configurations that were not approved will be identified in their as-built configuration during the Post Construction Hardware Validation Program (PCHVP) i (References 4.1 and 4.2). Splice connections that do not comply with the design criteria (Reference 4.3) will be identified and replaced with validated designs. Unused holes in cable trays which do not comply with the design criteria will be identified during the Post Construction Hardware Validation Program (PCHVP) (References 4.1 and 4.2). Unused holes that are not acceptable will be repaired in accordance with validated procedures. Splice plates with unused holes will be identified during the Post Construction Hardware Validation Program (PCHVP) (References 4.1 and

                                                                                                          ~

4.2). Splice plates with unused holes that do not comply with the ( design criteria (Reference 4.3) will be replaced with validated designs, t i v) B5-1

i p vi SUBAPPENDIX 85 i Splice plates used in place of reducer fittings will be identified i during the Post Construction Hardware Validation Program (PCHVP) 1 (References 4.1 and 4.2). Spliced reducers that do not comply with the design criteria (Reference 4.3) will be replaced with validated l designs. 1 i 3.0 Corrective and Preventive Action No additional issues were identified during review and resolution of this issue. j l l This issue was determined to be reportable under the provisions of l 10CFR50.55(e). It was reported as Significant Deficiency Analysis i Report (SDAR) CP-86-52 in letter number TXX 4981, dated August 22, i 1986 from TU Electric to the NRC. ' 3.1 Corrective Action Cable tray splice connections that were installed using configurations that were not approved, as discussed above, will be identified (References 4.1 and 4.2) and design validated in their as-built (~'l configuration during the Post Construction Hardware Validation Program () (PCHVP). Configurations that do not comply with design criteria are being modified in accordance with the validated design. 3.2 Preventive Action l The cable tray installation specification (Reference 4.5) has been revised to include approved splice plate configurations-to preclude the i misuse or improper installation of new or modified splice connections. The cable tray inspection procedure (Reference 4.4) is being revised to include apprcved splice plate configurations. Inclusion of the approved splice plate configurations in the installation and inspection procedures will eliminate the potential for unused bolt holes in cable trays and the use of nonapproved splice plates. In addition, the installation and inspection procedures will not allow the use of splice plates in place of reducer fittings. 4.0 References 4.1 TU Electric Procedure TE-FVM-CS-048, " Field Verification Method Unit I 1 Cable Tray Selected Attributes As-Built Program," Rev. O, i December 31, 1986. 1 4.2 TU Electric Procedure CPE-EB-FVM-CS-019, " Supplemental Procedure for Unit 2 Halkdown - Selected Cable Tray Attributes Data Collection (N Unit 2," Rev. 2, June 3, 1987. V, B5-2

T i s SUBAPPENDIX B5

    '4.3. Comanche Peak Steam Electric Station No; 1.and 2, " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082,-Rev.0, July.31, 1987.                                                                                    q 4.4 TU Electric Procedure, QI-QP-11.3-24, " Class lE Cable ~ Tray Raceway Inspections," Rev. 17, March 26, 1987.

4.5 TU Electric Specification 2323-ES-100, " Electrical Installation. Class 1, 2, and Non-Safety," Rev. 3 June 5, 1987. j l O i 1 l I i . O. B5-3

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           )                                      SUBAPPENDIX B6                              1 i)

SDAR'CP-86-82. CABLE TRAY HANGER SPLICE HELDS l 1.0 Definition of the Issue The original installation specification required the use of full penetration welds when channel sections were spliced'end-to-end. Thi ~s .. issue .was that during the as-built program, non-destructive ~ tests 'of a i sample of these welds showed a lack of penetration. 2.0 Issue Resolution l l The review of cable tray hanger as-built drawings and non-destructive testing results identified the location of all' channel section splices which did not have full penetration welds. These splices were modified to meet the design criteria. 3.0 Corrective and Preventive Action l No additional issues were identified during the review and resolution of this issue. I fi V This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-86-82 in letter number TXX-6201, Dated January 6, 1987 from TU Electric to the NRC. 3.1 Corrective Action - As a part of the Post Construction Hardware Validation: Program (PCHVP), all cable tray hangers have been reviewed to determine if channel section splices which did not have full penetration welds exist. The review of cable tray hanger as-built drawings and non-destructive testing results l identified the location'of all channel section splices which did not have-l full penetration welds. These splices were modified to meet the design criteria (Reference 4.3). 3.2 Ereventive Action Construction procedures which address cable tray hanger installation have 1 been revised to correct this condition (References 4.1 and 4.2). The affected craft personnel have also been retrained to these procedures, I assuring that there will not be a recurrence of this problem. 4.0 References 4.1 CPSES Construction Procedure ECP-10. " Cable Tray and Hangers Installation - Unit 1," Rev. 9, January 13, 1987. 5 B6-1

i-I t :SUBAPPENDIX B6 SDAR CP-86-82. CABLE TRAY HANGER SPLICE WELDS 1 d i 4.2 CPSES Construction-Procedure ECP-10A, " Cable Tray.and Hangers; Installation - Unit 2," Rev. 5,. August 28, 1987. 4.3 Comanche Peak Steam Electric Station No -1 and 2, " Cable Tray.and

          . Cable Tray Hanger Design Basis Document," DBD-CS-082,:Rev. 0,-

July 31, 1987. 1 i

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1 y SUBAPPENDIX B7 1

                                                'SDAR CP-87-48. CABLE TRAY-TRANSVERSE CLAMPS i

1.0 Definition'of the' Issue- 4 a This. issue was that a combination ofLcertain' type.s;of transverse cable tray clamps was found which could not' prevent separation of tray and. 1 hanger when. subjected to transverse movement. 1 2.0 Issue Resolution- _.

                                . As part'of the Post Construction Hardware Validation Program.(PCHVP), a'<                         j
                                 -walkdown of all: installed clamp. combinations will be performed in                                  1 accordance with Reference 4.1. -Unacceptable clamps will:either be-                        .

i replaced by.an' acceptable clamp or an additional clamp will be.provided 1 to prevent separation of tray and hanger when. subjected'to transverse movement. -l 3.0 Corrective and Preventive Action No additional issues were identified during the~ review:and h resolution of this issue, t This issue was determined to be. reportable under'the provisions of 10CFR50.55(e). It'was reported as Significant Deficiency- Analysis Report (SDAR) CP-87-48 in letter number TXX-6658, dated August 21, 1987 from TV Electric to'the NRC. ,

                                                     ~

3.1 Corrective Action Identification and repair / replacement of unacceptable tray clamp combinations is being performed during the Post Construction Hardware Validation Program (PCHVP). 3.2 Preventive Action l The criteria for cable tray clamp ' design.have been. established and i documented in the cable tray and cable tray hanger Design Basis Document 1 (Reference 4.4). These criteria are included in the cable tray and . cable

                                - tray hanger design' procedures (References 4.2 and 4.3). - In addition, the validated' cable tray hanger.. installation specification, 2323-SS-16B (Reference 4.5), and inspection procedures (References 4.6'and 4.7) assure that the installation of the clamp assembly is in accordance with the work package drawing (s).

l(3 i RJ B7-1 ' ________m m__..__m _

SUBAPPENDIX BZ 4.0 References 4.1 TU Electric Procedure CPE-EB-FVM-CS-100, " Field Verification . Methods - Cable Tray Hanger Halkdown for Clamp Identification for j Unit 1," Rev. 0, September 9, 1987. 4.2 Impell Instruction PI-06, " Tray and Clip Qualification," Rev.1, October 20, 1987, with Addendum dated 02/02/87. 4.3 Ebasco Document SAG.CP34, " General Instructions for Cable Tray Hanger Analysis for Comanche Peak SES No._.1 and 2," Rev. II, August 27, 1987. 4.4 Comanche Peak Steam Electric Station No. I and 2. " Cable Tray and Cable Tray Hanger Design Basis Document," DBD-CS-082; Rev. O, July 31, 1987. 4.5 CPSES Unit I and 2, Specification 2323-SS-168, " Structural Steel / Miscellaneous Steel (Category I and.II)," Rev. 1. July 14, 1987. l _' 4.6 TV Electric Procedure, QI-QP-il.10-9 R8, May 7, 1987, " Modification,- l Rework and ' As-Built' Inspection / Verification of Cable Tray Hangers in Unit 1." 4.7 TU Electric Procedure, QI-QP-11.10-2A Ril, October 22, 1986, i

                                                                " Inspection of Unit II Cable Tray Supports."

i tN l s) B7-2 l

               . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ .         _ _ _ _     _                                      _         _      .t_.

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l SUBAPPENDIX B8-SDAR CP-87-59. IMPROPER APPLICATION OF' CONSTRUCTION AIDS i i 1.0 Definition of the Issue This issue was that certain cab.le tray fittings intended only to aid in alignment of cable tray segments during installation were~. installed as permanent components in cable tray systems without evaluation of their structural adequacy. 2.0 Issue Resolution. Cable tray fittings that were. intended only to aid 'in-alignment of cable tray segments during installation and that were installed as permanent components in cable tray systems will be identified in their as-built '. configuration during the Post Construction Hardware Validation Program l (PCHVP) (Reference 4.1). Cable tra9 fittings that do not comply with the design criteria (Reference' 4.4) will be identified and modified, j replaced, or removed to comply with the validated design. i 1 3.0 Corrective and Preventive Action j h v No additional issues were identified during review and resolution.of this issue. / This issue was determined to be reportable under the provisions.of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-59 in letter number TXX-6750, dated September 21, 1 1987 from TV Electric to the NRC. 3.1 Corrective Action Cable tray fittings intended only to aid in alignment of cable tray segments during installation and that were not approved as permanent components, as discussed above, will be identified (Reference 4.1) and design validated in their as-built configuration during the Post Construction Hardware Validation Program (PCHVP). Components that do not comply with design criteria are being modified, replaced, or removed in i accordance with the validated design. 3.2 Preventive Action ., The cable tray installation specification (Reference 4.2) has been revised to include approved cable tray fittings to preclude the misuse or , improper installation of fittings. intended only to aid in alignment of cable tray segments. The cable tray inspection procedure (Reference 4.3) . is being revised to include approved cable tray' fittings. ' Inclusion of the approved cable tray fittings in the installation specification and' (m) '" inspection procedure eliminates the . potential for improper installation specification of nonapproved fittin_gs. B8-1

4.0 References 4.1 TU Electric Procedure CPE-EB-FVM-CS-084, " Field Verification Method' Engineering Halkdown for Replacement of. Cable Tray Fittings in Unit 1 and 2 " Rev. O, July 28. 1987. 4.2 TV Electric Comanche Peak Steam Electric Station Units 1 and 2 Cable Tray Specification 2323-ES-19, Rev.1, November. 22, .1976. 4.3 ~ TU Electric Procedure QI-QP-11.3-24, '.' Class 1E Cable Tray Raceway Inspections,".Rev. 17, March 26, 1987. 4.4 Comanche Peak Steam Electric Station No. 1 and 2, " Cable Tray and. l Cable Tray Hanger Design Basis Document," DBD-CS-082, Rev. O, July 31, 1987.

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i SUBAPPENDIX 89 SDAR CP-87-76. FIELD DRILLED CABLE TRAY HOLES

                    -1.0  Definition of the Issue A'c ceptable cable / cable tray sp' lice configurations for installation at   -

CPSES.are defined by the approved vendor- drawings or by approved changes to-the vendor drawings. Unapproved splice plate installations were observed during field walkdown activities.' Field drilled holes, used- to. install these plates,.have resulted in some unused holes.in cable trays and splice plates. This issue was that these unused field drilled holes were not considered by CPSES. design. 2.0 Issue Resolution

                                                                                                      . R Unused holes in cable trays which-do not comply with the ' design' criteria        l (Reference 4.3) will be identified (References 4.1 and 4.2) during the Post Construction Hardware Validation Program (PCHVP). Unused holes that.

are not acceptable will be repaired so that the installation is in accordance with validated design. 3.0 Corrective and Preventive Action O

• No additional issues were identified during the review and V resolution of this issue.

This issue was determined to be reportable under the provisions of~ 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-76.in letter number TXX-6763, dated _ September 18, 1987 from TU Electric to the NRC, 3.1 Corrective Action Unused holes in cable trays which do not comply with the design criteria will be identified (References 4.1 and 4.2) and design validated'in their as-built configuration during the Post Construction Hardware Validation Program (PCHVP). Configurations that do not comply with design criteria are being repaired so that installation is in accordance with the validated design. 3.2 Preventive Action The cable tray installation specification (Reference 4.5).has been revised to include approved splice plate configurations. to preclude the misuse'or improper installation of new or modified splice connections. I The' cable tray inspection' procedure (Reference 4.4) is being revised to l- include approved splice plate configurations. Inclusion of the approved-L splice plate configurations in the-installation specification..and-i inspection procedure eliminates-the potential for unused bolt holes in L, . cable. trays. L l 89-1

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1 h q l 4.0 References 4.1 TU Electric l Procedure..TE-FVM-CS-048, " Field Verification' Method UnitL 1 Cable Tray Selected Attributes As-Built Program," Rev. 0, , December 31,.1986.

         . 4.2 TU Electric Procedure CPE-EB-FVM-CS-019 "Su'plemental p           Procedure-for Unit 2 Halkdown - Selected Cable. Tray. Attributes Data Collection-Unit'2," Rev. 2,. June 3, 1987..

4.3 Comanche Peak Steam Electric Station No. 1 and'2,:" Cable Tray and Cable Tray Hanger Design Basis Document,"'DBD-CS-082, Rev.;0,' July 31, 1987. 4.4 TU Electric Procedure, QI-QP-ll .3-24, '" Class 'IE Cable Tray Raceway Inspections," Rev. 17, March 26,'1987. [l 4.5 TV Electric Specification 2323-ES-100,'" Electrical Installation. Class 1,.2, and Non-Safety," Rev. 3,~ June 5, 1987~ " 1 H l , O {

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