ML20236R983
| ML20236R983 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/18/1987 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20236R943 | List: |
| References | |
| TAC-R00282, TAC-R282, NUDOCS 8711240149 | |
| Download: ML20236R983 (124) | |
Text
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f COMANCHE PEAK
. STEAM ELECTRIC STATION t UNIT 1 and COMMON CORRECTIVE ACTION PROGRAM O
PROJECT STATUS REPORT CONDUIT SUPPORTS TRAINS A AND B, AND TRAIN C LARGER THAN 2 INCH DIAMETER l hDR DO 45 A PDR i
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N f i. t l TABLE OF CONTENTS Section lji_tig Pace NN EXECUTIVE
SUMMARY
iii
. ABBREVIATIONS AND ACRONYMS vi l
1.0 INTRODUCTION
1-1 Figure 1 Conduit and Conduit Supports Trains A and B and Train C Larger Than 2 Inch Diameter Corrective Action Program (CAP) i <- 2.01 PURPOSE 2-1 j 3.0 -SCOPE 3-1 4.0 SPECIFIC ISSUES 4-1
,' 5.0 CORRECTIVE ACTION PROGRAM METHODOLOGY 5-1 AND RESULTS 5.1- METHODOLOGY,AND. WORK PERFORMED 5-1 5.1.1^ Licensing Commitments,. Design Criteria and 5-1 Procedures-
.5.1.2 Design Validation Process 5-2 ;
. 5.1. 2.1. Evaluation of Results from Comanche Peak Response 5-3 i Od- 5.1.2.2 Team (CPRT) Quality of Construction (00C) Program Testing. Programs 5-3 5.1.2.3 Modification of UNISTRUT and Transverse 5-4 Conduit Supports 5.1.2.4 Validation of the Governing Design Document, 5-4 Orawing No. 2323-S-0910 5.1.2.5. Engineering Walkdowns 5-4
;5.1.2.6 Design Validation 5-5 5.1.2.7- Design Validation Methodology 5-6 ;
5.1.2.8 Technical Interfaces with Other Organizations 5-7 5.1.2.9 ' Validation of Train C Conduit and Conduit Supports 58
'5.1.2.10- Final Reconciliation Process 5-8 ,
5 .1 '. 3 Post Construction Hardware Validation Program 5-9 -
.(PCHVP) j 5.2 RESULTS 5-13 5.3 QUALITY ASSURANCE PROGRAM 5-13 5.3.1 Summary of Ebasco Quality Assurance (QA) Audits 5-16 5.3.2 Summary of Audits by TV Electric Technical 5-16 Audit Program (TAP) and the Nuclear Regulatory Commission (NRC) 5.4 CORRECTIVE AND PREVENTIVE ACTION 5-17 l
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'Sectioni lil]g Pace L
Lm .- tFigure 5 1: Corrective Action Program (CAP) Flow Chart and L D Governing Procedures. Conduit and Conduit Supports
\M Trains A and.B and Train C Larger Than 2 Inch !
Diameter Figure-5-2 . Post Construction Hardware Validation Program (PCHVP)- Figure 5-3 :. Corrective Action Program (CAP) Technical Interface Conduit and Conduit Supports. Trains A and B and
' Train'C Larger Than 2 Inch Diameter Figure 5-4' Typical Conduit Overhang configuration F
- ' Table 5-l' Post Construction Hardware Validation Program (PCHVP) Conduit'and Conduit Supports Trains A"and B and Train C Larger Than 2 Inch Diameter e Attribute Matrix-
' Table 5-2' TV Electric Audits
6.0 REFERENCES
6-1
. APPENDIX A : COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL A-1 ISSUES:
1 APPENDIX B ISSUES IDENTIFIED DURING THE PERFORMANCE OF THE B-1
. CORRECTIVE ACTION PROGRAM (CAP)
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fI [N ' ' EXECUTIVE
SUMMARY
EThis Project Status Report (PSR)isummarizes the systematic validation ! l P b' m , process for safety-related' Seismic Category I Trains A and B conduit and 4 1 conduit supports and for non-safety-related Seismic Category 11 Train C
' larger than.2Linch diameter conduit and conduit supports implemented by 4
Ebasco Services. Incorporated at Comanche Peak Steam Electric Station (CPSES) Unit:1 and-Common. ';This Project Status Report:(PSR) presents the results of.the design l validation and describes-the Post Construction L
,V l Hardware Validation; Program (PCHP). Ebasco's activities are. governed by the TV Electric Corrective Action Program (CAP) which required Ebasco to:
"1. Establish ~ a consistent set of CPSES safety-related conduit and conduit? support design criteria that complies'with the CPSES licensing commitments..
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i2. Produce a set of design control procedures that assures tcompliance with the: design criteria.
'3. Evaluate systems,l structures,.and components, and direct the .i corrective actions (recommended by the Comanche Peak Response Team I (CPRT)=and those determined by the. Corrective Action Program I (CAP) investigations to be necessary.to demonstrate that systems, !
-structures,-and components are in~conformance with..the design. 1
- ' 4 . ' Assure that the validation resolves the conduit and conduit support related design 'and hardware issues identified b Comanche Peak Response Team-(CPRT), external and sources,2 the y the
; Corrective' Action Program (CAP).-
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~ 5. -Validate -that' the design of safety-related conduit and conduit support systems is in conformance with the licensing commitments
-and that the installed hardware.is in conformance with the j
validated design. 6 .- - Produce a. set ~of consistent and validated design documentation.
- 1. Common refers to areas in CPSES that contain both Unit I and Unit 2 systems,-structures, and components.
i e :2. External issues are identified by the following: 1 NRC' Staff Special Review Team (SRT-NRC) NRC Staff Special Inspection Team (SIT)
*' 'NRC Staff Construction Appraisal Team (CAT)
' -* Cit _izens Association for Sound Energy (CASE)
;* Atomic Safety and Licensing Board (ASLB) !
*: NRC Region IV Inspection Reports l
--NRC Staff Technical Review Team (TRT) (SSERs 7-11]
CYGNA Independent Assessment Program (IAP) i i Comanche Peak Response Team (CPRT) issues are identified by the following:
.CPRT Desi
* ' CPRT Qual $n Adequacy Program (DAP)ty of Construction Prcgram (
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' - Consistentidesign criteria:and methodologies.for CPSES safety-related fconduit and conduit. supports-have been' developed and used by Ebasco for y >
f, the, design validation process. These design criteria and methodologies- i are in conformance with the CPSES licensing commitments.. These ' design h- ! criteria-and methodologies have been independently and extensively reviewed by Comanche. Peak Response Team (CPRT) and by CYGNA Energy
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. Services'(CYGNA).
Ebasco-developed design control ' procedures to.' implement the design criteria and methodologies and to govern the work flow and technical i
- interfaces with-other disciplines, for both the design.and hardware 3 validation. processes, zThese procedures specify the processes.(such as the validation'of: conduit system inputs,' conduit and conduit support checklists,L documentation control, and final. reconciliation). that have been implemented'throughout the safety-related conduit and conduit 1 supports Corrective Action Program (CAP).
!Ebasco has performed analyses to validate the design off all CPSES Unit 1 L and -Common safety-related conduit- and . conduit supports. Ebasco also
** ' validated that the non'-safety-related. Seismic Category II Train C conduit larger than two inch-diameter in Unit 1 and Common will not fail such that the functioning of any Unit'l. safety related structures, systems, or components would be. reduced to an unacceptable safety level. The Unit 1
'and Common conduit ~and conduit support design validation results are documented ~in_ approximately.5,995 calculation packages which include approximate 1y'30,000 as-built conduit supports. The as-built hardware for Lsafety-related conduit and conduit supports is being validated to the validated design-by.the' Post Construction. Hardware Validation Program (PCHVP).
'd The conduit and conduit' support.related design and hardware issues identified by'the Comanche Peak Response Team (CPRT), external sources,
- and the Corrective Action Program (CAP) have been resolved by incorporation of methodologies and design criteria into the Ebasco design validation procedures and the Post Construction Hardware Validation Program (PCHVP) implementation procedures. Consequently, the validated design'of the CPSES safety-related conduit and' conduit supports has resolved these issues.-
z The Post-Construction Hardware Validation Program (PCHVP) assures that the safety-related conduit and conduit supports are installed in conformance with the validated design. Ebasco has reviewed and revised the CPSES conduit-related installation specifications, construction procedures, and i LQuality Control-(QC) inspection procedures to assure that the validated design requirements are implemented. The Post Construction Hardware Validation Program (PCHVP) for safety-related conduit and conduit supports, including inspections, engineering walkdowns and evaluations, implements the corrective actions recommended by the Comanche Peak Response Team (CPRT), as well as those required by Corrective Action Program (CAP) investigations. , O iv
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;Ebasco will provide TV Electric a complete set of validated design
-documentation for CPSES safety-related conduit and conduit supports, including calculations, drawings, and discipline interface transmittals. .
SThisdocumentation,inconjunctionwiththeupdatedspecificationgand j d(~Y procedures, can provide the basis for CPSES configuration control to 1 facilitate maintenance and operation throughout the life of the plant. In-depth quality and technic'al audits performed by Ebasco Quality l' Assurance, TU Electric Quality Assurance and the independent Engineering Functional Evaluation (EFE) verified that implementation of the validation program was' in .conformance with 10CFR50, Appendix B, quality assurance j requirements. 'In addition, the third party overview performed by TENERA, . L.P._(TERA) for the Comanche Peak Response. Team (CPRT) verified that the
.Ebasco procedures and the established design criteria complied with the
-licensing commitments.
The Unit I and Common conduit and conduit supports Corrective Action Program'(CAP) conducted by Ebasco as part of the overall CPSES CAP validates =that:
.The design of the conduit and conduit supports complies with the CPSES.-licensing commitments; The as-built' conduit and conduit support hardware complies with the validated design; The conduit and conduit supports comply with the CPSES licensing commitments and will perform their safety-related functions.
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- 3. Configuration control is a system to assure that the design and u hardware remain in compliance with the licensing commitments c .
throughout the life of the. plant.
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?4 ABBREVIATIONS AND ACRONYMS v.
D= AISC- .American Institute of Steel Construction b1 'AISI. American Iron and Steel. Institute ANSI American National Standards Institute ARS Amplified Response Spectra
- ASLB Atomic Safety and Licensing Board CAP Corrective Action Program (TV Electric)
CAR Corrective Action Request CASE Citizens Association for Sound Energy CAT Construction Appraisal Team (NRC)
. CCL Corporate Consulting and Development Company, Ltd.
.CFR. Code of Federal Regulations CMC Component Modification Card
- CPE Comanche Peak Engineering (TV Electric)
CPRT.- Comanche Peak Response Team (TV Electric) CPSES Comanche Peak Steam Electric Station CTH Cable Tray Hanger
- CYGNA CYGNA Energy Services D: Deadweight DAF- Dynamic Amplification Factor ;
DAP Design Adequacy Program (CPRT) DBCP- . Design Basis Consolidation Program DBD Design Basis Document DR . Deviation Report DIR Discrepancy Issue Report (CPRT-DAP) DSAP' Discipline Specific Action Plan (CPRT) DVP -Design-Validation Package A EBASCO' -Ebasco Services Incorporated V EFE ESM' Engineering Functional Evaluation Equivalent Static Method l FSAR' . Final Safety Analysis Report l FVM Field Verification Method
'GIR Generic' Issues Report HKB -Hilti Kwik Bolt
- .HSKB Hilti Super Kwik Bolt
!. HVAC Heating, Ventilating and Air Conditioning IAP. Independent Assessment Program (CYGNA)
IMPELL Impe11 Corporation IN-FP Individually Engineered - Fire Protected , IR' Inspection Reports (TV Electric) 1 NCR Nonconformance Report NOV- Notice of Violation (NRC) NRC United States Nuclear Regulatory Commission vi L __m.___.
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\:6 .NSSS- Nuclear Steam Supply System
.NUREG- 1NRC Document i.. :PCHVP Post Construction Hardware Validation Program
'I : : PSR Project StatusiReport 3~.' ! OBE~ Operating Basis. Earthquake QA- -Quality Assurance 4 QCf Quality. Control . 1 LQOC - Quality of Construction - >
- RES; Radiant Energy Shield
_ LRG Regulatory Guide-(NRC) iRIL -Review. Issue List _(CYGNA).
- RSM: '
Response Spectra Method t: :SBML -r , Separation Barrier Material
'SDAR ,
'Significant' Deficiency Analysis Report.(TU Electric)
-SER ~ . Safety Evaluation Report-(NRC, NUREG-0797) 2 SIP' Systems Interaction Program
- . SIT . Special: Inspection Team.(NRC Staff)
- f. '
SRSS. ' Square Root of the Sum of the Squares lSRT- ~ . Senior Review Team (CPRT) SRT-NRC Special? Review Team (NRC)
. SSEL l Safe Shutdown Earthquake .
iSSER- Supplemental. Safety Eval' uation Report (NRC, NUREG-0797)
'SWEC: Stone & Webster Engineering Corporation.
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SWEC-PSAS ' Stone-& Webster. Engineering Corporation-Pipe' Stress and
-Support Project ,
- 1 TAP . Technical Audit Program (TV Electric)
; TERA- TENERA,.L.P.
TRT. Technical Review Team (NRC Staff, SSERs 7-11) ZPA Zero Period Acceleration [ I I i Q. ' vii j
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'l.0 ' INTRODUCTION
'- In'0ctober 1984, TU Electric established the Comanche Peak Response Team (CPRT)'to evaluate issues that have been raised at CPSES and to prepare a i) '
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 33-and 35). This review identified that the Comanche Peak
", Response Team (CPRT) findings were very broad in scope and included each discipline. -TV Electric decided that the. appropriate method to correct the issues raised and-to identify and correct any other issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue. TV Electric decided to
-initiate a comprehensive Corrective Action Program (CA Reference 39) to
. validate the entirety of CPSES safety-related designs. The
- Corrective Action Program (CAP) has the following objectives:
Demonstrate that the design of safety-related systems, structures and components complies with licensing commitments; t
* ' Demonstrate that,the existing systems, structures and components ;
are in compliance with the design; or develop modifications '
- which will bring systems, structures, and components into
- ' compliance with design;
*- Develop procedures, an organizational plan, and documentation to maintain compliance with licensing commitments throughout the oll life of CPSES.
, M The Corrective Action Program (CAP) is thus a comprehensive program to val _idate both the design and the hardware at CPSES, including resolution 3 of specific Comanche Peak Response Team (CPRT) and external issues. j l J l
- 1. Portions of selected non-safety-related systems, structures and components are included in the Corrective Action Program (CAP).
These are Seismic Category 11 systems, structures and components, !
-and Fire Protection. Systems. l l
- 2. . Nuclear Steam Supply System (NSSS) design and vendor hardware I design and their respective QA/QC programs are reviewed by the .
NRC independently of CPSES, and are not included in the l Corrective Action Program (CAP) as noted in SSER 13; however, the design interface is validated by the CAP.
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1-1 1
o m O b ;y TV Electric contracted with, and'provided overall management to Stone & H Webster. Engineering Corporation ~(SWEC), Ebasco Services Incorporated ! n -(Ebasco), and'ImpellL Corporation (Impell) to: implement the Corrective , wh Action Program..(CAP).and divided the CAP into eleven disciplines-as follows: l o Disciolina Responsible Contractor Mechanical SWEC
-Systems Interaction Ebasco
-Fire Protection ~ Impell
-Civil / Structural- SWEC
' Electrical SWEC "i Instrumentation & Control SWEC Large Bore Piping and Pipe Supports SWEC-PSAS
, Cable Tray.and. Cable Tray Hangers Ebasco/Impe11 Conduit Supports Trains A,B, & C >2" Ebasco
' Conduit Supports 1 Train C:< 2" Impe11 Small BoreLPiping and Pipe Supports SWEC-PSAS
.HVAC~ Ebasco i
. Equipment Qualification Impell A Design. Basis Consolidation Program (DBCP) (Reference 28) was developed Lto: define lthe. methodology by'which Ebasco performed the design and hardware validation. The approach of this Design Basis Consolidation
' Program (DBCP) is consistent with other contractors' efforts and
-products.
,_f .. -The' design validation. portion of the Corrective Action-Program (CAP) identified the design-related licensing commitments. The design criteria
. - .were established from the' licensing commitments and consolidated in the Design Basis Documents (DBDs). The DDDs identify the design criteria for
~ the. design validation affort. . If the existing design did not satisfy the design criteria, it was modified to satisfy the criteria. The design validation effort' for each of the eleven Corrective Action Program (CAP)
' disciplines was documented in the Design Validation Packages (DVPs). The Design Validation Packages (DVPs) provide .the documented assurance (e.g.,
calculations and drawings) .that the validated design meets the licensing commitments,' including resolution of all Comanche Prak 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) is being implemented by the Post Construction Hardware Validation Program
.(PCHVP), which demonstrates that existing safety-related systems, structures, and components are in compliance with the installation specifications'(validated-design), or identifies modifications that are necessary to bring the hardware into compliance with the validated design.
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, LThe results of the Corrective Action Program (CAP) for each discipline are J L-
; described 1in.a Project. Status Report'(PSR). This Project Status Report .j
> .- (PSR): describes ~the results of the Corrective Action Program.(CAP) for j LA conduit and conduit supports for Trains A and B.and Train C greater than 2 i M inch diameter.1 ]
'This Corrective Action Program-(CAP) for conduit and conduit supports .
, consists'of activities carried out by Ebasco and is shown schematically in m , .' Figuref l-1. Ebasco has performed a comprehensive design validation and is t
performing hardware validation of safety-related conduit and conduit ,
' supports for the. Comanche Peak Steam Electric. Station. (CPSES) in order to (
--demonstrate that the as-built design of; safety-related conduit and conduit.
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7 supports'compliesiwith licensing commitments. Ebasco was initially-
. contracted by TV . Electric in' 1985 (Unit 2) and 1986 (Unit 1 and Common) to
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,> ?" ! validate conduit and conduit. supports at CPSES. 'When the Corrective J A Action Program-(CAP) was created in 1986, it-incorporated and expanded upon_Ebasco's existing program. The validation process was conducted in accordance with the Ebasco Design Basis Consolidation Program (DBCP) .;
(Reference 28).,1This DBCP controls implementation of the conduit and j
- conduit support portion of. the. TV Electric Corrective Action Program {
-(CAP).3 The conduit and' conduit supports Corrective Action Program (CAP) {
. ; encompassed'the Comanche' Peak Response' Team . Discipline Specific Action j Plan. VIII:(CPRT '_DSAP VIII) (Reference,22). .- The design bases of the !
' Corrective Action Program:(CAP) are contained within the CPSES Design !
'BasisLDocument (DBD),(Reference 44).for safety-related conduit and conduit' '
supports. Validation of.the CPSES con'd uit and conduit supports was accomplished by complete' conduit and conduit support ' analyses and implementation of {' required field modifications. The methodology used in the validation and
%p) ; results'of.the validation for Unit.1 and Common conduit.and conduit' supports are presented in this Project Status Report (PSR).
i 1This conduit and conduit supports Project Status Report (PSR) describes i the validation effort from the early stages of. design criteria I
. 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 of1the Post Construction Hardware Validation Program '
)
(PCHVP) to validate the as-built safety-related conduit and conduit support-design, and the completion of the Unit 1 and Common Design Validation Package (DVP). uO ' 1-3
.---_a______-um__._m.- _ _ - - -
FIGURE 1-1 CORRECTIVE ACTION PROGRAM ( CAP) p-CONDUIT AND CONDUIT SUPPORTS
' TRAINS A AND B AND TRAIN C LARGER
(. N. L
.THAN 2 INCH DIAMETER
- FSAR IDENTIFY LICENSING C0tt4ITE NTS e - OTHER LICENSING DOCUKNTS If DEVELOP DESIGN BASIS DOCUENT ( DBO) o c CPRT ( OAP & 000)
PERFORM DESIGN VALIDATION : EXTERNAL ISSUES
-NRC ( SRT. SIT. TRT. CAT)
-CYGNA ( I AP) u -CASE
' ASLB
-NRC INSPECTION REPORTS IS MODIFICATION YES -
DESIGN REQUIRED MODIFICATIONS
?
ao u e POST CONSTRUCTION LD M SPECT HARDWARE-VALIDATION MODIFICATION PROGRAM (PCHVP) U FINAL DESIGN RECONCILIATION u IS' YES ADDITIONAL
' VALIDATION REQUIRED
?
l y NO I e FINAL DOCUM NTATION (DESIGN VALIDATION PACKACES)
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2.0. PURPOSE' [Thepurpo'se;ofthisProjectLStatusReport'(PSR)isto-demonstratethat'the f.' if)'..; conduit and conduit supports in Unit 1 and Common are in conformance with
-'-' , the.CPSES licensing commitments, satisfy the design criteria, and will satisfactorily perform their safety-related functions. ._s i i 1
i O 2-1
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3.0 SCOPE q This report addresses all of the activities of the Corrective Action Q Program.(CAP) for conduit and conduit supports as described below-
- 1. Trains A and B These are safety- lated Seismic Category I conduit and conduit supports
,. 2. Train C 2
These are non-safety-related Seismic Category 11 conduit larger than 2 inch diameter and their supports. This conduit is_ either seismically supported or seismically
-restrained.
Non-safety related, non-seismic3 conduit and conduit supports of Train C larger than 2 inch diameter are addressed as part of System Interaction Program (SIP) and are described in the Mechanical Project Status Report (PSR)-(Reference 14). Conduit and conduit supports of Train C less than and equal to 2 inch diameter are addressed in the Conduit Supports Train C Two Inch Diameter and Less Project Status Report (PSR) (Reference 10). Structures, systems, and components that are designed and (')' 1. constructed to withstand the effects of the Safe Shutdown Earthquake (SSE) and remain functional are designated as Seismic Category I in accordance with the requirements of NRC Regulatory Guide 1.29 (Reference 5), 2.. .Those portions of structures, systems, or components whose continued function is not required, but whose failure could reduce the functioning of any Seismic Category I structure, system or component required to satisfy the requirements of Regulatory Guide 1.29 to an unacceptable safety level or could result in incapacitating injury to occupants of the control room, f are designated as Seismic Category'II and are designed and j constructed so that the Safe Shutdown Earthquake (SSE) would not cause such failure.
- 3. Those portions of structures, systems, or components whose ,
continued function'is not required, and whose failure will not
' reduce the functioning of any Seismic Category.I structure, system or component required to satisfy the requirements of Regulatory Guide 1.29 to an unacceptable Jafety level and will not result in incapacitating injury to occupants of the control room, are designated as non-seismic.
I 1 L G o 3-1 l 1 1
C 4 The'CPSES conduit and conduit supports Corrective Action Program (CAP) is shown schematically in Figure 1-1 and discussed below. The program required:
.O 1. Establishment of conduit and conduit support design criteria s
which comply with licensing commitments.
- 2. Development of the Design Basis Document (080) for CPSES conduit and conduit supports, which contains the design criteria. This Design Basis Document (DBD) provides assurance that the licensing commitments are complied with throughout the life of the plant.
- 3. Implementation of design and hardware validation that consist of analyses, identification and implementation of necessary modifications, as well as field verifications as identified in the Post Construction Hardware Validation Program (PCHVP). The as-built design of all conduit and conduit supports is validated by engineering walkdowns, Quality Control (QC) inspections as applicable and engineering evaluations. Analysis results are documented in Unit 1 and Common Design Validation Package (DVP).
- 4. Resolution of the design and hardware-related issues of CPSES conduit and conduit supports and implementation of a Corrective Action Program (CAP) for closure of these issues. These issues include external issues, Comanche Peak Response Team (CPRT) issues, and issues identified during the performance of the Corrective Action Program (CAP) (See Section 4.0).
- 5. Developent of validated design documentation to form the basis g for configuration control of CPSES conduit and conduit supports.
The validated design documentation and updated procedures / specifications will be provided to TV Electric to facilitate operation, mair.tenance, and future modifications following issuance of an operating license. Within Section 5.1, Section 5.1.1 describes the methodology by which the CPSES licensing commitments were identified, the design criteria were ! established and consolidated in the Design Basis Document (DBD) and the procedures were developed. These technical and design control procedures were used to implement the corrective actions for conduit and conduit supports. Section 5.1.2 describes the design validation process, including the calculation input / output reviews and interface requirements with other organizations. This section also describes the final reconciliation process by which the consistency of the conduit and conduit support design documentation with hardware installation is assured. 4 Conduit and conduit supports as used in this PSR hereafter refer to , safety-related conduits and conduit supports including junction boxes g and Junction box supports in the conduit run. 3-2
p , L Section 5.1.3 describes the Post Construction Hardware Validation Program
.(PCHVP) process and the procedures for field validation (QC inspections igo and engineering walkdowns) and engineering evaluations required to be
' T "1' implemented to validate that the as-built conduit and conduit supports are l in compliance with the design documentation. Section 5.2 presents a summary of the design validation and Post 4 Construction Hardware Validation Program (PCHVP) results, including the _ hardware modifications resulting from the Corrective Action Program (CAP). Section 5.3 describes the quality assurance program implemented for the - validation process, including Ebasco Quality Assurance (QA) audits, the TV Electric Technical Auditing Program (TAP) audits and the Engineering Functional Evaluation (EFE) audits.
-Section 5.4 describes the'Ebasco inputs to the TV Electric preventive actions including the training of TV Electric Comanche Peak Engineering (CPE) personnel and the transfer of a complete set of tne validated design documentation and procedures to CPE. This documentation and these procedures can prov;de the basis for CPSES configuration control throughout the life of the plant.
Appendix A of this PSR describes the details of the Corrective Action 1 Program (CAP) resolution of all CPRT and external issues. Appendix B.of this PSR describes the details of the resolution of issues identi_fied during the performance of this conduit and conduit supports Corrective Action Program (CAP). These issues are identified in Significant Deficiency Analysis Reports (SDARs) (10CFR50.55(e)) initiated [') by TU Electric. V 3-3 - _ _ - l
4.0 SPECIFIC ISSUES The conduit and conduit supports Corrective Action Program (CAP) resolved
', all of the relats Comanche Peak Response Team (CPRT) issues, external issues and issues vientified during the performance of the CAP. This section presents 7 listing of all conduit and conduit supports related issues addressed in this Project Status Report (PSR). Technical review, resolution, corrective and preventive actions for all external and Comanche Peak Response Team (CPRT) issues are described in Appendix A.
Technical review, resolution, and corrective and preventive actions taken for issues identified during the performance of the Corrective Action Program (CAP) are described in Appendix 8. Comanche Peak Response Team (CPRT) and external issues are identified in the Generic Issues Report (GIR) " Evaluation and Resolution of Generic Technical Issues for Conduits and Conduit Supports," (Reference 1). This Generic Issues Report (GIR) has been transmitted to the NRC, CASE, CYGNA, and is incorporated in Subappendices Al through A29 of this report. The Comanche Peak Response Team (CPRT) contracted TENERA, L.P. (TERA) to perform the Third Party overview (Reference 33) for the completeness of the issues and the completeness and adequacy of these issues / resolutions, and the overview of corrective actions implemented by Ebasco to resolve these issues. The results of the Third Party overview are presented by TERA in the Discipline Specific Action Plan Results Report (DSAP-VIII) (Reference 40). Comanche Peak Response Team (CPRT) and external issues are listed below (issue number corresponds to the Subappendix number in Appendix A). Issue No. Issue Title Al Governing Load Case for Design A2 Dynamic Amplification Factors A3 Combination of Deadweight and Seismic Responses A4 Measurement of Embedment from Top of Topping AS Bolt Hole Tolerance and Edge Distance Violation A6 FSAR Load Combinations A7 Support Self Weight A8 Torsion of UNISTRUT Members A9 Improper Use of Catalog Components A10 Anchor Bolts All Longitudinal Loads on Transverse Supports A12 Hilti Kwik-Bolt Substitutions A13 Substitution of Smaller Conduits on CA-Type Supports A14 Use of CA-Type Supports in LS Spans j A15 Stresses in Cable Trays due to Attached Conduit Supports l A16 Increases in Allowable Span Lengths ! A17 Substitution of Next Heavier Structural Member l A18 C1 amp Usage l A19 Documentation Deviations between Inspection Reports, CMCs l and IN-FP Drawings i A20 Nelson Studs l A21 Conduit Fire Protection Calculations l I A22 Span Increase for Fire Protected Spans l 4-1
n k A23 ' Grouted Penetrations-k 'A24' Rigidity of CA-Type Supports
, , ;c A25 Enveloping Configurations ~ for Design i L' ~ 'i A26. ' Design Drawing Discrepancies J
'-A27-Walkdown- Discrepancies -
'A28 ' Systems Concept ,
A29 Cumulative Effect of Review Issues m A30- Conduit Unions j
)
Is' sues. identified during the performance of the Corrective Action Program (CAP)'are.. listed below-(issue number corresponds to the Subappendix number in Appendix B): l Issue No'. Issue Title 4 i
'1 8 SDAR-CP-85 Conduit Support Spans v B2- SDAR CP-85-31 . Electrical Raceway Support System j 83: SDAR-CP-85-34 Conduit Support Design
.84 ~SDAR-CP-86 Seismic Design of Conduit l
4 f
. c. !
T l 4-2 _..______-________D
l 5.0 CORRECTfVE ACT10N PROGRAM METHODOLOGY AND RESULTS This section of the Project Status Report (PSR) addresses the methodology for j- the conduit and conduit supports portion of the Corrective Action Program (CAP). This section also addresses the establishment of design criteria in conformance with CPSES licensing commitments, the development of procedures, the implementation of the design validation process and the Post Construction Hardware Validation Program (PCHVP). This section describes the results of the Corrective Action Program (CAP) and the corrective and the preventive actions identified by the CAP. 5.1 METHODOLOGY AND WORK PERFORMED The methodology and work performed by Ebasco in implementing the Corrective Action Program (CAP).for conduit and conduit supports are discussed in the following sections. 5.1.1 Licensing Commitments, Design Criteria and Procedures Ebasco reviewed the conduit-related CPSES licensing documentation (such as FSAR
'(Reference 3), NRC Regulatory Guides, NRC Inspection and Enforcement Bulletins, and NRC/TU Electric correspor.dence) and identified licensing commitments related to the conduit and conduit supports. Ebasco established design criteria to assure compliance with the licensing commitments. The design criteria are documented in the Design Basis Document (DBD). Ebasco then developed design procedures which encompass the following:
Design criteria including allowable load capacities for conduit clamps and UNISTRUT supports which were established by tests; J
- Resolution of Comanche Peak Response Team (CPRT) and external issues; Ebasco's experience gained through the design of conduit and conduit supports for several recently licensed and operating United States nuclear power plants; Regulatory and professional society guidance,such as applicable codes and standards.
The governing procedures implementing the Corrective Action Program (CAP) for conduit and conduit supports are shown in Figure 5-1. These procedures assure compliance with the design criteria and the resolution of the Comanche Peak Response Team (CPRT) and external issues. , Several audits and overviews were conducted by the Ebasco Corporate Quality Assurance Group, and the Comanche Peak Rosponse Team (CPRT) to assure that the licensin) commitments related to conduit and conduit supports were identified, appropriate design criteria were established, and procedures were developed to comply with the design criteria. Ebasco's Quality Assurance (QA) audits were performed as described in Section 5.3. The Comanche Peak Response Team (CPRT) overview was performed by TENERA, L.P. (TERA), and the overview of g implementation was performed by the.TU Electric Technical Audit Program (TAP). 5-1 i
The TU Electric Technical Audit Program (TAP) audited the Corrective Action Program (CAP) to assure that the design criteria were in compliance with the a licensing commitments. In addition, CYGNA Energy Services-(CYGNA) is reviewing M the Ebasco resolution of conduit and conduit support issues that were { identified by the Independent Assessment Program (IAP) conducted by CYGNA and summarized in CYGNA conduit supports Review Issues List (RIL) (Reference 38). 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 CPRT and external issues were clearly identified and resolved l
'in accordance with the CPRT Discipline Specific Action Plan VIII (DSAP-VIII) l (Reference 22).
The scope of Third Party overview included: Comanche Peak Response Team (CPRT) and external issues identification, design criteria / commitments identification, as-built procedures review, design validation procedures review, special studies review, test programs review, and issue resolution review. During the performance of the Design Adequacy Program (DAP) overview, TENERA, L.P. (TERA) identified discrepancies and documented these discrepancies in Discrepancy . Issue Reports (DIRs). Ebasco has responded to and closed all of the 96 5 Discrepancy Issue Reports (DIRs) received from TENERA, L.P. (TERA). TENERA, L.P. (TERA) has completed the Third Party overview and presented the results in the Discipline Specific Action Plan Results Report for conduit and Supports (Reference 40). On Page 1-2 of the Results Report, TENERA L.P. (TERA) statcs:
"The assessment of the overall adequacy of Ebasco's design validation 9 effort was accomplished by Third Party review of the procedures, supporting special studies and tests, generic calculations, and resolution methodology for each external. source issue. These reviews were performed to evaluate the adequacy of Ebasco'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 appropriate criteria.
In summary, the Third Party has concluded that the Project's conduit / supports design validation program is comprehensive and capable of resolving known technical issues and assuring that the design will meet the FSAR and licensing commitments." 5.1.2 Design Validation Process The Ebasco design validation process assures that the conduit and conduit support design conforms to the licensing commitments. The process consists of seven distinct but interrelated tasks. These tasks are: Evaluation of results from CPRT Quality of Construction (QOC) program; Testing programs; Modification of UNISTRUT and transverse conduit supports; O 5-2
m.e ^.x 3 H o s c m). a b b- ,, i..;
,K.., jg r (Validation of'the. governing design' document, Drawing No.
y 4iV , J
.. -2323-5-0910'(Reference 4);-
% .3 e . Engineering: walkdowns_;
.W T Design. Validations
- IQ] , .a 3... Technical. interfaces with other organizations.
;5.1'.2.'1L Evaluationfo'f Results from CPRT Quality of ; Construction l(QOC) Program l Et asco reviewed l thel 'results of. the Comanche Peak Response Team (CPRT) Quality-m icf Construction;(QOC) Program-relating to conduit and-conduit supports.
S Ebasco'sireview concluded- that-the design _. validation procedures developed by
- Ebasco"(See Section 5.1.1); included resolution of issuas identified-by Comanche.
@ ld ' Peak Response ~ Team-(CPRT). Qual.ity of. Construction (QOC) Program.
qn ,
- 5.1'.2.-2: Testing Programs a 6 ) (Tests'were performed to eshablish' design criteria specified in the procedures
, .for conduit clamps and.UNISTRUT supports, and-to identify modifications
. required;for threaded couplings. The tests performed are described below:
a); Clamp Capacities 4 ' - Conduiticlamp[t'ests were performed .by Corporate Consulting and
> s Development Company:(CCL) (References 7 and 8).to establish conduit rallowable , load; capacities. The. tests-included the effects of' s clampreaming',Domission.or hole- alteration of. washers, 'and the clamp E r : distortions that were noted in the field.
d .: . M7 1 ,
> Static and simultaneous:three directional cyclic loads were applied
? "y Jduring :the tests. . Ebasco reviewed'and evaluated the test results and c established the clamp allowable load capacities. . These capacities >
were incorporatedLinto the design. validation procedures for.use in the y 3,- ' Corrective. Action Program (CAP).1
' b)J .UNISTRUT Testing Program-
, +
UNISTRUT support configurations were tested by Corporate Consulting i m ~
-and Development Company-(CCL) to establish the;1oad capacity of each type of UNISTRUT conduit support (Reference 6). Ebasco reviewed and evaluated the-results. of the tests and ' established the UNISTRUT
+ . support design capacities. These capacities were' incorporated into the design document (Reference 4) and were utilized in the conduit and e
> conduit: support design validation process. l c) Torsional Capacity of Threaded Couplings
-Tests were performed by Corporate Consulting and Development Company
.(CCL)~~(Reference 34) on conduit overhangs with threaded coupling l located._on the overhanging portion of the conduit beyond the last :
,. support-(see Figure 5-4). The purpose of this test was to establish '
&' ' i the method'to prevent excessive movement of the overhang conduit due
.to torsional moment created by the CPSES Safe Shutdown Earthquake I
i
]hl r
- 3 l/ = 5-3 l
[c I{h , j L
. w g.w '
.(SSE);;-Static;and cyclic) loads tere applied during tho, test lwhich- d
,X '
;were equivalent to the maximum calculated! torsional moment based on l
Jthe CPSES Safe: Shutdown = Earthquake.(SSE). The results of the testi (' Mf-- 1 .
~
- 11dentified the physical.. modification to the conduit threaded coupling
,,b.~ / required to prevent excessive movement lof;the overhang. conduit--due to
%- i torsional; moment b f5.1.2i3b Modification' of- UNISTRUT' and Transverse Conduit Supports -
7q
- , m' > ISome conduit support hardware.. modifications were identified prior to the j beginning ofsthe detailed design validation' process. These included conduit
{ supports;which utilized UNISTRUT' members and hardware,'and transverse type-W isupports'(supports which' provide' restraint to conduit-in two-directions perpendicular,:to the length,~. but were assumed to provide no restraint in et ' sconduit? longitudinal l direction). UNISTRUTeconfigurations which were not tested J or which exhibited: unacceptable capabilities during. testing were identified by-t[4 Engineering.walkdown and ~were or:are being replaced. Transverse supports were , 4 lidentified and either,are being modified to provide three directional restraint forare:being; eliminated.1
, ; i X ,
5.1'.2.41 Validation of the Governing Design Document,, Drawing No. .) 2323-S-0910
\'
~
-Ebasco reviewed the entire original Drawing No. 2323-S-0910 design document to rascertainiits compliance with the' established design criteria and procedures 1 (see?Section 5.1.1).LThis review resulted in a revision of the Drawing No.
yG ', 12323-S-0910 design, document-(Reference 4) to incorporate the established design-criteriaLand resolution?of Comanche: Peak. Response. Team (CPRT) and external j]z Lissues.. ' m Ikaddition,:Ebasco reviewed and identified revisions to the applicable-E installation: specifications (Re.ferences 19-and 30), construction procedure (Reference 31) 'and ' Quality.Contro1L (QC) -inspection procedures (References 16
- cand 29). (These documents were subsequently revised to incorporate the-e requirements.of:the Drawing'No.L2323-S-0910 design document, t5.1.2.5 ' Engineering Walkdowns..
Ebasco developed' a;11st of attributes of the as-built configurations required
-asfinput to the design validation process ~ .
1 #
- Ebasco then developed engineering walkdown procedures, called Field
- Verification Methods (FVMs),.which incorporated the list of attributes required
, :as input to the design validation ~ process. The FVMs define engineering walkdown requirements such as measurement and recording tolerances, measurement fmethodsiand as-built drawing preparation. ;
L Ebasco ' assigned ' qualified walkdown personnel who were provided with classroom
-as well as:f.ield training on'the requirements of Field Verification Methods
- (FVMs). prior:to performance' of the engineering walkdown.
, .y G.) < ; t, 5-4 4.-- I
~.___.m
__.m_ _ . _ _ _
- These ' personnel performed the engineering walkdowns of all Unit I and Common conduits'and conduit supports to obtain the as-built.information required by
- the Field Verification Methods (FVMs). During the walkdown, isometric drawings V
3 were prepared with details of the conduit and conduit support configurations. The following' attributes were examined by engineering walkdown personnel and l were documented on the conduit isometric drawings- ! Conduit identification Routing of conduit Location of supports (spans between supports) Identification of conduit fittings
*- Identification of seals at conduit wall, floor and ceiling penetrations Conduit size
. Distances between conduit fittings and supports Location of embedments of conduit in concrete Junction box physical characteristics Flexible conduit length and size Air drops'(cable length from end of conduit)
Support identification Fire protection material (Thermolag or Thermoblanket) configuration
.The isometric drawing was accompanied by detailed as-built drawings of the conduit supports. For each support, the following attributes were examined by engineering walkdown personnel and were documented on the conduit support- )
drawings: Dimension of support members in
- Member thickness U
- Orientation, i.e. vertical, horizontal or floor mounted Nelson stud diameter Bolt diameter, spacing and type Clamp type Shim and filler plate sizes Edge distance (distance from bolt hole to free ends of structural member)
Dimension from clamp edge to free end of conduit support structural member j Fire protection material (Thermolag or Thermoblanket) I configuration j Hilti bolt / Richmond insert diameter, length identifier and bolt " projection Base plate dimensions The accuracy of the as-built drawings of the conduits and conduit supports has been verified by TU Electric QC Surveillance on a sample basis, and audited by the TU Electric QA Technical Audit Program (TAP). 5.1.2.6. Design Validation Ebasco performed the design validation of the :onduit and conduit supports to E ' determine whether they comply with the requirements of the validated and f revised Drawing No. 2323-S-0910 design document. The design validation l !- includes analyses which either demonstrated that the as-installed conduit and l L (~Y conduit supports complied with the design criteria, or identified necessary sJ modifications to bring the hardware into compliance with the design criteria. 5-5 l d______._i___ _ _ _ -
I In the design validation, either as-built information from engineering walkdowns or as-designed information was utilized. As-built information for I
. attributes specified in the engineering walkdown procedures (References 25 and
- 27) was validated during engineering walkdowns as described in Section 1 j
) 5.1.2.5. As-designed information was used for attributes such as bolt hole diameter, tube steel thickness, wcld quantitative attributes (size, length and type), conduit yield stress, structural steel material properties and anchorage inside junction boxes. The as-designed information used in the design validation is being validated as part of the Post Construction Hardware Validation Program (PCHVP) as described in Section 5.1.3. As a result of design validation, Ebasco identified modifications necessary to l bring the installed hardware into compliance with the design criteria. Modifications of conduit supports have been and continue to be performed in accordance with the revised Drawing No. 2323-S-0910 design document and design / installation specifications (References 11, 19, 26 and 30). These modifications have been and continue to be implemented in accordance with the construction procedure (Reference 31). These modifications are being inspected in accordance with Quality Control (QC) inspection procedures (References 16 and 29). 5.1.2.7 Design Validation Methodology The conduit and conduit supports have been design validated utilizing all applicable loads and load combinations as specified in the design criteria. The effects of conduit and conduit support self weight, seismic response loads simultaneously applied in three orthogonal directions, normal operating thermal loads, and accident thermal loads were utilized in the design validation
- h. process. Conduits and conduit supports required for plant safe shutdown and which were located in the zone of influence of the pipe break (i.e., subject to pipe' whip or jet impingement loads), were identified and they were either relocated or protected by barriers. Conduits and conduit supports located
.outside of the building boundaries, which may be subject to the effects of tornado wind and tornado generated missiles, were reviewed by the Systems Interaction Program (SIP) (Reference 14). SIP found no conduit outside the building boundaries required to be design validated for tornado effects. 'The conduit and conduit support self weights (Deadweight) were consistently utilized in the design validation process. The conduit deadweight included the weight of cable housed within the conduit. The deadweight of the conduit supports included the weight of support members and any permanent attachments.
The conduit and conduit supports were design validated for seismic loads produced by the Operating Basis Earthquake (OBE) and Safe Shutdown Earthquake (SSE) which are described by the CPSES Amplified Response Spectra (ARS). ARS with two percent and three percent damping were used for OBE and SSE, respectively, as described in the CPSES FSAR. Detailed engineering studies were performed by Ebasco to evaluate the effects of operating thermal loads and accident thermal loads. The results of these studies were incorporated into the conduit and conduit supports design validation procedures (References 12 and 45) used in the design validation program. O 5-6
1 The design validation of conduit and conduit supports utilized the methods of analysis described below:
- g. .Eauivalent' Static Method (ESM)
, The Equivalent Static Method (ESM) was utilized for conduit support design j validation. A finite element model was developed for the conduit support and a frequency analysis of the conduit support model was performed to determine the conduit support frequency. Seismic response accelerations in three orthogonal directions were applied independently to the conduit support model and the responses were combined by the Square Root of the Sum of Squares (SRSS) method. s The Equivalent Static Method (ESH) was also utilized to design validate individual conduit configurations. In the analysis, the conduit configuration (conduit and conddit supports) was conservatively considered to be subjected to 1.5 times the peak seismic accelerations from the Amplified Response Spectra (ARS) in compliance with the guidance provided in Regulatory Guide 1.100 (Reference 17). These seismic accelerations were applied independently to the conduit configuration in three orthogonal directions and the responses were combined by the Square Root of the Sum of the Squares (SRSS) method. Resoonse Soectra Method (RSM) The Response Spectra Method (RSM) of analysis was used for the design validation of conduit span configurations. As a result, design seismic accelerations were established for the design validation of conduit supports. In addition, the RSM was used for the design validation of the conduit and conduit supports with fire protection material as well as individually as-built conduit and conduit support configurations. The analytical model constructed for.the RSM analysis included all significant components of conduit and conduit G- supports such as support stiffness, conduit bends and location of conduit fittings. The dynamic responses of the conduit configuration due to seismic loading were evaluated for both the OBE and SSE load cases using 2% and 3% damping respectively. The responses for each mode were combined in accordance with Regulatory Guide 1.92 (Reference 37). The N-S, E-W and vertical directions of earthquake were applied independently and the responses were combined using the Square Root of the Sum of the Squares (SRSS) method. In addition to ESM and RSM analyses, detailed finite element models were j constructed and analyzed for the design validation of junction boxes and for the design validation of the effects of Nelson stud tensioning load in localized areas of shim plates or support members. 5.1.2.8 Technical Interfaces with Other Organizations The technical interfaces between Ebasco and other interfacing organizations for conduit and conduit supports are shown schematically in Figure 5-3. Procedures have been established (References 42 and 43) which control the interface activities between Ebasco and other organizations. O 5-7
w ^lg ,
. Conduit' loads;at: attachments to other commodities.were'provided to-SWEC Civil / Structural Group, SWEC-PSAS Group,:Ebasco/Impe11 Cable Tray and Cable vp Tray Hangers (CTH): Group and Ebasco HVAC Supports Group for acceptance.
G' Impe11 provided conduit loads from Train C 2 inch and less in diameter
" conduits to Ebasco for acceptance.
- ' Amplified Response Spectrajsupplied by SWEC Civil / Structural Group were
' utilized lin.the design validationof conduit and conduit-supports.
.5.1.2.9 Validation of Train C Conduit and Conduit Supports m
Non-safety-related Seismic Categoryill Train C conduit larger than 2 inch
-diameter and their. supports were design validated to provide assurance that 1 they will-not fail and-reduce the functioning of any Seismic Category I System,
> : Structure or Component to an unacceptable: safety level, or result in b '
incapacitating injury to: occupants of the control room during or after a Safe Shutdown Earthquake (SSE).. The System Interaction. Program (SIP) Portion-of the
- Corrective Action Program (CAP) (Reference.14) identified those Train C conduit
> greater lthanT2 inch diameter required to be validated as Seismic Category II.
1These conduits were evaluated by.Ebasco during design validation to be either seismically: supported or seismically restrained.
= 5.1.2.10 Final: Reconciliation ' Process The purpose of the final reconciliation process is to consolidate design validation analyses, hardware. modification, and inspection documentation to ,> : assure l consistency-of the. conduit and conduit support design documentation with the hardware installation. 'The final reconciliation process is performed in L accordance with approved procedure (Reference 20). The final reconciliation of
- Os; conduit-and conduit' supports ~ incorporates the following:
* 'l The. Post Construction Hardware Validation Program (PCHVP) results.
Resolution of the conduit and conduit support related Comanche Peak-Response Team (CPRT)~ and-external issues. : i Final reconciliation' includes confirmation that the interfacing organizations j
..have accepted the Ebasco conduit and conduit support results as compatible with '
l
# ~t heirovalidated design.
.Also the closure of open items, observations and deviations related to conduit and conduit supports that were identified by the TV Electric Technical Audit Program (TAP) .and,the Engineering Functional Evaluation (EFE) are resolved
-during the final. reconciliation.. Items from NRC Notices of Violation (NOV) and
'_TU' Electric Significant Deficiency Analysis Reports (SDARs) (10CFR50.55(e)) are resolved during the final reconciliation process.
l i At the conclusion of final reconciliation, the Unit 1 and Common Design Validation Package (DVP) as described in Section 1.0 is compiled and consists Lof'as-built conduit and conduit supports data, conduit and conduit support
" design validation calculations, design validated conduit isometric and conduit i support; drawings, and test ~results. l 'f '
5-8
. a l
___LL.--. _ _ _ - _ -
i l 5.1.3 Post Construction Hardware Validation Program (PCHVP) j l The Post Construction Hardware Validation Program (PCHVP) (Reference 23) is the p: portion of TU Electric's Corrective Action Program (CAP) which validates the l; M- . matrix of attributes for safety-related hardware. The Post Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 562. L. The input to the Post Construction Hardware Validation Program (PCHVP) is q contained in the installation specifications. The installation specifications i implement the licensing commitments and design criteria of the Design Basis Documents (DBDs), which were developed during the design validation process of
'the Corrective Action Program (CAP). l Final acceptance inspection requirements identified in the validated ]
installation specifications were used to develop the Post Construction Hardware j Program (PCHVP) attribute matrix. This matrix is a complete set of final j acceptance attributes identified for installation hardware (See Table 5-1). j The Post Construction Hardware Validation Program (PCHVP), by either physical ] validations or through an engineering evaluation methodology, assures that each of the attributes defined in-the attribute matrix is validated. l ) Physical validation of an attribute is performed by Quality Control (QC) l inspection or engineering walkdown, for accessible components. Quality Control i (QC) inspections or Engineering walkdowns are controlled by appropriate Field l
- Verification Method (FVM) procedures.
The Post Construction Hardware Validation Program (PCHVP) engineering ) evaluation depicted in Figure 5-2 is procedurally controlled to guide the l
.n Corrective Action Program (CAP) responsible engineer through the evaluation of j V each item on the attribute matrix to be dispositioned by the engineering
~
I
' evaluation method. Disposition of each attribute.is clearly documented. If l the technical disposition of the final acceptance attribute is "not acceptable" )
'or the attribute cannot be dispositioned based on available information, an l alternate plan consisting of additional evaluations, testing, l inspections /walkdowns or modifications as necessary will be developed to demonstrate and document the' acceptability of the attribute.
Recommendations from the Comanche Peak Response Team (CPRT) effort comprise a significant portion of the evaluation. A major cc.nponent of the Comanche Peak l L Response Team (CPRT) program has been the inspection of a comprehensive, random ! sample of existing hardware using an independently derived set of inspection I attributes. The inspection was performed and the results were evaluated by l Third Party personnel in accordance with Appendix E to the Comanche Peak Team (CPRT) Program Plan (Reference 41). 'The scope of the inspection covered the installed safety-related hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished l product). Samples of these populations were inspected to provide reasonable assurance of hardware acceptability in accordance with Appendix 0 to the l Comanche Peak Response Team (CPRT) Program Plan. Corrective action recommendations were made to TV 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 l Appendix E (Reference 41) to the Comanche Peak Response Team (CPRT) Program Pl an. 5-9 l' h__-_m___ . _ _ .
p, l +1 i;t <
;a (The, Post' Construction.HardwareValidationProgram-(PCHVP)assuresthatall
%[f, p . Comanche' Peak (Response Team -(CPRT) recommendations are properly dispositioned.- L'd.. j Rf,
~
! Figure 5-2 illustrates.that during the evaluation of a given attribute:from the-
' Post Construction Hardware. Validation . Program (PCHVP)- attribute matrix, the 1
; initial task of the Corrective Action Program (CAP) responsible engineer is to idetermine if;any of the'following statements lare true:
L. [The,attributewasrecommended.for;reinspectionbytheComanche l Peak Response Team;(CPRT)- .
- Lb. ' Design' validation'.resulted in?a change to design or.to.a-hardware-
. final: acceptance attribute that-is more stringent than the
+ 4 Loriginal . acceptance attribute, or Comanche Peak' Response Team n ,
(CPRT) did'not inspect..the. attribute. o a' c2 , Design validation.resulted in new work, including modification to existing hardware. j l p > LIf'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 Leonclusion is Justified by the-comprehensive coverage of the Comanche Peak j
"/ . Response / Team (CPRT) . reinspection and. the' consistently conservative evaluation ' ' ,6. !of each finding from both"a.' statistical and adverse trend perspective. The Lattribute matrix is.then updated to indicate that.neither the engineering-walkdown nor quality control;(QC) inspection of the attributeLis necessary. ' A ,
Lcompleted1 evaluation packageLis prepared and forwarded'to the Comanche Peak l Engineering (CPE) organization for' concurrence. . The evaluation package becomes
.. .part ofithe. Design Validation Package (DVP) after Comanche Peak Engineering j 5(CPE)~. concurrence,is obtained, l
s -If any of the three statements'are-true, .it is assumed that the final
- acceptance; attribute must be further evaluated as follows:
' Determine Attribute Accessibility The Corrective Action' Program (CAP) responsible engineer will determine if the attribute is accessible.- If the. attribute <is' accessible, a field validation of'
=the item's acceptability is performed and documented in accordance with the 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 2 be conducted'by technical' disposition of available information. After completing.the attribute accessibility review, the responsible engineer will update the attribute matrix as necessary to' reflect the results on the review.-
-Technical Disposition l s
The Corrective Action Program (CAP) responsible engineer identifies the data to be considered during the subsequent technical disposition precess. Examples of
'such items used-in this disposition may include, but are not limited to:
l' 5-10
- f
w'~ lf. l%2L ' .. 1*2 Historica1Ldocuments (e.g.,. specifications,Lprocedures,-. inspection.
~
^ '
;results)-
mq-q yy
; t*t . Comanche Peak Response Team (CPRT) and external issues m- , .. u > Construction practices; y , y pww I* ' ' Quality; records -
7' / vy . s- m "*; -Test results
- m. _
Audit reports
, e
~'
'1 ' Surveillance deports-
-* 'NCRs, DRs, SDARs, and ' CARS-
' ' 1;f* l Inspections conducted to date t i-
- Results of Third Party reviews.-
Purchasing documents y" * -
-Construction packages-
, Hardware receipt; inspections E< o : After compiling..the data identified as pertinent to the attribute, the
;-~- technical disposition will be' performed.. The' actual steps and sequence of actions required for each technica1' disposition may differ, however, the-
" ~h.i
- . tangible;results from each' technical: disposition will be consistent. These
'results'wilitinclude as a minimum:
*- 'A written! description of the attribute.
A written! justification by the Corrective Action Program-(CAP)
< ! responsible; engineer-for acceptance of the. attribute.
- A written explanation for the logic utilized to conclude that the
- attribute need not'be field validated.
.A chronology. demonstrating that the attribute has not been
~
V1 n
.significantly altered by redesign.
- *- -All documents reviewed to support the disposition. ,
l
*=
Concurrence of the acceptance of the attribute's validity by Comanche l 7', J c. Peak Engineering (CPE).
}
5-11
, )
]: I l
i___1.n__._1__.______.._ ._ _ 1
Q( ' b 'IftheCorrectivefActionProgram(CAP)responsibleengineerconcludedthatiihe
% data ~. evaluated represented evidence of the attribute's acceptability, the.
conclusion.wil1<be, documented...The documentation will be reviewed and approved byLComanche Peak Engineering ~(CPE) and filed in the Design Validation Package " k. F ~ -h" (DVP)L JIf the Corrective Action Program (CAP) responsible engineer determines
- thattthe data reviewed does not provide evidence of the: attribute's
; acceptability, the documentation will' explain why the attribute cannot be b 4
' accepted ~ and recommend an alternative course. of action. This alternative
' course.of. action may.take various-forms such as making the attribute accessible and inspecting it,~or testing to support the attribute's acceptability. This
. alternative. plan, after approval by Comanche Peak Engineering (CPE), will be 11mplemented'to. validate the attribute.
In summary, the Post Construction Hardware Validation Program. (PCHVP) . is 'a x 1 comprehcosive process by which each attribute in the PCHVP attribute matrix is
, validated'to the validated design. . The TV Electric Technical Audit Program-
-(TAP); audits the Post Construction Hardware Validation ~ Program (PCHVP). This :
audit: program is complemented by the Engineering Functional Evaluatinn (EFE) e-
' being performed'by an independent team comprised of Stone & Webster, Impe11, i i and Ebasco engineering personnel working under the Stone & Webster QA program i k
'and subject.to direction by i.he Comanche Peak Response Team's-(CPRT) . Senior
. Review Team (SRT). .The Post Construction Hardware. Validation Program (PCHVP)
.provides' additional assurance that- the validated design has been implemented for safety-related hardware.
To providef assurance that the as-built hardware complies with the validated design, ~ the Post. Construction Hardware Validation Program (PCHVP) for conduit and conduit supports developed an' attribute matrix of final acceptance
~
attributes' (See Table 5-1)l based on the validated installation specifications. V}' E-The attributes contained in the attribute matrix for conduit and conduit supports incorporate those recommended corrective actions identified by
.i CPRT-QOC, therebylresolving the hardware related issues. The Field Verification Methods-(FVMs) (including those used to obtain as-built
'information utilized as input for the design validation) were then reviewed to determine whether all- final acceptance attributes'had been included. This review concluded that all' final acceptance attributes requiring physical validation were. included in the. Field Verification Methods (FVMs). 4 The 'FVMs developed by Ebasco in the' Post Construction Hardware Validation l Program'(PCHVP) are identified below:
,CPE-FVM-CS-033 As-Built Field Verification Method for Design
.(Reference 27)
Control of Electrical Conduit Raceways for Unit 1 Installation in Unit 1 and Common Areas CPE-FVM-CS-014- As-Built Field Verification Method for Design (Reference 25) Control of Electrical Conduit Raceways for Unit 2 Installation in Unit 1 and Common Areas
.The conduit and conduit supports have been as-built in accordance with the Field Verification Methods.(FVMs).: Most of the attributes in the attribute matrix have been validated during engineering walkdowns as described in Section 5.1;2.5. The remaining attributes are being validated in the Post Construction
- Hardware Validation Program (PCHVP) for conduit and conduit supports (See Table 5-1). ,
5-12 e i
5.2 LRESULTS t
- . The design ' validation of the Unit 1 and Common conduit and conduit supports has Dp been completed and the calculations have been included in the Unit I and Common V Design Validation Package (DVP).
1 The results of the conduit and conduit supports Corrective Action Program (CAP) I' are as..follows: Ebasco prepared approximately 5,995 as-built conduit isometric i drawings. 1 Ebasco prepared approximately 30,000 as-built conduit support ) drawings. j Ebasco identified a total of 8,302 conduit support modifications, which include.929 UNISTRUT and transverse supports. Ebasco identified 421 modifications to conduit threaded couplings.
.Q, l j
/.O 5-13 1
hM u
.5.3 . QUALITY' ASSURANCE PROGRAM-
.a Activities of the Unit.1 and Common Conduit and Conduit Supports Trains A and B Nh-s and Train C Larger Than 2 Inch Diameter Corrective Action Program (CAP) were Lperformedin'accordancewithEbasco'sQualityAssurance(QA) program,as I applicable. j Ebasco implements their Corporate Nuclear Quality Assurance. Program described
'in Ebasco's Topical' Rep' ort ETR-1001 (Reference 36) which is in conformance with >
'10CFR50, Appendix B and has been approved by.the NRC. ETR-1001 addresses all !
i' phases of completion of a nuclear power plant including design, procurement, 'l
.and construction. ETR-1001'has been modified to make it CPSES project.'
. specific. Ebasco's Nuclear Quality Assurance Program as modified for CPSES .has l been reviewed and approved by TV Electric's Quality Assurance (QA) -
l organization. Ebasco' developed and' issued'a Manual of Procedures (Reference 9) specifically s
- related tc'CPSES work. This manual includes specific instructions and procedures'to supplement the Ebasco standard Engineering, Nuclear, Project and !
Procurement Procedure Manuals. The Manual of Procedures includes instructions
- for alll aspects of the design validation effort performed under Ebasco's '
1
' Quality Assurance program. Separate' instructions are issued to direct the precise organization.and format.for documents that validate designs. -These
- instructions are issued so that 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-N-45.2.11 and NRC Regulatory Guide 1.64 (Reference 32).
N In.accordance with this Quality Assurance (QA) Program,_ detailed procedures and 1 project specific-QA instructions. covering the essentials of the conduit and ) conduit supports Corrective Action Program.(CAP)'were developed. These ! documents were-distributed to Ebasco supervisory personnel and were readily l available' to CPSES conduit and conduit support design validation personnel. The issuance.of these documents was followed with detailed training programs i for the applicable' personnel.- An Ebasco' Project Quality Assurance (QA) Manager experienced in both auditing and QA program procedure development for engineering activities was assigned to the project in the earliest stages of project mobilization. He reports
~ directly through the Corporate Quality Programs Department of Ebasco to the Vice President Corporate Quality Programs with an administrative line of
. communication to the CPSES Ebasco Project Management. This reporting responsibility assures the independence of Quality Assurance (QA) functions.
-QA personnel provide assurance that the QA program properly addresses all project' activities and assists project personnel to implement the QA program properly.
To date, more than 12,000 man-hours have been expended by Ebasco in activities directly attributable to the overall Project Quality Assurance program (i.e., i 1 training, procedure development, auditing and the project QA supervisory l staff). O 5-14 i d
The adequacyfand implementation of Ebasco's Quality Assurance (QA) program was-o extensively audited by Ebasco's Quality Assu o? by TU Electric Technical Audit Program-(TAP)yance (QA) Engineering Audit G and the Nuclear Regulatory e c3 f M Commission. A total ~ of 12 audits were performed by these organizations.on the Conduit and Conduit. Supports Trains A and Bland Train C Larger Than'2 Inch m4 Diameter Corrective Action Program (CAP) from May 6,1986 to date for Unit 1
' and Common' as follows:-
? *' Ebasco Audit Groep 4 TU Electric'- TAP 7
'NRC 1
, :In' addition,. the. Engineering Functional Evaluation (EFE) team has audited .
Ebasco's performance'since June 1987 and TENERA L.P. (TERA) has overviewed L .Ebasco's performance continuously between October 1986 and June 1987. ; l The Ebasco Quality Assurance (QA), TU Electric Technical Audit Program (TAP)
' and NRC audits collectively evaluated the technical adequacy of the engineering product (e.g., engineering walkdowns, . calculations, drawings and s~~
-specifications);and-assessed the adequacy and implementation of the Ebasco Quality Assurance ~. Program.
As required by Ebasco's-Quality Assurance (QA) Program, Ebasco performs internal _' Quality Assurance (QA) Audits.of project safety-related activities
.twice per, year. A. list of audit subjects is provided in Section 5.3.1.
. TV Electric Technical Audit Program (TAP) has evaluated details.of
'D- calculations, drawings,l procedural compliance and technical interface. These M technical audits have resulted in enhancements to the Corrective Action Program L(CAP)' procedures and methods.and contributed to the overall quality of the Conduit.and~ Conduit Supports Trains A and B and Train C Larger Than 2 Inch Diameter Corrective. Action Program (CAP).
.A Third Party ~ organization (TENERA, L.P.) was contracted by CPRT to evaluate the adequacy of Ebasco's Corrective Action Program (CAP). It performed
. technical reviews of responses to the Generic Technical Issues; reviewed design criteria; and reviewed the backup studies, tests and calculations that support design criteria. The Third Party concluded that the Conduit and Conduit i supports Trains A and B and Train C Larger Than 2 Inch Diameter Corrective
; Action Program (CAP) was comprehensive and capable of resolving known Comanche J Peak Response Team (CPRT) and external issues. This Third Party overview provides additional assurance that the design validation of the conduit and conduit supports satisfies the licensing commitments.
i L, 1. The TU Electric Technical Audit Program (TAP) has been in effect since January 1987. Prior to this the TU Electric Quality Assurance Department performed audits of engineering service contractors using technical specialists as part of its vendor 1
' audit program.
> 5-15 ]
. ____n____._ _ i
m.
!TU.Electiic habinitiated the: independent. Engineering Functional Evaluation s 5 (EFE)? program to provide-an overview of the. technical activities being.
conducted.on the.CPSES project.' The Engineering Functional Evaluation (EFE)' program for Conduit'and Conduit Supports Trains A and B and Train C Larger Than %.h.<
> > M,' 2' Inch Diameter, Corrective Action Program (CAP).-was initiated in May, 1987.
. Conduit-and conduit _ support design has been reviewed to' assure consistency with
- validated input data ~and to' assure outputs have been transferred to appropriate interfacing ~ organizations..
These audits represent a very detailed and complete assessment of the following:L
. Adequacy 'of the Quality Assu'rance. programs Implementation of the Quality Assurance programs
- Technical adequacy of the design criteria and procedures Implementation of the design criteria and procedures
, , .InLsome cases'these audits identified the need for procedure modifications, and specific calculation revisions to incorporate an omission or required clarification. Additional training in implementation of procedures in these
, cases was provided as required.. Each item identified in the audit report was
" carefully' reviewed and response to all items was expeditiously provided. Any
- corrective / preventive actions deemed necessary as a result. of the audit findings were; identified and implemented. Proper implementation of commitments made.in. response to the ' audit items was verified during subsequent audits..
These audits' have. confirmed technical. adequacy of Ebasco's Conduit and Conduit Supports. Trains A and B and Train C Larger Than 2 Inch Diameter Corrective Action Program (CAP).- In addition'to quality assurance audits, surveillance and reviews, TU M(7 .. Electric . Quality Control (QC) inspection program is in place on the CPSES site. QC personnel performed inspection of all attributes as delineated in the (inspection procedures prior to acceptance of any installation. In' summary, an appropriate level of attention has been given to the quality of all Corrective Action Program (CAP) activities; the Quality Assurance (QA)
, programs are appropriate for the scope of. work; project performance has been demonstrated to be in compliance with the QA' programs; and appropriate
. corrective and preventive actions were taken whenever they were required.
I s i i, o I 5-16 , l i 5 ..'______. _ _ i. J
5.3.1: Summary of Ebasco Quality Assurance (QA) Audits To date, Ebasco QA has performed 4 audits of the Conduit and Conduit Supports Trains A and B and Train C Larger Than 2 Inch Diameter Corrective Action Each Ebasco location has been audited. The following list of Program (CAP). audit subjects describes the depth of auditing that has been performed:
- 1. Adequacy of the Ebasco Project Design Procedures l
- 2. Adequacy of the Ebasco Project Procedures
- 3. Calculations - Documentation
- 4. Compliance with Project Procedures and Instructions I
- 5. Design Control
- 6. Document Control
- 7. Indoctrination and Training ;
8.- . Licensing Activities
- 9. Records Maintenance
- 10. Maintenance of Project Procedure Manuals
- 11. Personnel Qualification and Experience Verification h 12. Inputs to Conduit and Conduit Support Design Validation Process 5.3.2 Summary of Audits by TV Electric Technical Audit Program (TAP) and the NRC In addition to the Ebasco Internal Quality Assurance (QA) Audits, Ebasco was audited by the TV Electric Technical Audit Program (TAP) and the NRC.
The TU Electric Technical Audit Program (TAP) has performed 7 audits of Ebasco's activities to date. Ebasco project locations (New York, CPSES site) performing conduit and conduit support related work for CPSES have been audited. The list of audit subjects in Section 5.3.1 is representative for these audits. In addition, TV Electric Audit Program (TAP) performs audits of the technical adequacy of the Corrective Action Program (CAP). A tabulation of the TU Electric Technical Audit Program (TAP) audits is presented in Table 5-2. In August of 1986 the NRC Vendor Program Branch performed an audit of Ebasco's implementation of Ebasco's approved Nuclear Quality Assurance Program. Its inspection specifically related to Ebasco's QA Program implementation on the Comanche Peak Project. Its report, No. 99900505/86-01, indicated that the NRC inspectors found no instance where the implementation of Ebasco's QA program for CPSES failed to meet NRC requirements. NRC personnel are currently performing inspections of Ebasco's conduit and conduit supports design validation effort. The results of their inspections are expected to be published at a later date. O 5-17
5.4 CORRECTIVE AND PREVENTIVE ACTION m Ebasco has developed the technical and design control procedures and updated installation specifications to implement the corrective actions resulting from m) the Conduit and Conduit Supports Trains A and B and Train C larger than 2 inch Diameter Corrective Action Program (CAP). These procedures and specifications contain the bases for validating the conduit and conduit supports in Unit I and Common. As a result of this validation effort, CPSES Unit I and Common Trains A and B conduit and conduit supports are validated as being capable of performing their safety-related functions and the non-safety-related Train C larger than 2 inch diameter conduit and conduit supports are validated as Seismic Category II. This validation is documented in the drawings, calculations, and specifications which are contained in the Design Validation Package (DVP). This validated design documentation will be provided to TV Electric at the completion of the Corrective Action Plan (CAP). Ebasco procedures used for conduit and conduit i supports validation will also be provided to Comanche Peak Engineering (CPE). The validated design documentation and procedures can provide the basis for configuration control of CPSES conduit and conduit supports and can be utilized by TV Electric to facilitate operation, maintenance and future modifications following issuance of an operating license. Utilization of this documentation and these procedures assures that future CPSES conduit and conduit support design is performed in accordance with the licensing commitments. Training for Comanche Peak Engineering (CPE) personnel will be provided by Ebasco. The training will cover background assumptions and the methodology used in the validation of the conduit and conduit supports. o V TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from Ebasco to CPE. The program provides for the identification of those tasks presently being performed by Ebasco which are to be transferred to Comanche Peak Engineering (CPE)_ and the identification of all procedures, programs, training, and staffing requirements. The program is based upon three prerequisites: 1) the conduit related Corrective Action Program (CAP) effort to support plant completion is finished for the particular task; 2) the Unit 1 and Common conduit and conduit support Design Validation Package (DVP) is complete; 3) any required preventive action taken is complete, o j LU . 5-18
FIGURE 5-1 I' CORRECTIVE ACTION PROGRAM ( CAP) I i
.,3- FLOW CHART AND GOVERNING PROCEDURES
(,) CONDUIT AND CONDUIT SUPPORTS TRAINS A AND B AND l TRAIN C LARGER THAN 2 INCH DIAMETER DESIGN VALIDATION e , SAG. CP10 ( REF 12) DBD-CS-090 ( REF 44) <. SAG. CP17 ( REF 13) SAG. CP20 ( REF 15) ' SAG. CP25 ( REF 45) j SAG. CP29 ( REF 21) , 1 1r ISSUE MODIFICATIONS l l E-7-CP ] 3 3r ( REF 2) BUILD AND INSPECT
~'%
'(Q 1r ;
POST CONSTRUCTION _ HARDWARE VALIDATION ( ECE 9. 04-02/ECE 9. 04-05) ( REF 18/23) FVM-CS-014 ( REF 25) FVM-CS-033 ( REF 27) 1r FINAL RECONCILIATION SAG. CP35( REF 20) 1r FINAL DESIGN DOCUffNTATION 1r
! CONDUIT'AND CONOUIT
\ SUPPORTS CAP COMPLETE W h-.______m._ _ _ _ _ _ _ _
FIGURE 5-2 f POST CONSTRUCTION HARDWARE VALIDATION PROGRAM ( PCHVP) 1 j p4 g-j
. i samass esmopeest i-
.lNE14deMIDATION l l A TE I
' lMv1EE INSTALLATION f g
,, I_.PLCIFICAT1ous._ _ c0ccu,gn=
__J U Yl8 MC set M-INFECT 10Il --
? -- _-- ._ - _-- __
q l EIS?)EERIMS EMLMTION
= 1 l IDENTIFT 1
= -
N&Iau CO*1L E l vatan11. DATA l- l vit .mi.Jn GenM.Dcan = l- } j AT1RIRM S CPR1 l
~
l- #C .M l "Y' l DISP 9SITION ; i l n . l v4 1DAT10n i I gg MSULT IN EW l g MMTS W reDI ON l ACCEPTABLE l OF EXISTileG y r I l
= I
.2 4 _
.n , l I vtS PL*#*f2TER TTCieu!CE l
fC.- 3 l DISPOSITION FEASISLE yt$ l
\ x, .
l s I
.A,,,1,_
cC .m. I I
-#eult ACCESS 1tLE a l -eLTEmpenff,F m l as- o I o l comin I o
- tax i 'V,*Tu"
,c l !
.. , m I i e 1.au 1 cc.um. 0., l " l n l l fuk1RIE g gg N0 fis l
I , t ! l l j _. _ _ , i n. l l u i L_____._.___ I m 1 r I =rm.1._ ===.=- sl
- asslam parit VES _ tlaLIDAT1008 ~
PfuBEast
- Meleet Em y
D. = 9W1FICAT191l 4
1 . I g FIGURE 5-3 l -( CORRECTIVE ACTION PROGRAM ( CAP) TECHNICAL INTERFACES {f% N CONDUIT AND CONDUIT SUPPORTS TRAINS A AND B AND ! TRAIN C. LARGER THAN 2 INCH DIAMETER ! TU ELECTRIC COMANCHE PEAK ENGINEERING MANAGEMENT OF CORRECTIVE ACTION PROGRAM EBASCO CPRT l
- SYSTEM - OVERVIEW INTERACTION RESOLUTION OF l PROGRAM TECHNICAL '
INTERACTION ISSUES WITH g j - OVERVIEW SAF ETY-REL ATED COMPONENTS
/ PROCEDURES
- LOADS ON HVAC EBASCO SUPPORTS VALIDATION OF
/O CONDUIT AND SWEC-
\ ~
CIVIL / STRUCTURAL CONDUIT SUPPORTS AND MECHANICAL TRAINS A AND B - LOADS ON j EBASCO/IMPELL AND TRAIN C > 2, STRUCTURES : AND CONCRETE
- LOADS ON DIAMETER ANCHORAGES !
CABLE' TRAY - AWLIFIED l AND CABLE RESPONSE TRAY HANGERS SPECTRA
- CLEARANCES TO OTHER COMMODITIES
- ANCHOR BOLT SPACING I
1 IWELL SWEC-PSAS
)
- LOADS FROM - LOADS ON TRAIN C < 2' PIPING ;
DIAPETER SUPPORTS j CONDUIT 1 I l
i-u FIGURE 5-4 TYPICAL CONDUlT OVERHANG mC CO N FI G U RATION
's t .
. g., N
-SU P PO RT MEMBER
%'..- %,' q Q; ~
CON DUlT D '% 'N - '.
,, s s f.'Ns ,,
i.
* .. l -
' i: . . . ,,.
s',
*'%N w '
CON C RETE ' ' ,d by \ TH READE D 3! i COUPLI NG fi ! i ! J
.5 l CABLE >
., AI RD RO P
..g-<
.. j'~~ % .
'u J
'L: L _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _.__________________m__________ _________._____ __ _ _ _
L ! l' TABLE 5-1 j m POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP) ,
- s. CONDVIT AND CONDVIT SUPPORTS TRAINS A AND B l AND TRAIN C LARGER THAN 2 INCH DIAMETER ATTRIBUTE MATRIX Construction Final Acceptance PCHVP Attribute .
Work Cateaory Attribute Validation Method Conduit Type (Rigid / Flex) CPE-EB-FVM-CS-014 i (Reference 25) CPE-EB-FVM-CS-033 (Reference 27) ( Size (Diameter) CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Identification CPE-EB-FVM-CS-014 l CPE-EB-FVM-CS 033 As-built configuration CPE-EB-FVM-CS-014 (Spans / Shape) CPE-EB-FVM-CS-033 Union CPE-EB-FVM-CS-014 j (Tightness / Location / Size) CPE-EB-FVM-CS-033 1 900 Bend pull Condulet - CPE-EB-FVM-CS-014 LBD's fitting (Size / Location) CPE-EB-FVM-CS-033 Lj Coupling (Size / Location) CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Straight pull point Condulet- CPE-EB-FVM-CS-014 l BC (Size / Location) CPE-EB-FVM-CS-033 Electrical conductor seal CPE-EB-FVM-CS-014 , assemblies (Location) CPE-EB-FVM-CS-033 Pull sleeve (Size / Location) CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 450 or 900 bend flex CPE-EB-FVM-CS-014 I l connector above 2" CPE-EB-FVM-CS-033 diameter (Size / Location) Seismic restraint configuration ECE 9.04-05 (Reference 23) Conduit Supports Bolt material CPE-EB-FVM-CS-014 Clamps for clamp CPE-EB-FVM-CS-033 Bolt diameter CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 q Bolt torque ECE 9.04-05 LJ
TABLE 5-1.(continued) ;
- ,% Construction Final Acceptance PCHVP Attribute -l '
{/. . (f ~ Work Cateaory . Attribute Validation Method Conduit Supports ~ Nut material & type ECE 9.04-05 LClamps ) n .: ;(continued) _
.l Hardened washer ECE 9.04-05
.(Existence)
Nelson Stud - Diameter CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 ' Bolt length (Flush with ECE 9.04-05 face of nut) Gap between CPE-EB-FVM-CS-014 conduit and support member CPE-EB-FVM-CS-033 a- , Shims / Fillers - size CPE-EB-FVM-CS-014.
& configurations (Overhang) CPE-EB-FVM-CS-033 Clamp width or identifica- CPE-EB-FVM-CS-014 tion stamp'(P2558, 708) CPE-EB-FVM-CS-033 Clamp ~ modification ECE 9.04-05 y s,m C-708-S ('A' Dimension) p\' j -
Stud projection ECE 9.04-05 Stud torque ECE 9.04-05
~ Junction Box / Pull Junction box / pull' box CPE-EB-FVM-CS-014 Box type (Supported / Unsupported) CPE-EB-FVM-CS-033
' Junction box / pull box CPE-EB-FVM-CS-014 size'(W,L,D) CPE-EB-FVM-CS-033 Junction box / pull box CPE-EB-FVM-CS-014 number, location & I.D. CPE-EB-FVM-CS-033 of conduits entering box Junction box orientation CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 h
Af 2
, - 1
f -+ ' TABLE 5-1 (continued)
' <S . 1 Construction Final Acceptance PCHVP Attribute kf " Work Cateaory Attribute Validation Method Fire Protection /- Thermolag (Location, CPE-EB-FVM-CS-014
- Separation Barrier Configuration and Dimensions) CPE-EB-FVM-CS-033 Conduit ~ Supports Plumb / Level ECE 9.04-05 General-Member shape (Plate, 'CPE-EB-FVM-CS-014 Channel, Angle, Wide Flange, CPE-EB-FVM-CS-033 Tube Steel, Unistrut)
Member size (Thickness) CPE-EB-FVM-CS-014 other than tube section CPE-EB-FVM-CS-033 Member length CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033
. Distance to brace points CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Location of work points CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 .,\ ,
L /-' Distance and location of CPE-EB-FVM-CS-014 conduits on member CPE-EB-FVM-CS-033 Hole repair (Plug welding) ECE 9.04-05
-Unused holes (Size / Location) ECE 9.04-05 Material type ECE 9.04-05 ,
for material grades other than A36 and A500 Gap between base member and ECE 9.04-05 concrete l Base member size (Length, CPE-EB-FVM-CS-014 Width, Thickness) CPE-EB-FVM-CS-033 Base member shape (Angle, CPE-EB-FVM-CS-014 Plate, Channel) CPE-EB-FVM-CS-033 Base memter configuration CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 l 3 t
- m. _ _ _ _
4 q y:~ , ,
. TABLE' 5-1 (continued) 7 . Final Acceptance _ PCHVP Attribute ,
3 ) N ' Construction:
' Werk Cateaory Attribute . Validation Method
' Conduit Supports. . Base' member edge distance. CPE-EB-FVM-CS-014 Y General .' to' support-member CPE-EB-FVM-CS-033 1(continued)
I Identification of. member CPE-EB-FVt'-CS-014 e commodity attaches to (i.e. CPE-EB-FVM-CS-033 Structural Steel, Pipe Supports, Cable Tray Hangers) Identification of attachment CPE-EB-FVM-CS-014 point- CPE-EB-FVM-CS-033 Identification of support CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Vent hole existence CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033
' Attachment to embedded CPE-EB-FVM-CS-014 plate and to liner CPE-EB-FVM-CS-033 Conduit Supports Bolt material CPE-EB-FVM-CS-014 .
Bolted Joints - CPE-EB-FVM-CS-033 b*~ Bolt diameter CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033
. Bolt length ECE 9.04-05 Bolt torque - ECE 9.04-05
. Bolting configuration CPE-EB-FVM-CS-014 as per design drawing CPE-EB-FVM-CS-033 Bolt edge distance to free CPE-EB-FVM-CS-014 end of structural member CPE-EB-FVM-CS-033 Washer bearing contact CPE-EB-FVM-CS-014 ,
(Bevel / Flat) CPE-EB-FVM-CS-033 i Washer orientation CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 g Nut material & type ECE 9.04-05 4 u
.y g.
+
i k -TABLE 5-1 (continued) n , , , Construction. Final Acceptance PCHVP Attribute b-b) i, 'l Work Cateaory- Attribute Validation Method Conduit' Supports- Bolting' material. CPE-EB-FVM-CS-014
, Bolted Joints CPE-EB-FVM-CS-033
-(Continued)
Turning elements on correct- ECE 9.04-05 face Hardened washer (Existence) ECE 9.04-05 Bolt looseness CPE-EB-FVM-CS 014 CPE-EB-FVM-CS-033 IConduit Supports -. Weld size / length ECE 9.04-05
- Welding
. Weld profile - ECE 9.04-05 Weld location ECE 9.04-05 Weld fusion ECE 9.04-05 Weld Undercut ECE 9.04-05 .
Surface slag (existence)
- ()- ECE 9.04-05 Porosity-(existence) ECE 9.04-05 Weld overlap-(existence)_ ECE 9.04-05 Craters-(existence) ECE 9.04-05 ARC strikes (existence) ECE-9.04-05 ,
Cracks (existence) ECE 9.04-05 Conduit. Supports Hilti bolt type and diameter CPE-EB-FVM-CS-014 Anchorage (Super-Kwik or Kwik) CPE-EB-FVM-CS-033 Hilti bolt marking (Length) CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Hilti bolt projection CPE-EB-FVM-CS-014 (From face of concrete) CPE-EB-FVM-CS-033 Hilti bolt washer type CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 Hilti bolt thread CPE-EB-FVM-CS-014
', h: engagement CPE-EB-FVM-CS-033 5
I _ _ _ _ _ _ . . . _ _ _ . _ _ - . _ _ ...__-__E
, ,u _
v i s .' f TABLE 5-1 (continued) C Final Acceptance PCHVP' Attribute J (Construction ~
. Work CateaorvL -Attribute Val-idation Method a;
Conduit Supports .Hilti. bolt torque' ECE 9.04-05
' Anchorage .
(Continued). .. . Hilti Bolt l Angularity ECE 9.04-05 ? Hilti bolt-nut not ECE 9.04-05 bottomed out
-Richmond insert diameter'- CPE-EB-FVM-CS-014 CPE-EB-FVM-CS-033 i
Richmond in' sert-bolt CPE-EB-FVM-CS-014 material CPE-EB-FVM-CS-033 <' Richmond insert-double CPE-EB-FVM-CS-014 nuts for threaded rod CPE-EB-FVM-CS-033 Richmond' insert-thread ECE 9.04-05 J. engagement 1
.) '
h l L 'Ill 3 6 ) l y-u L .
.. .l
s Table 5-2 ! l
>"., TV ELECTRIC AUDITS qf
~ Audit File Number letter Number Date v -
TES-8 QVC-584 November 24, 1986 TCP-86-21 QIA-97 May 9, 1986 TCP-87-24f In-progress In-progress ATP-87-Ol' ATP-7005 April 20, 1987 ATP 87-19 ATP-7117 June 29, 1987 1 ATP-87-32 ATP-7219 August 12, 1987 ATP-87-35 alp-7218 August 13, 1987
,. s
( 1 l i b l 1
<-~s I 1
l
p p , I 6.0 ' REFERENCES h, 10.s 1 ~. Generic Technical Issues' Report (GIR), " Evaluation and W' ")' . Resolution of Generic-Technical Issues for Conduits and Conduit Supports", Revision 2, dated March 30, 1987. , 4
- 2. Ebasco Engineering. Procedure E-7-CP, " Review / Approval of Drawings, Diagrams, and Lists - Nuclear Projects," Revision 7, dated.0ctober 26, 1987. i l
- 3. Comanche Peak Steam Electric Station Final Safety Analysis I Report. i 4
- 4. Drawing No. 2323-S-0910 design document.
- 5. Regulatory Guide 1.29, " Seismic Design Classification", .
Revision P, February 1976. ! i
- 6. CCL Report No. A678-85, " Seismic Qualification Test Report of Conduit Support Systems", Volume I and II, October 9, 1985.
-7. .CCL Report No. A699-85, " Conduit Clamp Test Report", Phase I, !
December.17 1985.
- 8. CCL Report No. A-702-86, " Conduit Clamp Test Report", Phase II,
- April 7, 1986. -
- 9. Ebasco Manual- of Procedures for CPSES.
h'~ 10. TV Electric CPSES Unit I and Common, Impe11 Conduit Supports
. Train C Two Inch Diameter and Less Project Status Report, Revision 0.
- 11. TV Electric Specification No. 2323-SS-30, " Structural ;
Embedments", Revision 3, August 3, 1987. '
- 12. Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic Category I: Electrical Conduit System", Revision 6, dated October 30,'1987.
- 13. Ebasco Procedure No SAG.CP.17, " Unit 1 Design Criteria for Junction' Boxes for Seismic Category I Electrical Conduit System", Revision 7, dated October 12, 1987. l l
- 14. TU Electric CPSES Unit 1 and Common, SWEC Mechanical Project Status Report, Revision 0. l j
- 15. Ebasco Procedure No. SAG.CP20, " Unit 1 Technical Guidelines for ,
-System Analysis of Conduit Span Configuration", Revision 4, j dated October 13, 1987.
- 16. TV Electric Procedure, NQA-3.09-2.05, " Civil Concrete Anchor Inspection Activities", Revision 0, August 19, 1987.
7 17. Regulatory Guide 1.100, " Seismic Qualification of Electrical ! Q - Equipment for Nuclear Power Plant, " Revision 1, August, 1977. 6-1 l
[ r
- 18. TV' Electric procedure ECE 9.04-02, " Post Construction Hardware
- Validation Program. Implementation Plan - Ebasco Services,
. 2: Inc.", Revision 0, July 28, 1987.
9': 19.- TU Electric Specification No. 2323-ES-100, " Electrical Installation Class I, II and Non-Safety", Revision 3, June'5,
-1987.
. 20. - Ebasco Procedure No. SAG.CP35, " Procedure for Conduit Isometric
. Design Validation Package Close-out", Revision 0, dated' October
.16, 1987.
'21. Ebasco Procedure No. SAG.CP29, " Unit .1 General Instructions for
~ 0esign-Verification of Electrical Conduit and Box Supports",
Revision 4, dated October 12, 1987.
- 22. TV Electric CPRT Program Plan, DSAP VIII, Appendix B and .
H . Appendix C, Revision 1, January 24,.1986. '
- 23. TU Electric Procedure ECE 9.04-05, " Post Construction Hardware
~ Validation Program - Engineering Evaluations", Revision 0, September 1, 1987.
25.. CPE-EB-FVM-CS-014 " Design Control of Electrical Conduit Raceways for Unit 2 Installation in Unit 1 & Common Areas", , Revision 4, February 2, 1987.
- 26. TU Electric Specification No. 2323-SS-09, " Concrete", July 17,
, 1987. .
27 .- CPE-EB-FVM-CS-033,." Design Control of Electrical Con'duit Raceways for Unit 1 Installations in Unit I and Common Areas", Revision 2,' dated August- 14, 1987.
- 28. TU Electric CPSES Unit 1 & 2 " Design Basis Consolidation
~ Program Plan", Ebasco Services, Inc., Revision 1, April 11, 1987. '
- 29. TU. Electric Procedure NQA-3.09-2.03, " Conduit Support Field Inspection", Revision 1, September 24, 1987.
30.- TU Electric Specification No. 2323-SS-16B, " Structural Steel / Miscellaneous Steel (Category I and II)", Revision 1,
' July 14, 1987.
- 31. TU Electric Specification No. ECP-19 " Exposed Conduit / Junction Box and Hanger Fabrication and Installation", Revision 15, August, 31, 1987. ;
i L 32. Regulatory Guide 1.64, " Quality Assurance Requirements for the ! Design of Nuclear Power Plants", Revision 2, dated June 1976.
- 33. ' TU Electric Letter No. TXX-6631, W. G. Counsil to U.S. Nuclear
! Regulatory Commission, Comanche Peak Programs, August 20, 1987. l 6-2 L _. j
y} , n g.- E34.: LCCL' Report No.<A-746-87,." Static and Cyclic Te'st..of. Conduit-W Couplings", Revision:0, June 110, 1987. jh fg. .
~
TU Electric Letter No. TXX-6500 W.LG. Counsil to U.S. Nuclear O 3 5 . ,- yf':J n l Regulatory Commission,. Comanche. Peak Programs, June 25, 1987. m ' E36h : Ebasco ' Nuclear- Quality' Assurance Program, ETR-1001 ' for. CPSES.
, 37. Regulatory Guide'132, " Combining. Modal Responses' and Spatial 3 ? Components.in' Seismic Response Analysis", Revision 1, February y ~~'1976.
" ~
38 '. . CYGNA, Conduit Supports Review Issues List,. Revision 3, NovemberJ20,u1985.
- 39. ;TV Electric Engineering and Construction Policy No.1, CPSES Corrective Action Program,' Revision 2, September 28, 1987, a - 40.- TENERA,. L.P. Discipline . Specific Result Report:
W"' Civil / Structural . -Train A&B Conduit and Supports, Revision 1. s '41h 'TU Electric CPRT.. Program Plan, Appendix' E. L 142.- LTU Electric Task Description No. CPE-TD-EB-033, " Interface 7+ .0 .iControl Guidelines", Revision 4, August 12, 1987.
- 43. TU Electric Task Description No. CPE-TD-EB-060,' " Conduit Design -
Adequacy. Program", Revislon.2, October 9, 1987. ( f44.: CPSESl Design'BasisDocument,DBD-CS-90,"ConduitandConduit-
-Supports Design Train A, B and Greater than Two' Inches Diameter Train C Conduits", Revision l.
- 45. Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for
. Seismic Category I Electrical Conduit Isometric Validation",
Revision 1, dated October 16, 1987. 3
..r h
)
6-3 j i l u j
.. - - J
1 APPENDIX A )
'q COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL ISSUES x)
- 1. Introduction This appendix contains a comprehensive summary of the Ebasco evaluation,
-resolution and corrective and preventive action for all Comanche Peak Response Team (CPRT) and external issues which are related to the conduit and conduit support designs. Specific references to the criteria, procedures, engineering studies and tests which have resolved the issue are provided.
I To report the resoletion of the Comanche Peak Response Team (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. { i TheissuescontainedinSubappendicesAlthrouggA29areincludedinthe l CYGNA Energy Services (CYGNA) Review Issue List (RIL). The issue { contained in Subappendix A30 was initially raised by the Comanche Peak Response Team (CPRT) - Quality of Construction (QOC) Program. l l The preventive action is embodied in the procedures and the Design Basis l
-Document (DBD) developed and used in the conduit and conduit supports I
~ Corrective Action Program (CAP). These procedures and the Design Basis Document (DBD) resolve all CPRT and external issues. Implementation of ,
these preventive actions will assure that the design and hardware for l r CPSES. Unit 1 and Common conduit and conduit supports will continue to , C]/ comply with the licensing commitments throughout the life of the plant as described in Section 5.4. I Comanche Peak Response Team (CPRT) and external issues contained in l Appendix A are listed below: Issue No. Issue Title Al Governing Load Case for Design A2 Dynamic Amplification Factors , A3 Combination of Deadweight and Seismic Responses ! A4 Measurement of Embedment from Top of Topping i A5 Bolt Hole Tolerance and Edge Distance Violation ] A6 FSAR Load Combinations > A7 Support Self Weight ! A8 Torsion of UNISTRUT Members l A9 Improper Use of Catalog Components A10 Anchor Bolts All Longitudinal Loads on Transverse Supports
- 1. CYGNA, " Conduit Supports Review Issues Lists (RIL) Comanche Peak Steam Electric Station Independent Assessment Program - l All Phases", Revision 3, transmitted to TV Electric by CYGNA Energy Services in letter No. 84056-094, November 20, 1985.
i n l
$]
1 j l _ ___ i
g ,,, P , l% 0 m Issue No. : Issue Tith : Mg' ' S A12 '- l Hilti Kwik-Bolt: Substitutions-if d j 'A13' Substitution of Smaller Conduits on CA-Type Supports is.. ~~ J J A14 :i , 1Use of CA-Type Supports in LS Spans
'A15 ' Stresses in. Cable Trays due to Attached Conduit
$'W fu , .. Supports; mi -
' ,-A16. -
- Increases inl Allowable Span Lengths
.A17' Substitution.of Next Heavier Structural Member w lA18' Clamp l Usage; ~
- h. v., ' Documentation Deviations between Inspection Reports,
' A19
~CMCs'and?IN-FP Drawings =
<r i- A20' . Nelson' Studs-U Conduit Fire Protection Calculations A21:
'A22 . Span Increase for Fire Protected Spans wl. 'J .A23 .Crouted Penetrations F ",' ,
~A24. : Rigidity'of CA-Type Supports 13
,A25' Enveloping Configurations for; Design.
A26l ^ Design Drawing Discrepancies A27 Walkdown Discrepancies A28 . Systems Concept A29 Cumulative'Effect of Review Issues A30- Conduit Unions i.y , 3. I ( a L k 4 v. )- i:. j i
. d s
y, A-2 l
._2. _- r __u _ _ _ . _ _ _ _ >
i
,I SUBAPPENDIX Al !
c GOVERNING LOAD CASE FOR DESIGN (CYGNA ISSUE NO, 11
I 1.O Definition of the Issue I l
The issue was that by designing catalog items for the Operating Basis { Earthquake (0BE) event only, the design factor of safety may not have been , maintained for the Safe Shutdown Earthquake (SSE) event. The original design ! of the conduit and conduit supports assumed that a 60 percent increase in the i Safe Shutdown Earthquake (SSE) allowables was applicable to all conduit and i conduit support components rather than only to the allowables for structural steel as specified in the CPSES Final Safety Analysis Report (FSAR) (Reference 4.4). 2.0 Issue Resolution The design validation procedures (References 4.1 and 4.2) require that the conduit and conduit supports be evaluated for the effects of Operating Basis Earthquake (0BE) and Safe Shutdown Earthquake (SSE) loads separately. Appropriate OBE and SSE allowables are included in the design validation procedures and are used in the design validation of conduit and conduit support components including structural steel, welds, anchorages, and catalog items Hilti Kwik Bolts (HKBs), Richmond Inserts, Nelson Studs, and UNISTRUT/ SUPER STRUT clamps and their components. 3.0 Corrective and Preventive Action
,m 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TU Electric to the NRC (Also see Subappendix B3). 3.1 Corrective Action Conduit and conduit supports have been design validated for the effects of Operating Basis Earthquake (OBE) and Safe Shatdown Earthquake (SSE) loads, using appropriate allowables (References 4.1 and 4.2) for the conduit and conduit support components including structural steel, welds, anchorages and catalog items Hilti Kwik Bolts (HKBs), Richmond Inserts, Nelson Studs, and UNISTRUT/SUPERSTRUT clamps and their components. 3.2 Preventive Action Problems similar to this issue will be precluded because the design validation procedures (References 4.1 and 4.2) require a separate evaluation of the Operating Basis Earthquake (0BE) and Safe Shutdown Earthquake (SSE) loads. In addition, the criteria used for the design validation of conduit and conduit supports have been documented in the Design Basis, Document (DBD) (Reference 4.3). Al-1
L i i hy , SUBAPPENDIX Al
-4.0' References f4 :
4.1 Eb'asco Procedure No. SAG.CP10, " Unit 1. Design Criteria for Seismic Category I~ Electrical Conduit System," Revision 6, dated October 30, ; L1987. I 4.2 Ebasco Procedure No. SAG.CP17 " Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System," Revision 7, dated October 12, 1987. 4.3 Comanche Peak Steam Electric Station Design Basis Document, . DBD-CS-090, " Conduit and Conduit Support Design Train A, B and Greater than Two Inch Diameter Train C Conduits," Revision 1. c w; 4.4 CPSES FSAR, Section 3.8.3 and 3.8.4 with current amendments.
.wf'\
i l 4 1 1 Al-2 l' l i l' ._ _ - - _ - _ - - _ _ _ - - - _ - - - _ _ - - - _
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, SUBAPPENDIX A2 m-[wy n'
. DYNAMIC AMPLIFICATION FACTORS'(CYGNA ISSUE NO.2)
]
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- l A . liOI"M Definition of the Issue .
l
^
.zTheIissue was;that for conduit and' conduit supports designed;by the equivalent
- static method,- the seismic. load was not increased to' account for a dynamic )
g4 < amplification. factor (DAF)l of:1.5:as specified in Section 3.78.3.5 of the CPSES. j LFinal" Safety Analysis Report (FSAR) (Reference 4.7). - i.l pm 2.0 -Issue Re' solution > The design' validation procedures:(References 4.2 through 4.5) for ' conduit and
; conduit supports require ^the use of one of the following three methods-to ;
account; for a' dynamic; a'nplification . factor (DAF): i
.(1) 'Using a seismic acceleration of 1.5 times peak spectra acceleration from.the Amplified Response Spectra (ARS) as the seismic. load. !
vx !
#(2). Us'i ng design accelerations derived through analytical procedures as 4 .
-_specified in Reference 4.1 as the: seismic load..
i (3) .Using seismic ~ accelerations derived from Response Spectra Method ! 7(RSM)' for specific conduit and conduit support configurations as the
. seismic load.- l 9 3 . 0' Corrective l and Preventive Action.
v0- 's .
. No? additional' issues were identified during' the review and resolutio'n of this o
(issue. 1 T ' Thisiissue was determined to be reportable under the provisions of ;
.10CFR50.55(e).: ~It was reported as Significant Deficiency Analysis Report
.(SDAR)LCP-85-34 incletter number TXX-6047, dated October 21,'1986 from TV Electric to:the NRC (Also see Subappendix B3).
- 3.lu Corrective Action
- ConduitLand conduit supports have been design validated utilizing a dynamic !'
p amplification factor (DAF) as required in References 4.2 through 4.5.
? -
3.2 Preventive Action v ; 1.: ;The design validation procedures (References 4.2 through 4.5) require the use i E of a' dynamic: amplification factor (DAF) for conduit and conduit supports. In saddition,:the design criteria used in the design validation of conduit and
. conduit supports-have'been. documented in the Design Basis Document (DBD)
;(Reference 4.6)'. .
p J T V A2-1 4 I i L _ . . _ _ _ . _ _ - _ _ _ _ _ _ - _ _ _ _ - - - - - _ _ _ _ -
"7 ' j . 1
.SUBAPPENDIX A2 y
af , . 4 0..
. Reference s -.
,/ y.
M f 41L Ebasco' Procedure No.; SAG.CP20, " Unit 1 Technical-Guidelines for- f System ' Analysis of Conduit Span Configurations," Revision 4, dated
-October 13, 1987. ;
4.2 .Ebasco Procedure No. SAG.CP10,." Unit 1 Design Criteria for Seismic w _ Category-I Electrical Conduit System," Revision 6, dated October 30,.
.~1987..
i 4.3 .Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for-
~
Seismic. Category I Electrical Conduit Isometric Validation," Revision.1, dated October 16, 1987. 4.4' Ebasco Procedure No. SAG.CP17, " Unit 1 Design Criteria for Junction Boxes for Seismic.' Category I Electrical Conduit System," Revision 7, dated October 12, 1987. 4.5. Ebasco Procedure No. SAG.CP29, " Unit' 1 General Instructions for 4 Design Verification'of Electrical Conduit and Box Supports,"
.f Revision 4,, dated October 12, 1987.
4.6 Comanche Peak Steam Electric Station Design Basis Document, '! DBD-CS-090, " Conduit and Conduit Support Design Train A, B and
. Greater than Two Inch' Diameter Train C Conduits," Revision 1.
4.7-CPSESFShR,Section'3.7withcurrent. amendments. l th -
, )
i o I
.]
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y v ,2 ; # ,
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p 1 I]l k ' ; ';SUBAPPENDIX A3 6 ; COMBINATION ~0F DEADWEIGHT AND SEISMIC RESPONSES'(CYGNA ISSUE NO.3)
.jk l. ,
a h
'\ 1.0,: Definition of th'e? ssuei ?
I
,y [Thelissue was th'a't in the design calculations,'the acceleration'due:to
.deadweights(D) was improperly. combined with the seismic accelerations using the
- h r , Square'Roottof thel Sum of 4he' Squares-(SRSS) method. A 1.0g' deadweight' 4 4
-acceleration was first added;to the vertical seismic acceleration. The sum was y, thenicombined with theltwc horizontal seismic acceleration components using the 4 NSquare. Root of the Sum'ofLthe Squares (SRSS) method.
2.0: Issue ReJolution iThefdesign validation procedures for conduit'and conduit supports.(Reference
- i. '
4.1?and.4.2) require that the acceleration due to deadweighti(D).be combined
'separatelyifrom the: seismic accelerations.. .Only the; vertical- and two.
. horizontal seismic accelerations are' combined using the Square Root of the Sum of the Squares.(SRSS)? method.
,3.01 <Correctivefand Preventive Action
,i_ E' , ;No! additional: issues were!identifiedLduringlthe review and resolution of this B iD issue.
- U This issue was' determined to be reportable under the provisions of t
's .L 10CFR50'.55(e) . It was reported as Significant Deficiency Analysis Report' hc- ' , LElectric :(SDAR)~CP-85-34?in letter number TXX-6047, dated October #21, 1986 from TU to the NRC'(Also see Subappendix B3).
13.1 Corrective Action p w w C .Cohduit~and conduit' supports have been design validated based on the- 4 h
, acceleration due to deadweight (D) effects being added separately to the Square 'l h:
1
' Root of the Sum of the. Squares (SRSS)' seismic acceleration effects (References ,
14;1,and 4.2)'.. -{ 4 L3.2 : Preventive Action : j '. The design validation procedures (References 4.1 and 4.2) . require the i
- acceleration due te deadweight-(D) effects-to be added separately to the Square
- Root of the Sum of.the' Squares (SRSS) seismic acceleration effects. In addition, the criteria used for the design validation of conduit and conduit .
! supports have been documented in the Design Basis Document (DBD) (Reference 4.3)~ .
- >3 q. A3-1 l: h ,
- ,7 ll_ ~ s > .z SUBAPPENDIX A3-o -. .
, '4'.0 ! References
'4.1' ' Ebasco Procedure No.- SAG.CPIO,: " Unit 1 Design Criteria for Seismic Category I Electrical. Conduit' System," Revision 6, dated October 30.
1987. 4.2 Ebasco-Procedure No.. SAG.CP17,." Unit.1 Design Criteria for Junction
- Boxes for Seismic. Category I Electrical Conduit System," Revision 7, 1 dated October 12, 1987.
4.3E Comanche Peak Steam Electric Station Design Basis Document, j DBD-CS-90, " Conduit and Conduit Support Design Train A, 8 and Greater;than Two Inch Diameter Train C Conduits," Revision 1. 10
'"I I i, A3-2 i
1 h-1* . . . . .
SUBAPPENDIX A4 1 MEASUREMENT OF EMBEDMENT FROM TOP 0F TOPPING (CYGNA ISSUE NO, 4) i
~-
1.0 Definition of the Issue I The issue was that a note on the original Drawing No. 2323-S-0910 design i document allowed a full Hilti Kwik Bolt (HKB) embedment for certain supports at ) lower building elevations where a 2 inch architectural floor topping was j placed. Since the integrity of the architectural topping can not be assured, i an evaluation of all affected designs must be made to account for a reduction j of 2 inches in embedment length for Hilti Kwik Bolt (HKB). ' 2.0 Issue Resolution The original Drawing No. 2323-S-0910 design document (Reference 4.1) was revised to specify embedment length requirement for Hilti Kwik Bolts (HKBs) installed in the areas with a 2 inch floor topping. Floor counted conduit or junction box supports were identified by.an engineering walkdown (Reference 1 4.4) and design validated using the as-built embedment length (as measured from the top of the topping) minus 2 inches as specified in design criteria (References 4.3 and 4.5) in areas with architectural topping. 3.0 Corrective and Preventive Actio_n No additional issues were identified during the review and resolution of this issue. m
) 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B3).
3.1 Corrective Action The floor-mounted conduit or junction box supports in the areas with a 2 inch floor topping have been design validated in accordance with the design validation procedures (References 4.3 and 4.5) to include the effect of the reduced embedment on the support adequacy. 3.2 Preventive Action Drawing No. 2323-S-0910 design document (Reference 4.1) specifies embedment length requirements for Hilti Kwik Bolts (HKBs) installed in areas with 2 inch architectural topping. The design validation procedures (References 4.3 and 4.5) require the reduction of 2 inches from the embedment length as measured from the top of the topping. In addition, the criteria used for the design validation of conduit and conduit supports have been documented in the Design 1 Basis Document (DBD) (Reference 4.2). p QJ A4-1 i
f
't . ) -.
SUBAPPENDIX A4 ji 4.0? References !
.e e ' ' \~) --
(4.1 Drawing No. 2323-S-0910 design document,.Sh. G-4a, Revision CP-01, March 31, 1987 h 4.2 Comanche' Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit Support-Design Train A, B and Greatcr Than 2. Inch Diameter Train C Conduits," Revision-1.
.4.3; Ebasco; Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic
. Category I Electrical Conduit System," Revision 6, dated October 30, 1987.
4.4 CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways for Unit 1 Installations in Unit I and Common Areas," Revision 2, I dated August 14, 1987. 4.5 Ebasco Procedure'No. SAG.CP25, " Unit 1 Technical Guidelines for i Seismic Category'I Electrical Conduit Isometric Validation," Revision 1, dated October 16, 1987. 1 I i v< ! l
. ,x.>.
I l a. [h V A4-2 l l
i 4
- SUBAPPENDIX A5 BOLT HOLE TOLERANCE AND EDGE DISTANCE VIOLATION (CYGNA ISSUE NO. 5) 1.0 Definition of the Issue A. The issue was that conduit support bolt hole tolerances in excess of 1/16 inch were specified on the original Drawing No. 2323-S-0910 design document. These bolt holes were considered to be oversized, since they .
could violate the American Institute of Steel Construction (AISC) ! specification (Reference 4.1) requirement, which is a 1/16 inch tolerance. . a B. The issue was that edge distance in structt.ral members may not always comply with requirements of the American Institute of Steel Construction > (AISC) specification. For example, conduit support type CA-5a and CSM-42 have insufficient edge distances. 2.0 Issue Resolution 1 A. There are two kinds of connections in conduit supports: steel to concrete and steel to steel. For the former, the AISC specification requirements for bolt hole tolerance do not apply (Reference 4.9). The effects of oversized bolt holes in concrete connections have been evaluated through the use of analytical methods and test data. Engineering studies (References 4.4 and 4.5) have demonstrated that these concrete connections are acceptable. The steel to steel connection's ) bolt hole size requirements are governed by the AISC Specification. 3n There are two categories of steel to steel connections employed in t.J - conduit supports: clamp to support connections and connections to structural members. The clamp to support connections are qualified by tests (References 4.2 and 4.3) performed with the oversized bolt holes specified in the Drawing No. 2323-S-0910 design document. The results of these tests established the clamp capacities utilized in the design validation of the conduit and conduit supports. Engineering studies (References 4.4 and 4.5) have demonstrated that the connections to structural members with the oversized bolt holes specified in Drawing No. 2323-S-0910 design document are acceptable. L B. The support configurations contained in the Drawing No. 2323-S-0910 design document which have bolted connections, have been design validated l by an engineering study (Reference 4.6). This study considered the edge distances allowed by the original Drawing No. 2323-S-0910 design document, and utilized the guidelines of the American Institute of Steel Construction (AISC) for the design validation. Support types CA-5a and CSM-42 were included in this study and were found to be acceptable. Edge distances in structural members of conduit supports were determined during the engineering walkdowns. This as-built data was used to design validate the conduit support configurations with bolted connections. 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue. j (3 ( (j I A5-1 ! l l l
SUBAPPENDIX A5-E va > .This issue was determined to be reportable under the provisions of P V ' 10CFR50.55(e). It was reported as.Significant Deficiency Analysis Report
- (SDAR).CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV l Electric to the NRC (Also see Subappendix B3).
Corrective Action- < 23.1:
~
Engineering studiesfon the effects-of oversized bolt holes on the' conduit and I r conduit support capacities have been performed. The results of this study (Reference 4.6)'have demonstrated the acceptability of the methodology used for the design ~ validation process. Conduit supports included in the Drawing No. I
- 2323-S-0910 design document have been design validated utilizing engineering -
' study ~(Reference 4.6) and the edge distances allowed by the original Drawing No:-2323-S-0910 design document. As-built edge distances were obtained by engineering walkdowns and the as-built data was used in.the design validatior, process.
3.2 Preventiv_g Action i
'The results of the . edge ' distance study were incorporated in the Drawing No.
2323-S-0910 design document. ~The criteria requiring adherence to the AISC specification has been included in the conduit and conduit support design validation procedure'(Reference 4.7). In addition, the criteria used for the
' design validation of conduit and' conduit supports have been documented in the ,
Design Basis' Document (DBD);(Reference 4.8). l 1 4.0 References
~4.1 AISC Manual of Steel Construction, 7th Edition including Supplements l No.'1,'2'and 3.- ;
1
~
4 '. 2 CCL Report No. A-699-85, Conduit Clamp Test Report,' Phase I, December 17, 1985. ;
'4.3' CCL Report No. A-702-86, Conduit Clamp Test Report, Phase II, April l
-7,.1986. l 4.4 -Ebasco'CPSES Unit 1, Conduit Calculation Book No. Supt-0253, Revision 1, dated October 26, 1987. !
4.5 Ebasco Position Paper - TV Electric, Comanche Peak Steam Station i Units 1 and 2, " Effects of Bolt Hole Oversize in CTH System and Conduit System Adequacy", Revision 4, October 16, 1987. 4.6 Ebasco CPSES Unit 1, Conduit Calculation Book No. 0246, " Support Verification for CYGNA Issue No. 5, Bolt Hole Tolerance and Edge Distance Violation", Revision 2, October 30, 1987. A5-2 um __ _ _ _
7
-R
'SUBAPPENDIX A5 s.
.12lip l
'l(7l > '
24.7i. Ebasco Procedure No.' SAG.CP10, " Unit 1 Design Criteria for Seismic
- Category I Electrical Conduit' System", Revislon 6, dated October 30,
.M 1987.
.4 o
; w. :4.8i Comanche Peak Steam. Electric Station Design Basis Document, DBD CS-090, " Conduit ~and Conduit Support Design Train A, B and Greater Than Two: Inch Diameter Train C Conduits", Revision-1.
f4.9lAISC. Letter:toL.D.NacedatedAugust 29, 1986. [ k ( L O. . I ! i. A5-3 p _ = _ - _ . _ _ _ _ _ _ _ _ - - _ __ _ _ _ _ _ - _ -
L ) 1 1 SUBAPPENDIX A6 1
,m FSAR LOAD COMBINATIONS (CYGNA ISSUE NO. 6)
() l 1.0 Definition of the Issue l The issue was that all applicable loads, as defined in the CPSES Final Safety l Analysis Report (FSAR) (Reference 4.7), were not explicitly included in the conduit and conduit support design. Loads which result from normal operating and' accident temperatures as well as jet impingement, pipe whip, internally generated missiles and tornado effects were not addressed. In addition, seismic response spectra of the Containment Building and internal structure within the Containment Building should have been enveloped to design conduit and conduit supports which are supported by the Containment Building shell and Containment Building internal structure. 2.0 Issue Resolution Sections 4.0 and 7.0 of Reference 4.1 and Section 7.0 of Reference 4.2 specify the applicable loads and load combinations to be utilized for conduit and conduit support design validation. The loads and load combinations are based on CPSES Final Safety Analysis Report (FSAR) (Reference 4.7). Pipe whip,' jet impingement, internally generated missiles and tornado effects (where applicable) are addressed by the CPSES System Interaction Program (SIP). The results of the SIP Corrective Action Program (CAP) described in the Mechanical Project Status Report (PSR) (Reference 4.6) indicated that safety-related conduit and conduit supports have either been relocated or (n') shielded from the pipe whip, jet impingement and internally generated missiles. There are no safety-related conduit and conduit supports affected by tornado or tornado generated missiles. The effects of both normal operating temperature (To) and accident temperature (Ta) loads on conduit and conduit supports have been determined based on a detailed engineering study performed by Ebasco and described in Reference 4.3. The results of this. study of thermal loads are summarized in Appendix 10 of Reference 4.1. Conduit and conduit supports have been design validated in accordance with Reference 4.4. Response spectra which envelope the Containment Building shell and the internal structure response spectra were utilized as input for the Response Spectra Method (RSM) of analysis for conduits and conduit supports which are supported by both the Containment Building shell and the internal structure (Reference 4.4). All other loads in the load combination as specified in the CPSES FSAR and incorporated in the design validation procedure (Reference 4.1) were included in the design validation of the conduit and conduit supports. O. U A6-1 l
SUBAPPENDIX A6 3.0 Corrective and Preventive Action U No additional issues were identified during the review and resolution of this . issue. l This issue was determined to be reportable under the provisions of f 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV , Electric to the NRC (Also see Subappendix B3).
-3.1 Corrective Action Ct,nduit and conduit support design criteria (References 4.1 and 4.2) require that the effects of all loads identified in the CPSES Final Safety Analysis Report (FSAR) (Reference 4.7) be included in the design validation of conduit and conduit supports. Design validation of conduit and conduit supports was performed in accordance with References 4.1 through 4.4. The CPSES System
, Interaction Program (SIP) determined that there are no conduit or conduit supports which are targets for pipe whip, jet impingement, missile or tornado effects. 3.2 Preventive Action The design validation procedures (References 4.1 through 4.4) identify the loads that must be utilized in the design validation of conduit and conduit supports. In addition, the load definition and load combination criteria used i for the design validation of conduit and conduit supports have been documented
'l in the Design Basis Document (DBD) (Reference 4.5). ,G 4.0 Egferences 4.1 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit System", Revision 6, dated October 30, 1987.
4.2 Ebasco Procedure No. SAG.CP17, " Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System", Revision 7, dated October 12, 1987. 4.3 Ebasco Procedure No. SAG.CP21, " Unit 1 Technical Guidelines for Thermal Analysis of Seismic Category I Electrical Conduit System", Revision 3, dated October 13, 1987. 4.4 Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric Validation," Revision 1, dated October 16, 1987. I 1 A6-2 l _ _ _ __ L
SjlBAPPENDIX A6 ) h 4.5 Comanche Peak Steam Electric Station Design Basis Document 0B0-C5-090, " Conduit and Conduit Support Design Train A, B and Greater Than Two Inch Diameter Train C Conduits," Revision 1. 4.6 TV Electric CPSES Unit I and Common, SWEC Mechanical Project Status Report, Revision 0.
-4.7 CPSES FSAR Sections 3.8.3 and 3.8.4 including current amendments.
3 l e i j O A6-3
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L , SUBAPPENDIX A7 j: .. SUPPORT SELF WEIGHT (CYGNA ISSUE NO. 7) 73 C) 1.0 Definition of the Issue The ~ issue was that support loads due to the self weight of the support were not
- calculated consistently.
2.0 Issue Resolution Section 4.0 of Reference 4.1 and Section 7.0 of Reference 4.2 specify that the self weight of the support be utilized in design validation. The design validation process has consistently considered the self weight of the support. 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 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TU
- Electric to the NRC~(Also see Subappendix B3).
3.1 Corrective Action Supports were design validated in accordance with the design validation procedures (References 4.1 and 4.2) to include the self weight of the support. 3.~ 2 Preventive Action The design validation procedures (References 4.1 and 4.2) require that the self weight of the support be utilized in the design validation of the supports. In addition, the criteria used for the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.3). 4.0 References 4.1 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic l Category I Electrical Conduit System," Revision 6, dated October 30, ' 1987. 4.2 Ebasco Procedure No. SAG.CP17, " Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System," Revision 7, ,
' dated October 12, 1987. J t.
4.3 Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit Support Design Train A, B, and Greater than Two Inch Diameter Train C Conduits," Revision 1. l C( A7-1 i L t
)[2 h ,
7 g O SUBAPpENDIX A8 dhh'] f, TORSION OF'UNISTRUT MEMBERS'fCYGNA ISSUE NO. 8)
.1.0 ! Definit' ion of the-Issue
)f .
.,- A. The original issue _ was that torsional loading of UNISTRUT members' was not M, ' considered.in the support design. Testing of UNISTRUT members was I
- determined to be'the. method utilized to evaluate the support capacity.
" B. The 'following additional . issues' resulted from CYGNA's review of the Corporate Consulting-and Development Company, Ltd (CCL) test (Reference l '
- 4.1):
The conduit support types. selected for test may not represent all
~ support. types installed at CPSES site. Also,. test results for some conduit supports may have been affected by improper test set up.
1
'Only'one conduit clamp type (C-708-S) for large conduit sizes was l
= included in most of the tests. -
L 2.0, Issue Resolution { , . . ,.c A.: Tests were performed by Corporate Consulting and Development Company, o Ltd. (CCL) which included the torsional load effect on the UNISTRUT members (Reference 4.1). The results of the tests were used to establish
' allowable capacities for supports utilizing UNISTRUT inembers. These L
' allowable load capacities were used in design validation.
B.- The' conduit support test procedures, test set up and results were reviewed and conduit- clamp and support capacities were developed as , follows:. '
.The conduit support test procedures,-test set up and test results were reviewed by Ebasco. Only those supports which adequately represented the support configurations at the CPSES site and not affected by imprgar test set up were accepted. Ebasco established allowable load cancities for those acceptable . supports from the
~ test results. For wpports bounded by the tests, specific load s ' capacities were determined analytically in accordance with the American Iron and Steel Institute (AISI) Code (Reference.4.4). All c
other conduit. supports utilizing UNISTRUT are being replaced.
' Conduit clamp. capacities for clamp types used in CPSES conduit and conduit supports were established by tests (References 4.2 and 4.3)
.and incorporated in the design validation procedure (Reference 4.6).
3.0 Ccrrective and Preventive Action No additional issues were identified during the review and resolution of this issue. A8-1
L SUBAPpENDIX A8 This' issue was determined to be reportable under the provisions of n) 10CFR50.55(e).- It ses reported as Significant Deficiency Analysis Report
- (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV l Electric to the NRC (Also see Subappendix B3).
3.1 ~ Corrective Action The test'results (Reference 4.1) for conduit supports utilizing UNISTRUT members were evaluated. Capacities for these conduit supports were established (References 4.8 and 4.9) based on the test data and these capacities were used in the design validation process (Reference 4.6). Conduit supports utilizing UNISTRUT members with unacceptable test results were identified and are being replaced. The conduit clamp allowable capacities were established by tests (References 4.2 and 4.3) and incorporated in the design validation procedure (Reference 4.6). 3.2 Preventive Action The design criteria identifying the allowable capacities including torsional loading for conduit supports constructed with UNISTRUT members and allowable capacities for conduit clamps have been included in the conduit and conduit support design validation documents (References 4.5 and 4.6). In addition, the criteria used for the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.7). O 4.0 RertReNCes 4.1 CCL Report No. A-678-85, " Seismic Qualification Test Report of Conduit Support Systems", Volume I and II, October 9,1985. 4.2 CCL Report No. A-699-85, " Conduit Clamp Test Report", Phase I, December 17, 1985. 4.3 CCL Report No. A-702-86, " Conduit Clamp Test Report", Phase II, April 7, 1986. 4.4 AISI, Cold-Formed Steel Design Manud,1983 Edition. 4.5. Drawing No. 2323-S-0910 design document, Sh. CA-la, Revision CP-01, April 27, 1987; Sh. CA-lb, Revision CP-01, April 30, 1987; Sh. CA-2a, Revision CP-01, April 30, 1987; Sh. CA-2b, Revision CP-01, April 30,1987; Sh. CA-8, Revision CP-01, April 30,1987; Sh. JA-1, Revision CP-01, April 30, 1987; Sh. JA-2, Revision CP-01, April 30, 1987; Sh. JA-3a, Revision CP-01, June 12, 1987; and Sh. JA-3b, Revision CP-01, April 30, 1987. 4.6 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit System", Revision 6, dated October 30, 1987. O A8-2
k p< ' C < SU8 APPENDIX A8
~ ,Hy - 4.7' Comanche Peak Steam Electric Station Design' Basis Document
"'l DBD-CS-090, " Conduit and Conduit Support Design Train A, B and Greater Than 2 Inch Diameter. Train C Conduits", Revision 1.
4.8 Ebasco' Calculation No. TNE-CS-CA-CA-la, " Design of Conduit Support Capacities for CA-la and CA-2a type UNISTRUT Supports," Revision 2, p October 5, 1985, p 4.9 .TNE-CS-CA-CA-2b, " Design of Conduit Support Capacities for CA-2b type UNISTRUT Supports", Revision 1, dated October 16, 1987.
.Y I l E
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.SUBAPPENDIX'A9-e-
IMPROPER USE OF CATALOG COMPONENTS (CYGNA ISSUE NO. 9)
- f, ,
21.0l Definition of the Issue-i The' issue was that'American Institute of Steel Construction (AISC) derived , Aallowables 'were used in the. original design process for the 'UNISTRUT members. l
< lThese AISC allowables are not always conservative for UNISTRUT members. -In i j addition,.the.following catalog components were used in' ways not recommended by
~
.the Vendors:. ,
UNISTRUT brackets'and: plate connectors' used in,UNISTRUT supports ' SUPERSTRUT;and.UNISTRUT. clamps' l Nelson Studs: f 4
~ Hilti Kwik Bolts (HKBs) and Hilti Super Kwik Bolts (HSKBs) , 'm
- Richmond. Inserts 1 2.0 < Issue Resolution 1 -'-
AISC' derived allowables were not used'in design validation of UNISTRUT-supports. UNISTRUT components' including plate connections (Reference 4.1) used
' in conduit supports (See Subappendix A8) have been validated by testing in accordance with the'American Iron and Steel Institute (AISI) Code (Reference
'4.2)' Support capacit.ies were established from test. data (Reference 4.5) and
. utilized during,the design validation.(Reference 4.8).
W U UNISTRUT! brackets:are no longer used, since conduit support' types CST-3, CSM-6b and: CST-17. which include UNISTRUT brackets have been replaced (Reference 4.12) '. SUPERSTRUT and UNISTRUT clamps and Nelson Studs were tested as a single clamp assembly'(References 4.3 and 4.4). 'The conduit clamp capacities have
.been incorporated in the design procedure (Reference 4.7).
' Nels$n Studs used in applications other than with clamps were validated as
'~
threaded-fasteners-in accordance'with the American Institute of Steel Construction (AISC) Manual (Reference 4.10) as confirmed by vendor (Reference 4.9).
- Allowable. anchorage capacities ~for Hilti Super Kwik Bolts (HSKBs), Hilti Kwik Bolts (HKBs), and Richmond Inserts have been established from test data and
, : incorporated-in the design validation procedures (References 4.6 and 4.7).
' All catalog components-are utilized in CPSES conduit supports either in a manner intended by the vendors or in a manner validated as acceptable by tests.
.3.0 ' Corrective and Preventive Action No additional ' issues were identified during the review and resolution of this issue.
s A9-1 ' 1
a f
, . l-SUBAPPENDIX A9 w
~
lThisLissue wasLdetermined to be reportable under the provisions of. 10CFR50.55(e). :It.was reported as Significant Deficiency Analysis Report -i
+.. -(SDAR) CP-85-34 in -letter number TXX-6047, dated October 21, 1986 from TV- )
Electric to the NRC (Also.see Subappendix B3). i l 3.1 Corrective Action. . The:DrawingLNo. 2323-S-0910 design document.was revised to eliminate supports containing catalog. components which were not' validated by tests. The allowable capacities: for' catalog components used 'in the ' conduit support installations
'have been established based on vendor data or extensive test programs. These
. capacities have.been incorporated in the design validated drawings-(Reference
,,-4.8):and: procedure (Reference 4.7) and utilized in the conduit support; design
. validation. process..
~
3.2 Preventive Action
.The design drawings.(Reference 4.8) incorporate the support capacities and the des i gn ; val i dati on . procedure (Reference 4. 7 ) ; i incorporates ' the all owabl e
- capacities of catalog components 'to be' utilized in the. design' validation of 1 . conduit supports. In addition, the criteria used for the design validation of
- conduit'and conduit supports have been documented in the Design Basis Document
-(DBD) (Reference 4.11).
4.0 REFERENCES
4.1 J UNISTRUT General- Engineering Catalog No. 9.
^
4.2 AISI, Cold-Formed Steel Design Nanual,1983 Edition. 4.3 CCL Report No. A-699-85, " Conduit Clamp Test Report", Phase I, December- 17,'1985. 4.4 CCL Report No. A-702-86, " Conduit Clamp Test Report", Phase II, April 7, 1985.
'4.5 CCL Report No. A-678-85, " Seismic Qualification Test Report of Conduit Support Systems", Volume I and II, October 9, 1985.
4.6 : TU Electric Specification No. 2323-SS-30, Structural Embedments, Revision 2, dated June 13, 1986.
-4.7 ~Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic
? Category I. Electrical Conduit System", Revision 6, dated October 30, L 1987. 48 Drawing No. 2323-S-0910 design document, Sh. CA-la, Revision CP-01, Apri1~27, 1987; Sh. CA-lb, Revision CP-01, April 30, 1987; Sh. CA-2a, Revision CP-01, April 30, 1987; Sh. CA-2b, Revision CP-01, 4 April 30, 1987; Sh. CA-8, Revision CP-01, April 30, 1987; Sh. JA-1, Revision CP-01, April 30, 1987; Sh. JA-2, Revision CP-01, April 30, 1, . 1987; Sh. JA-3a, Revision CP-01, June 12, 1987; and Sh. JA-3b,
? .- Revision CP-01, April 30, 1987.
A9-2
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" - SUBAPPENDIX'A9, k(
7[)J -4.9 TRW Letter..to H.S.Yu dated Mayl20, 1987. 4.10 AISC Manual lof SteelcConstruction, 7th Edition Lincluding Supplements-
- No. 1,-2 and-3. 4
~
l 4'.11 Comanche Peak Steam Electric Station Design Basis Document, E_ 080-CS-090 " Conduit and Conduit Support Design. Train A, B and 'to - Greater-Than-2 Inch ~ Diameter Train C Conduits," Revision 1. l c
;4.12 Drawing-No.12323-S-0910 design document, Sh.G-9b Revision CP-01, EJune 8, 1987, Sh. G-9g, Revision CP-01, June 8, 1987, and Sh.G-9m, Revision CP-01, June 8, 1987.
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-w L' SUBAPPENDIX A10 i
; iANCHOR BOLTS (CYGNA ISSUE NO. 10)
;1.07 Definition 'of the Issue The.' original; design' of the conduit-support anchorages may not have considered
- the reduction in support capacity attributed to bolt-substitutions and
- additional: load effects. -Specifically- .
s
?A., The issue wasithat prying action on anchor bolt tension was not considered. consistently and when considered there was no technical ,
P ~ justification of the methodology. l P
; 8L .
The issue was:that.the' design.of concrete connections for conduit support
. CST-17? Type 17, did 'not consider the additional moment. induced in the
' anchor bolt due .to shear. force- applied above the concrete surface.
C. ;The , issue was'that outrigger Hilti Kwik Bolts (HKBs) for CA-2a supports were assumed'not to take any load.. However some load may be imposed due
; te conduit loads ~and assembly of the support. The_Hilti Kwik Bolts
.-(HKBs)_ may not. be adequate .in resisting these loads since the design drawing did not require evaluation of separation distances between HKBs
'in:the outriggers-and'any other bolts.
.D. The issue was that the original Drawing No. 2323-S-0910 design document
. ... allowed the substitution of Richmond Inserts for Hilti Kwik Bolts 4
(HKBs). - This! substitution may result in lower bolt / insert capacities. l2.0 Issue Resolution A. ' All' conduit supports have been design validated in accordance with the
; design validation procedures'-(References.4.2, 4.3 and 4.5) which considered the: prying action effects on support components including the tension in the anchor bolts. The' prying action factors incorporated in Reference'4.2 were developed in engineering studies (Reference 4.1). The prying action factors on junction box supports are included in Reference 4.9.
, .B. CST-17, Type 17, conduit supports are either being replaced or eliminated (Reference 4.11), therefore, resolving this issue.
'C. The CA-2a. type UNISTRUT conduit support was tested (Reference 4.6)
' without.Hilti. Kwik Bolts (HKBs) on the outriggers. Therefore, it was demonstrated that HKBs on the outriggers are not required to achieve the
. required support capacity (Reference 4.4 and 4.6). There is no effect on the. support capacity due to separation distance between the outrigger '
HKBs and the support' main member HKBs since the separation distance between them is equal to or greater than that required in the design validation ~ procedures (References 4.2 and 4.3). The validation of other 4
. supports adjacent to CA-Pa type supports will be performed as part of the Post Construction Hardware Validation Program (PCHVP).
50 e A10-1 ______1:-____ . .
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- s. !
SUBAPPENDIX A10
~
> ?N , ; D. J .The Drawing No. 2323 S-0910 design document (Reference 4.8) was revised U such'that substitution of Richmond Inserts for Hilti Kwik Bolts. (HKBs) is
.noilonger' permitted... An engineering walkdown (Reference 4.10)' identified those conduit supports using Richmond Inserts. -Anchorages affected by the Richmond Insert' substitution were design validated in accordar.ce with the" design validation procedures (References 4.2,and 4.3).
3;0 Corrective and Preventive Action '
~
~.No ' additional issuest were identified during the review and resolution of this f
, Lissue. This! issue was determined to be reportable under the provisions of r
~10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TU
' Electric to the NRC (Also see' Subappendix B3).-
v: . 3.1 ~ Corrective Action
,' Conduit and junction box supports have been design validated for prying action effects in accordance with design validation procedures (References 4.2, 4.3
- and'4.5). Conduit supports where Richmond Inserts were substituted for Hilti
' Kwik Bolts (HKBs) have been identified and were design validated in accordance -
'with design validation procedures.(References 4.2 and 4.3). Other supports
- s Jadjacent to CA-2a supports will be validated as part of the Post Construction
- Hardware Validation Program (PCHVP). The Unistrut support tests were performed
'n- 'without Hilti Kwik Bolts (HKBs) in the outrigger; therefore, the capacity of u the CA-2a is not affected by the presence of the HKB on the outrigger. Also, CST-17, Type-17, supports were replaced or eliminated.
3.2 Preventive Action f
.The' design validation procedures-(References 4.2, 4.3 'and 4.5) specify criteria for prying action.and design drawings-no longer permit substitution of Richmond
-Inserts'for Hilti Kwik Bolts (HKBs) (Reference 4.8) or. use of CST-17, Type 17, ;
supports., In addition,: the criteria used for the design validation of conduit and conduit supports'have been documented in the Design Basis Document (DBD)
-(Reference 4.7).
)
1 4 O - A10-2 l
7 M' > >
.4]
SUBAPPENDIX A10 N : y 4.0 N References 4.1~ Ebasco Comanche Peak SES Cable Tray Hanger Volume I, Book 3, Prying
-g' faction, Revision.1,-April 24, 1986.
, 4.2 ' Ebasco Procedure. No. SAG.CP29, " Unit 1 General Instructions for Design-Verification of Electrical Conduit and Box ~ Supports",
Revision 4, dated October 12, 1987. _4.3 Ebasco Procedure No.-SAG.CPIO, " Unit 1-Design Criteria for' Seismic
. Category I Electrical Conduit System", Revision 6, dated October 30,
- 1987.
'4.4 ~ THE-CS-CA-CA-la, " Design of Conduit Support Capacities for CA-la and Ca-2a Type UNISTRUT Supports", Revision 2, October 5, 1987.
14.5 :Ebasco Procedure No. SAG.CP17, " Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System," Revision 7,
-dated October 12, 1987.
4.6 CCL' Report-No. A-678-85, " Seismic Qualification Test Report of ' Conduit. Support Systems," Volume I and II,.0ctober 9,-1985. 1 4.7 Comanche Peak Steam Electric Station Design Basis Document, LDBD-CS-090, " Conduit and Conduit Support Design Train A, B, and Greater than Two Inch Diameter 1 rain C Conduits", Revision l1. A.-
, M L4.8 Drawing No. 2323-5-0910 design document, Sh.G-4a, Revision CP-01, March 31, 1987.
~
4.91 Ebasco Calculation Book, CP-JB-27, Revision 2, dated October 31,- 1987. 4.-10 CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways
. for. Unit 1 Installation in Unit 1 and Common Areas", Revision 2, dated August.14, 1987.
4.11 Drawing No. 2323-S-0910 design document, Sh.G-9m, Revision CP-01, June 8, 1987. W
- o A10-3 c-u-___=_--_ - - - - - . _ _ _ - . _ a *
'SUBAPPENDIX'All ,y v- -- LONGITUDINAL LOADS ON TRANSVERSE SUPPORTS (CYGNA ISSUE NO. 11) )
L F"O
'il.0
~
Definitten of the Issue
<The issue was that there was no technical justification for not considering the longitudinal-. loads in the design of transverse. supports.
2.0 ~ Issue Resolution H During design validation,Ldesign modifications have been developed to replace or modify transverse conduit ' supports to be multi-directional type supports. Section 1.0 of Reference 4.1 stipulates-that' conduit' supports be design validated as multi-directional type. 3.0' Corrective and Preventive Action ' No' additional issues were: identified during the review and resolution of this issue. Thisl issue was' determined to be reportable under the provisions of < 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the.NRC-(Also see Subappendix B3). 3.1 . Corrective Action j - Design modifications have been developed to replace or modify transverse d-. conduit supports to be multi-directional type suppor.ts in accordance with the
' design validation procedure (Reference 4.1).
3.2 ~ Preventive Action: The design validhtion procedure (Reference 4.1) requires supports to be of the
-multi-directional type. The Drawing No.-2323-S-0910 design document (Reference 4.2) was revisea io exclude the transverse conduit supports. In addition, the criteria used for the design validation of conduit and conduit supports have
, been documented.'in the Design Basis Document (DBD) (Reference 4.3).
4.0 References 4.1 Ebasco Procedure No. SAG.CP10. " Unit 1 Design Criteria for Seismic ry I Electrical Conduit System," Revision 6, dated October 30,
. My ,
4.2 - DraHag No. 2323-S-0910 design document, Sh. G-9m, Revision CP-01, June 8, 1987. 4.3 Comanche Peak Steam Electric Station Unit Design Basis Document,
+ DBD-CS-090, " Conduit and Conduit Support Design Train A, B, and Greater than Two Inch Diameter Train C Conduits," Revision 1.
O A11-1 _ _ _ _ - _ _ _ i '
W ;*% . l SUBAPpENDIX A12' h g-y 'HILTI KWIK-BOLT SUBSTITUTIONS (CYGNA ISSUE NO. 12) 110. Definition of the Issue. Thi issue was that there was.no technical justification for the substitution of as-designed Hilti; Kwik Bolt (HKB) and'Hilti Super Kwik Bolt (HKB) sizes with r ;those of.a larger size.as was allowed by the. original Drawing No. 2323-S-0910
- design document. ,
k 1: , ,I 2.0L Issue Resolution lT 'The' Drawing No.'2323-S-0910 design document (Reference 4.2) was. revised _such
'that these bolt'substitutionsLare no longer. permitted. An. engineering.walkdown
,(Reference -4.3) ' identified those conduit supports where Hilti' Kwik. Bolts (HKBs)
'and Hilti. Super Kwik Bolts (HSKBs)'were substituted. ~ Anchorages affected by-
'the HKB and HSKB substitution were design validated in accordance with the
' design' validation procedure (Reference.4.1).
3.0: Corrective and Preventive Action No; additional 11ssues 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 in letter number TXX-6047, dated 0ctober 21, 1986 from TU fc ; -Electric to'the'NRC (Also see Subappendix B3).
d 4 3.1 Corrective Action'
,The design drawing.(Reference 4.2) was' revised'such that'Hilti Kwik Bolt (HKB) and Hilti Super. Kwik Bolt (HSKB) substitutions are no longer permitted. An engineering walkdown (Reference 4.3) was performed and those supports where
, bolt substitutions occurred were identified. These supports were then design validated'in accordance with the design validation procedure (Reference 4.1) on a case-by-case basis for the as-built condition.
3.2 Preventive' Action The design drawings.(Reference 4.2) were revised such that Hilti Kwik Bolt
-(HKB) and Hilti Super-Kwik Bolt (HSKB) substitution is no longer permitted.
- 4.0' Refereapes 4.1 o Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit System," Revision 6, dated October 30, 1987..
O A12-1
-r'
g , SUBAPPENDIX A12-l/'V 4.2 . Drawing No. 2323-S-0910 design document, Sh. G-4a, Revision CP-01, A J; -March 31,.1987. D'
.,. 4.3 CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways for. Unit 1 Installations in Unit 1 and Common Areas," Revision 2, !
2,.
. dated August 14, 1987. !
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, w I sSUBAPPENDIX A13
% t V ! --SUBSTITUTION OF. SMALLER CONDUITS ON
' ((] ' ,
CA-TYPE SUPPORTS (CYGNA' ISSUE NO. 13)' l j g- 1.'0 - l Definittim of the' Issue ! b 'CA-type's_upport drawingsiallowed the substitution of smaller conduits for-larger conduits on a conduit! support on a one for one basis. The CA-type
- supports:for~2' inch diameter and larger stze conduits were designed for Zero: l
- Period' Accelerations. (ZPA) and the smaller size conduits with flexible spans '
l were. designed.for: peak' seismic. accelerations.. The. issue was that the
*< L substitution'with smaller' size' conduit. may , result in larger loads on CA-type - r
~
- supports. ;
b- '2 0,
. Issue Resolution-c; o 3The' design: validation procedures for conduit and' conduit supports (References (
l4.1: through 4.3)Jrequire the use'of. thel same seismic accelerations to design M. ? validate the CA-type supports-regardless of conduit size. Therefore, the < P- substitution of smaller conduit sizes for larger conduit sizes is acceptable. s . 3.0:. Corrective and Preventiy_qt, Action. h .NoL additional issues were identified during-the review and' resolution of this % g Lissue. V. This issue was determined to be reportable under the provisions of h: ~
'10CFR50.55(e). 'It was reported as Significant Deficiency Analysis Report
.(SDAR):CP-85-34 in letter number TXX-6047,' dated October 21, 1986 from TV Electric to the NRC.(Also see Subappendix B3). '
3.1 Corrective Action The CA-type ' supports' have been design validated using the same seismic
- accelerations regardless of conduit sizes as-required by design validation
- , ' procedures-(References 4.1'through 4.3).. ;
3.2: Preventive Action The design validation procedures (References 4.1 through '4.3) require the same
, seismic accelerations: to be utilized for CA-type support design validation +
regardless of conduit" sizes. In addition, the criteria used for design i __ validation oftconduit and conduit supports have been documented in the Design Basis Doc (080)~(Reference 4.4). 4.0L REFEREEES 1 4.1 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic e Category I Electrical Conduit System," Revision 6, dated October 30,
- 1987.
A13-1
----*_A.Aa-_- _A-_-_m_m._.22_ _ . ___.. o
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$:s '
lX - . . [) ~SUBAPPENDIX A13 3' !4.2 Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for ' +}"! H-
-w~') . Seismic Category I Electrical Conduit Isometric Validation,"
Revision 1, dated October 16, 1987. 4.3 - Ebasco Procedure.No. SAG.CP29, " Unit 1 General Instructions for. V Design Verification of Electrical Conduit and Box Supports," Revision.4, dated October. 12, 1987.
- c.
. - 4.4. Comanche Peak' Steam Electric Station Design Basis Document,
'DBD-CS-090, " Conduit and Conduit Support Design Train _A, B and Greater than Two. Inch Diameter. Train C' Conduits," Revision 1.
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1 h l~ - SUBAPPENDIX A14 j jq. USE OF CA-TYPE SUPPORTS IN LS SPANS (CYGNA ISSUE NO. 14) ' i") 1.0 Definition of'the Issue-CA-type supports supporting two inch diameter and larger conduits were' designed )
.for Zero Period. Accelerations (ZPA) when used with the rigid conduit spans I
, .(LA). The issue was that'when CA-type supports are used in a conduit
. configuration containing'the non-rigid conduit spans (LS), the seismic ;
accelerations on'the CA-type supports can exceed Zero Period Acceleration
'(ZPA).
2.0 -Issue Resolution The design validation procedure for conduit and conduit supports (Reference 4.1)' requires that rigid conduit spans -(LA) be no longer used. CA-type supports were design validated based on the conservative non-rigid conduit span (LS) seismic accelerations (Reference 4.1).
"3.0. Corrective and Preventive Action. !
No additional issues were identified during the review and resolution of this issue. ThisL issue was determined to be reportable under the provisions of i 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV
, Electric to the NRC-(Also see Subappendix B3).
3 .1 - Corrective-Action
'The CA-type supports have been design validated utilizing non-rigid conduit span (LS) seismic accelerations, as required in Reference 4.1.
3.2 Preventive Action
- The' design validation procedure (Reference 4.1) requires the use of non-rigid conduit span (LS) seismic accelerations to design validate the CA-type supports. In addition, the criteria used for the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD)
(Reference 4.2). 4.0 References 4.1 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit System," Revision 6, dated October 30, 1987. 4.2 Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-90, " Conduit and Conduit Support Design Train A, B and Greater than Two Inch Diameter Train C Conduits," Revision 1. n (J. A14-1
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R ; 'SUBAPPENDIX'A15 $e w x' s
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. STRESSES IN CABLE TRAYS DUE TO ATTACHED u
g CONDUIT SUPPORTS-(CYGNA ISSUE-NO. 15) g,
\1.0 ' Definition'of'the Issue-Drawing No. 2323-S-0910 ' design document f(Reference 4.1) ' allows conduits to be i a
' attached directly to.a cable tray. .The issue was.that the cable tray may not,
.be' capable.ofisupporting,the additionalfconduit' loads. In' addition, the rigid' conduit .was designed for;Zero Period Acceleration (ZPA); loads and the flexible e
conduit wasfdesigned for peak' acceleration from Amplified Response Spectra j
, '(ARS). Since the cable-tray may.be flexible, the. use of Zero Period.
t Acceleration (ZPA) for the rigid conduit may not be justifiable. As.a minimum, [$ < , ..the- peak acceleration from tha Amplified Response Spectra (ARS)'should have
% >cbeen used.-- !
2;0) - Issue Resolution j
~
Theldesign: validation procedure foriconduit and conduit supports (Reference j 4;2) requires:that the connection between the rigid conduit and the cable tray (~ "be evaluated based oncl.5 times; peak ~ accelerations from the' Amplified Response l Spectral (ARS)',: as' rec 0mmended by. Regulatory Guide 1.100 (Reference 4.5) in -
! combination.with deadweight for'both the rigid and flexible conduit with p m< - maximum > flexible. conduittiengths allowed in Reference; 4.1. The design 1 i validation of. the ' cable tray with conduit attached was addressed in the '
. Subappendix. A32 ofjthe Cable Tray and Cable Tray Hangers Project Status Report v
?(Reference 4.3).
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-3.0<
Corrective and Preventive Action 1 1 s. j
;q No additional issues were identified during the review and. resolution of this Iissue.
- This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was. reported -as Significant Deficiency Analysis Report X :(SDAR)-CP-85-34..in' letter number TXX-6047, dated October 21,.1986 from TU
' Electric 1to the NRC-(Also see Subappendix B3).
f3.1' Corrective Action-Connections 2of the rigid conduit to the cable tray have been design validated for the.1.5 times peak accelerations from ARS for the maximum weight of the
, rigid plus' flexible conduits in accordance with the design' validation procedure u .(Reference 4.2)..
'3.2i ' Preventive Action 1 i
E .. fThe design criteria required for. the validation of connections between the Y rigidLeonduit and cable tray were included in the design validation procedure
*. . "(Reference 4.2). In addition, the criteria used for the design validation of
. conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.4).
O A15-1
'0
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![ 3 3 j _ ~ C ; .. I SUBAPPENDIX A15 p 4 0- . References p :7 . '-'4 . [ GQ) J i4.1 Drawing No. 2323-S-0910 design document, Sh. CSD-16, Revision CP-01, L April . 9, 1987. p l 4.2 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic ,. ~ Category I Electrical Conduit System," Revision 6, October 30, 1987. p., 4.3 . Comanche Peak Steam Electric Station, Project Status Report, " Cable L. Tray.and Cable < Tray Hangers", Revision 0. 4.4 Comanche Peak Steam Electric' Station Design Basis Document, DBD-CS-090,." Conduit and conduit Support Design Train A, B and Greater.than Two Inch Train C Conduits," Revision 1. p 4.5 US NRC Regulatory Guide 1.100, " Seismic Qualification of Electric . Equipment for Nuclear Power Plants", Revision 1, August 1977. j-h [ f
-7 l
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I
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A15-2 j l l I
, . . . - _ _ _ _ _ __ --- ---- - -- _ 1
%43& A> ' g;4 . SUBAPpENDIX'A16' F ' INCREASES IN ALLOWABLE SPAN' LENGTHS (CYGNA ISSUE NO. 16) I p 1.0. Defi$ition'oftheIssue < TheLissue was: that insufficient technical < justification- existed for the conduit rigid . span (LA)--lengths . allowed in the original- Drawing 2323-S-0910 design L ': document; 1The justification was insufficient because. conduit stresses had not L , .been considered. 4 ,
/210 Issue Resolution:
g' Design validation: procedures for conduit-and conduit supports:(References 4.2
- and 4.3)< require.that conduit stresses.be considered as part of the design ivalidationLprocess.: Drawing No. 2323-S-0910 design document.was also revised toldelete:condui_t rigid span.(LA) lengths.
m> ,
- 3.0: Corrective and Preventive' Action.
;NoladditionalLissues. wereLidentified during the review and resolution of this-issue.-
R" :This; issue'wasi determined to beLreportable uhde'r.the provisions off ". .10CFR50.55(e). It was ' reported as-Significant Deficiency Analysis Report i(SDAR);CP-85-34:in: letter. number TXX-6047,-dated Octooer 21, 1986 from TU (Electric to the'NRC'(Alsolsee Subappendix B3).
~
-3.li ,forrective Action
* .. 'ConduitLstresses have been determined as part of the conduit and conduit-n, ; support design validation process.
13.2 = M ventive Action Drawing.No. 2323-S-0910' design document (Reference 4.1) was revised to delete conduit' rigid span ~-(LA)11engths. Design validation procedures (References 4.2 andL4.3)l. require evaluation for conduit stresses. In addition, the design criteria used in the' design validation of conduit and conduit supports have been" documented in the Design' Basis' Document (DBD) (Reference 4.4).
-4.0' Preferences i4.11DrawingNo.2323-S-0910designdocument,Sh.G-9c,RevisionCP-02,
- dated October 29, 1987.- '
'4.2 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic Category I: Electric Conduit System," Revision 6, dated October 30,
, 1987.-
q;n j 4.3 Ebasco Procedure No. SAG.CP20, " Unit 1 Technical Guidelines for l System Analysis of Conduit Span Configurations," Revision 4, dated l October 13,- 1987. i LQ A16-1 i l
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'SUBAPPENDIX A16:
[lI g . .. e
- 4.4 : Comanche ' Peak Steam Electric. Station Design Basis'. Document,
>f^]'l 080-C5 090, " Conduit and Conduit Support Design Train A, B a'nd.
P -- Greater than Two-Inch Diameter Train.C Conduits," Revision 1. I ()) .., h 1 1~ 'I k "hi 9 . e l
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4 LSUBAhPENDIXA17- ,
' .-_--' : SUBSTITUTION OF NEXT HEAVIER
{/7 ' STRUCTURAL MEMBER (CYGNA' ISSUE NO. 17):
, A )[ ,
M? 1.0.. ' Definition "of the Issue , 6 Orignal Drawing' No. 2323-S-0910' design document' allowed thg substitution of 4'~
-the conduit support structural member with the next heavier structural.
member to that 'sh'own onithe drawing. - The issue was that the effect of the L
, ) increased support: selff weight was. not adequately considered in the design -(see-2 LSubappendix A7).;
- 2.0; Issue' Resolution J
. Engineering'walkdown~ procedure-(Reference 4.1) includes the requirement for the c nidentificationLof the structural members.of the conduit' supports.: .As-built 1 '
information -includes the member sizes for all open structural shapes such as.
- angles,? channel 1and I-beams. For. tube steel members with closed ends, the size iJ of the: tube is recordedt ,The. design. validation of.these members considers both x ithe' thickness'of the' tube steel member shown'on the-design drawing for the size 3 recorded and.the' thickness of the next. heavier tee steel of.the same size.
- Engineering. analyses were~ performed byrEbasco-(References 4.6 and 4.7) to-
- establish' criteria for. conduit support design validation which includes the Jeffect<of:theisubstitution;of the next heavier member size. This criteria was
' incorporated into.the' design validation procedures-(References 4.4,14.5, and 14.9)L and utilized in"the design validation of conduit and conduit supports.
3.0; Corrective and' Preventive Action f ~.. A./ No 'additionallissues were identified during the review and resolution of this
< , -issue.-
- This: issue wasTdetermined to.be reportable under the provisions of 10CFR50.55(e). It'was reported as Significant Deficiency Analysis Report
.(SDAR) CP-85-34 in letter. number TXX-6047,: dated October 21, 1986 from TV
( Electric;to the NRC (Also see Subappendix B3).. ( ~ 3.1 Corrective Actioni
- Design validation procedures (References 4.4, 4.5, and 4.9) include the design i n
criteria for design validation of supports where heavier member substitutions ! were made. 3, 1-1 For a given structural member, the AISC Manual-(Reference 4.2) provides dimensional, weight, and member design. properties. The ' next heavier member for a given size may be selected by referring to j
- Part'l of the AISC Manual. The next heavier member is defined as that structural: member whose overall shape and dimensions remain the
. same-but whose wall, web and/or flange thickness and corresponding I
. weight is the next greater member in the AISC manual than the structural member size shown on the design drawings.
{. A17-1
" ; y.47 . .; ,
- m 4
- 'SUBAPPENDIX A17-Id f3.2.LPreventive' Action IDrasingNo.2323-S-0910_designdocument(Reference.4.3)was,revisedsuchthat the
- note l allowing the substitution of next heavier structurai member was .
w deleted. ' Design validation procedures (References 4.4', 4.5, and '4.9) include
. design criteria for- the design validation of conduit supports 'with member
- substitution...In. addition,-the design criteria used for the design validation N lof. conduit and conduit supports.have been documented in' the Design Basis
. . Document'(DBD) (Reference.4.8).
"4.0: References
~41 LCPE-EBiFVM-CS-033, ." Design Control?of Electrical Conduit Raceways W. 3 . for Unit 1-Installation-in Unit 1 and Common Areas," Revision'2,
. dated August.14,'1987.
4.2 AISC Manual' of ? Steel Construction, 7th' Edition, incluoing Supplementsil, 2 and-3.. 4'.35 Drawing No. 2323-S-0910' design document, Sh. G-la, Revision CP 01, March 31, 1987. 4~4 Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for g
- Design Verification of Electrical Conduit and. Box Supports,"
= Revision'4,' dated October 12,,1987.
y' ~ L4.5 Ebasco .Procsdure.No'. SAG;CP25, " Unit 1 Technical Guidelines for / Seismic Category .I Electrical Conduit Isometric . Validation,"- R,
' Revision 1, dated October 16, 1987.
1 L T ~4.6lCalculationBookNo. Supt-0247,"SubstitutionofNextHeavier
.~
Structural Member for Unit No.1," Revision 0, dated July. 16, 1987. c/J[' 4.7J C$lculationBookNo. Span-1189,CYGNAIssueNo.17,"Substitutionof Next Heavier Structural Tube Member Size for Unit No. l'," Revision. O,' dated June 12, 1987. 4.8 Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit Support Design, Train A, B and l Greater.than Two Inch Train C Conduits," Revision 1. 4.9 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic
- Category I Electric Conduit System," Revision 6, Dated October 30, 1987. ;
LLO A17-2
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t LSUBAPPENDIX A18 r C y. <
; CLAMP USAGE- (CYGNA ISSUE' NO.18F
- f}~"
^ '
"1.01 ' Definition of the Issue
~
- Thefissue was that there was insufficient' engineering justification _ for the 3
- conduit clamps installed at CPSES with: holes _ reamed to accommodate larger !
bolts; the end. portion of the clamp ears modified by cutting; missing, modified or distorted washers and distortion present in the clamp. j 2.0 Issue =Reso1ution 4 Conduit 'and conduit- supports-were design validated utilizing clamp allowables
- which were established as~a result'of an extensive clamp testing program. This 4 clamp. test program was' conducted by Corporate Consulting and Development 1 Company,, Ltd. (CCL) -(References _4.1 and 4'.2). . Clamp assemblies . representing installed configurations were-tested for the' effects-of static and
. simultaneously applied'three directional cyclic loads. Test programs have
~
. considered theLeffects of oversized holes (reamed holes) for larger bolts;
' modified clamp ears; omitted, modified or distorted washers, and distorted r clamps. :The-allowable clamp capacities for various clamp assemblies were incorporated into the. design validation procedure (Reference 4'3). . i l
L 3'. 0; Corrective and Preventive Action a
~
LNo' additional issues were identified during the review and-resolution of this j issue. ; h' ;This issue was determined to be reportable'under the provisions.of 10CFR50.55(e)'. 'It,was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TU
' Electric to'.the NRC-(Also see Subappendix B3). ;
3.1 Corrective Action Clamp assemblies.were design validated in accordance with design validation procedure (Reference 4.3)- utilizing the clamp allowable capacities established from the test results, qq .3.2 Preventive Action The design validation procedures'(References 4.3 and 4.4) require the clamps to be design validated utilizing the clamp allowable capacities established by
. tests. Ebasco reviewed and identified revisions required to the installation i specifications' construction procedure and Quality Control (QC) inspection
. procedure ~ (References 4.6 and 4.7) to preclude unauthorized modifications to clamp and clamp assembly components. These revisions have been incorporated in
'the above procedures. In-addition, the design criteria used in the design
' validation of conduit and conduit supports have been documented in the Design ;
' Basis Document (DBD) (Reference 4.5). i
.O A18-1 1
__.__.m_-___._____m. _ . _ _ _ _ _ -_ . _ . _ _ . . _ _ . . _ _ _ . _ _ _ . _ . _ _ . . . _ _ _ ._ __._____.____-_.J
~
. g ..; SUBAPPENDIX A18 4.0 References
'7 1 1 l
4.1 CCL Report No. A-699-85, " Conduit Clamp Test Report, Phase I," J December 17, 1987. ) l 4.2 CCL Report No. A-702-86, " Conduit Clamp Test Report, Phase II," i April 7, 1986. j 4.3 Ebasco Procedure No. SAG.CP10, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit-System," Revision 6, dated October 30, l 1987. j 4.4 Ebasco Procedure No. SAG.CP.25, " Unit 1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric Validation, Revision 1, dated October 16, 1987. 4.5 Comanche Peak Steam Electric Station Design Basis Document, j DBD-CS-090, " Conduit and Conduit Support' Design Train A, B and ' Greater Than 2 inch Diameter Train C Conduits," Revision 1. i 4.6 NQA-3.09-2.03, " Conduit Support Field Inspection", Revision 1, September 24, 1987. ) 4.7 ECP-19, " Exposed Conduit / Junction Box and Hanger Fabrication and l
, Installation",. Revision 15, August 31, 1987.
(. O J l l l l 1 i I i i i i l l o V A18-2 i
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- SUBAPPENDIX ALS .a
. J DOCUMENTATION' DEVIATIONS BETWEEN INSPECTION REPORTS. l
,T. - , CMCs AND IN-FP DRAWINGS (CYGNA ISSUE NO. 19)-
% s ,.
1 " 30' ill0 ' Definit'ih of the Issue ; The? issue was'that information contained in the conduit support Inspection J '
> Reports:;(irs)ldid.not? always reflect all ~of the~ existing. design documents, or Lvb " , . exhibited inconsistencies with the information in the-existing documents. The i" , M issue?further was,that'the information contained in'the conduit support
#:w l Inspection Reports;(irs)ldid not always reflect the' installed configurations.
%' :2'.0jJIEsueResolution:
. Conduit and conduit supports', including those with fire protection (Thermolag)
, have'. bean' as-built;as' part of the engineering walkdown (Reference 4.1), and b @. ,1.
F - # ,;/(Referencesi4.2,.4'.3 and 4.4) utilizing'as-built data.were design validated in accordance 3.0L Corrective'and Preventive Action 4 LNotadditional' issues were ' identified during the review and resolution of this
~
= issue.
, I This issue wasLdetermined to be reportable under the provisions of
;10CFR50.55(e). .. It was reported as Significant Deficiency Analysis Report (SDAR):CP.-85-34 inLletter number TXX-6047, dated October 21,J1986 from TU JN .
w. Electric to the NRC:(Also see Subappendix B3). )
'3.1' Corrective Action' i
Conduit and conduit. supports have been as-built by an engineering walkdown '
'(ReferenceL4.1) Land. design validated in accordance with the requirements of the designLvalidation procedures (References 4.2, through 4.4).
3.2 o Preventive Action-
'New and. modified conduit and conduit support engineering requirements are documented in isometric . drawings of the specific conduits with drawings for each -individual. condit' support in accordance with. the engineering procedures 4 < -(References 4.5, 4.6,'and 4.9). Installation is performed in strict accordance
- with the-drawings'as specified in the construction procedure (Reference 4.7).
- Subsequent.to-' installation the conduit and conduit supports are inspected by
< Quality: Control '(QC). for conformance. with the specific drawing for the conduit
.and conduit-supportsLin accordance with the QC inspection procedure (Reference 4.8). L The specific conduit and conduit support drawings and/or calculations are_. updated to reflect the' as-built conditions. This process assures that
.;g .. assumptions and models used in the design are consistent with the design
drawing _and the as-built configuration.
m j A19-1 f C :l : i _ -_. _. ______-___--___ _ ____--_ - _ _ -
7-l E SUBAPPENDIX'A19 P
, f.q ! 4.0; REFERENCES f' ')" : 4 ~.1 CPE-EB-FVM-CS-033', " Design Control of Electrical Conduit Raceways for Unit 1 Installations in Unit 1 and Common Areas," Revision 2, dated August 14, 1987-.
4.2 Ebasco Procedure No. SAG.CP 25, " Unit 1 Technical Guidelines for
. Seismic Category I Electrical Conduit Isometric Validation,"
, 1 Revision 1, dated October 16,'1987.
4.3 Ebasco Procedure No~. SAG.CP10, " Unit 1 Design Criteria for Seismic Category-I-- Electrical Conduit System," Revision 6, dated October 30, 1987.
.4.4 Ebasco Procedure No. SAG.CP17, " Unit 1 Design Criteria for Junction
.c -Boxes for Seismic Category I Electrical Conduit: System," Revision 7, dated October'12, 1987.
4.5 ' Ebasco Engineering Procedure E-7-CP, " Review / Approval of Drawings, Diagrams, and Lists - Nuclear Projects," Revision 7, dated October 26,-1987.- 4.6 Ebasco. Engineering Procedure E-30, " Preparation of Calculations," y .. Revision 4, dated February 20, 1983. 4.7 ECP-19L" Exposed Conduit / Junction Box and Hanger Fabrication and
,. y Installation", Revision 15, Ausgust 31, 1987.
4.8 NQA-3.09-2.03 " Conduit Support Field Inspection", Revision 1, September 24, 1987.- l4.9 ~CPE-EB-FVM-CS-056, " Design Control and As-Built Data Collection of Electrical Conduit Raceways in Unit I and Common Areas," Revision 1, dated September 9, 1987. f i 4 LO A19-2 _ ---- _ _~ _
h , i' SUBAPPENDIX A20 m,y NELSON STUDS (CYGNA' ISSUE N0.20) ) u.) 1.0 Definition of the' Issue i
'The issue.was that-insufficient technical justification was provided for the Nelson stud allowable loads and shim plate configurations in conduit clamp assemblies. J 2.0 Issue Resolution L Allowable capacities for the conduit clamp assemblies utilizing Nelson studs were established based on the results of an extensive test program (References
'4.1 and 4.2)'. The design validation process utilized these allowable capacities (Reference 4.3) for the design validation of conduit and conduit
! supports. Loads calculated at the clamp assemblies as part of the design validation process do not exceed the allowables. Engineering studies were performed by Ebasco to establish adequacy of-the shim plate configurations (References 4.5 and 4.6). The studies showed that shim plate configurations utilized for conduit and conduit supports at CPSES are adequate. 3.0 Corrective and Preventive Action No additional issues were identified du .ng the review and resolution of this 73 issue. U This issue was determined to be reportable under the provisions of
-10CFR50.55(e). It was reported as Significant Deficiency Analysis Report
. (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TU
' Electric to the NRC-(Also see Subappendix B3).
3.1 Corrective Action Allowable capacities for the. clamp assemblies utilizing Nelson studs were determined by tests (Reference 4.1 and 4.2) These allowable clamp capacities were incorporated into the design validation procedure (Reference 4.3). The adequacy of the shim plate configuration utilized for the conduit and conduit supports at CPSES was confirmed by engineering -+udies performed by Ebasco. 3.2- Preventive Action The design validation procedure (Reference 4.3) includes allowable clamp
~ capacities utilized for the design validation of conduit and conduit supports.
In addition, the design criteria used in the design validation of conduit and conduit. supports have been documented in the Design Basis Document (DBD) (Reference 4.4). 0 . A20-1
SUBAPPENDIX A20 ! 1
((j
/~c ..
- 4. 0 . References 4.i CCL' Report No. A-699-85, " Conduit Clamp Test Report, Phase.I,"
1 -December. 17, 1985. 4.2 ' CCL Report No. A-702-86, " Conduit Clamp Test Report, Phase II," April.7, 1986. 4.3 Ebasco Procedure No. SAG.CP10,." Unit 1 Design Criteria for Seismic Category,I Electrical Conduit System," Revision 6, dated October 30, q 1987.
- 4.4 Comanche Peak Steam Electric. Station Design Bacis Document, D80-CS-090, " Conduit and Conduit Support Design Train A, B, and Greater than Two Inch Diameter Train C Conduits,"' Revision 1.
4.5 Ebasco Calculation Book No. Span 1191, Revision 0, April 16,1987.
, 4.6 Ebasco Calculation Book No.44, Revision 3, July 31,1987.
I: L .f . f. b ,? V 1 A20-2 1
^
i - - - - _
b SUBApPENDIX A21 r . . . fq . CONDUIT FIRE PROTECTION CALCULATIONS (CYGNA ISSUE NO. 21) W' v ) k 1' 0 . Definition of the Issue
. The. issue was that the original design used fire protection material (Thermolag) weights which were_ calculated based on configurations which were
'different<from installed configurations. In addition, original design
. calculations for these conduits with Thermolag did not, in all cases, accurately. utilize the capacities corresponding to the installed support .
configurations. 2.0' Issue Resolution. An engineering'walkdown was' performed to obtain as-built data, including installed Thermolag configurations, for the conduit and conduit supports with fire protection material- (Reference 4.1). As-built conduit ard conduit ' supports were design validated in accordance with design validation procedure (Reference 4.2).. 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 m 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report ' (j (SDAR) CP-85-42 in letter number TXX-6049, dated October 21, 1986 from TU Electric to the NRC. 3.1 Corrective Action As-built.information of Thermolag and support configuration for conduit and
. conduit supports were obtained by an engineering walkdown (Reference 4.1). The conduit and conduit supports were design validated utilizing design validation ,
procedure.(Reference 4.2). Required hardware modifications were identified, ! designed. and are being implemented. 3.2 Preventive Action The' design validation procedure (Reference 4.2) includes design criteria for the conduit and conduit supports with fire protection material (Thermolag). In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.3). n . A21-1 l
l e,. L i l' 4 SUBAPPENDIX A21 E 7; >
! 4 '. 0 . References n ,-) 1 4.1l CPE-EB-FVM-CS-033, " Design Control.of Electrical Conduit Raceways I for Unit l1 Installation in Unit I and Common Areas," Revision 2, ', '
dated August ~ 14, 1987. 4.2' Ebasco Procedure No.. SAG.CP25, " Unit 1 Technical Guidelines for r E Seismic Category I. Electrical Conduit Isometric Validation," .)
. Revision:1, dated October 16, 1987.
E 4.3. Comanche. Peak Steam Electric Station Design ~ Basis Document, 080-CS-090, " Conduit and Conduit Support Design, Train'A, B and f Greater than Two Inch Diameter Train C Conduits," Revision.1. ; L- , i: . i_ l I" l f' T l%) ' . < F![ < ( l
... 4 A21-2 l
l LLimm____._________________.__- _ k
d'.
.SUBAPPENDIX A22-N: ,
SPAN-INCREASE FOR FIRE PROTECTED SPANS (CYGNA ISSUE NO. 22) ; F L/: j 1
'1.0. : Definition' of the Issue' 1 iThe issue-was that insufficient justification was provided for the use of- a y
minimum' yield stress of 33,000 pounds per square inch (psi) for conduits, and ' Lfor the~ use of. conduit material yield stress values which vary with conduit
, size.:
-2.0 Issue Resolution -
LThe design validation procedure (Refence 4.1) requires that the design L validation of the conduit utilize allowable stress values based on a conduit l yield stress of 25,000 psi regardless of the conduit size. This yield stress-
- value is the lowest value.for any commercially available steel' used for conduits.
3.0 Corrective and Preventive Action R No additiona1Eissues were identified during the review and resolution of this-issue.. LThis-issue was determined to be reportable under the provisions of
, 10CFR50.55(e). 'It was. reported as Significant Deficiency Analysis Report (SDAR) CP-85-19 in letter number TXX-6046, dated October 21, 1986 from TU V
%- V Electric.to the NRC:(Also see Subappendix B1).
L, 3.1 Corrective Action Conduits, including those.with fire protection, have been design validated-utilizing allowable stress which does not vary with the conduit size and which e ;is based on-the lowest yield stress of any commercially available steel used
'for conduits.
F 3,2- Preventive Action The~ design validation procedures (Reference 4.1 and 4.2) require use of a conduit allowable stress which does not vary with size and which is based on the lowest yield stress for any commercially available steel used for conduits. In addition, the design criteria used in the design validation of conduit'and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.3).- I
. 1 A22-1 i
s
.js ,
SUBAPPENDIX A22
'.4.0~
References ' - l
^~'t - 4.1 Ebasco' Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic
' Category I Electrical Conduit System," Revision 6, dated October 30,
!i 1987. 1 L.- " 4.2 Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for 1
- Seismic Category I Electrical Conduit Isometric Validation," i Revision 1, dated October 16, 1987.
_4.3 7 Comanche Peak Steam Electric Station Design Basis Document, l DBD-CS-090, " Conduit and Conduit Support Train A, 8 and Greater than L Two ' Inch Diameter ~ Train C Conduits," Revision 1. e b. l' 'e
}
.' \J l A22-2 l
SUBApPENDIX A23 e p n- ' GROUTED PENETRATIONS'(CYGNA ISSUE N0, 23)
"hf 4 1.0 Definition of the Issue
. Conduit embedded in concrete walls and floors was considered to have multi-directional support- at the penetration. The issue was that no-justification'was provided..to assure the capability of the grouted penetration to carry the required loads..
p 1 2.0 I nue Resolution Design validation procedure (Reference 4.1) requires that the conduit penetration through concrete be evaluated to assure that it is capable of carrying required loads. If the conduit penetration is not capable of carrying the" load in any one direction, the design validation procedure requires that no b support in that direction be considered. Conduit and conduit supports were design validated utilizing this design criteria. 3.0 Corrective and Preventive Action i 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 es. !(SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TV p Q,. Electric to the NRC (Also'see Subappendix B3). 3.1 Corrective Action-Conduit and' conduit supports have been validated in accordance with the design L validation procedure (Reference 4.1) which requires that the conduit penetrations be evaluated to assure their capability to carry the required loads. 3.2 Preventive Action
. Design validation procedure (Reference 4.1) provides design criteria for grouted: conduit penetrations. In addition, the design criteria used in the i design validation of the conduit and conduit supports have been documented in j the Design Basis Document (DBD) (Reference 4.2). j i
)
i i i I i 1 O A23-1 I l l
W SUBAPPENDIX A23 {- 4.0' . References.
' 11 '
4.1 Ebasco Procedure No. SAG.CP10. " Unit 1 Design Criteria for. Seismic P ' Category 'I Electrical Conduit System," Revision 6, dated October 30, 1 b 1987.l j 4.2 Comanche' Peak Steam Electric Station Design Basis Document, . I DBD-CS-090,'" Conduit.and Conduit Support Design Train A, B and Greater than Two Inch Diameter Train C Conduits," Revision 1. I
- L g i
~
ai l (_~f r A23-2 I
- - - - _ - . . _ . J
SUBAPPENDIX A24 RIGIDITY OF CA-TYPE SUPPORTS (CYGNA ISSUE NO. 24) 1.0 Definition of the Issue i The original design assumed CA-type supports to be rigid (having support frequency equal to or greater than 33.0 Hz). The issue was that this assumption was not justified in design calculations. ! 2.0 Issue Resolution The design validation procedures (References 4.1 and 4.2) require that the l frequency of the CA-type supports be determined. The determined frequency is then used in the design validation of the conduit and conduit supports. 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B3). 3.1 Corrective Action '
-m I
Conduits with CA type supports have been design validated utilizing the CA-type
, ~ support frequencies in accordance with the design validation procedures (Reference 4.1 and 4.2).
3.2 Preventive Action The design criteria requiring the determination of CA-type support frequency have been incorporated into the design validation procedures (Reference 4.1 and 4.2). In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.3). 4.0 References 4.1 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic Category I Electrical Conduit System," Revision 6, dated October 30, 1987. 4.2 Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for Design Verification of Electrical Conduit and Box Supports," Revision 4, dated October 12, 1987. 4.3 Comanche Peak Steam Electric Station Design Basis Document, l DBD-CS-090, " Conduit and Conduit Support Design Train A, B and l Greater than Two Inch Diameter Train C Conduits," Revision 1.
)
l
/~ . 'J.
l A24-1 I i
SUBAPPENDIX A25 ENVELOPING CONFIGURATIONS FOR DESIGN (CYGNA ISSUE NO. 25) 1.0 Definition of the Issue The issue was that the original design calculations for some of the conduit ! supports did not consider the most critical support configurations. Maximum load eccentricities, installation tolerances, member substitutions, bolt substitutions, weight of support member components and overhangs as allowed by Drawing No. 2323-S-0910 design document were not included. 2.0 Issue Resolution The design validation procedures (References 4.1 through 4.4) require that all conduit supports be evaluated for all support configurations allowed by the Drawing No. 2323-S-0910 design document. This includes maximum load eccentricities, installation tolerances, member substitutions, bolt substitution, weight of support, member components and overhangs. 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TU
) Electric to the NRC (Also see Subappendix B3).
3.1 Corrective Action The conduit supports have been design validated utilizing all support configurations allowed by the Drawing No. 2323-S-0910 design document as required by the design validation procedures (References 4.1 through 4.4). 3.2 Preventive Action The design criteria requiring the consideration of all conduit support configurations allowed by the Drawing No. 2323-S-0910 design document have been included in the design validation procedures (References 4.1 through 4.4). In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.5). k , A25-1 1
m SUBAPPENDIX A25
.M . '4.0 References 4.1 'Ebasco Procedure No. SAG.CP10 " Unit 1 Design Criteria for Seismic
, Category I Electrical Conduit System," Revision 6, dated October 30,
.1987.
4.2- Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for Design Verification of Electrical Conduit and Box Supports," Revision 4,-dated October 12, 1987. 4.3 Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric Validation," Revision 1, dated October 16, 1987. 4.4 'Ebasco Procedure No. SAG.CP17 " Unit 1 Design Criteria for Junction Boxes.for Seismic Category I Electrical Conduit Systems," Revision
.7, dated October 1.2,.1987.
4.5 Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit Support Design Train A, B and Greater Than Two Inch Diameter Train C Conduits," Revision 1. lq tg l l ' v - A25-2 1 I
- - _ _ __ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - -_. - - _ _ - _ - _ - _ - _ - _ . _ _ _ _ - - _ _ - _ _ _. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - ___- _-____________ _ _ - A
y _ _ .- _ _ _ _ - SUBAPPENDIX A26 !! q DESIGN DRAWING' DISCREPANCIES (CYGNA ISSUE NO. 26) 1.0 Definition of the Issue j 4 The. issue was that'there were certain discrepancies or inconsistencies between l
-original Drawing No. 2323-S-0910 design document, and assumptions and. models i used in the design. calculations. In addition, information such as base plate '
size and clamp type was.not provided on some original design drawings.
'2.0 1ssue Resolution
'All the conduit and conduit support attributes required for design validation were identified. Examples of such attributes are: stud / bolt diameter, clamp
. type,. shim plate size, mounting' surface, dimensions, member size, anchor bolt
' size and type, and support cor. figuration. .The engineering walkdown procedure '
'(Reference 4.1) established the methods by which as-built field validation of these attributes was performed and documented. Conduit and conduit support .
drawings (Reference 4.5) were revised to incorporate the as-built l configurations obtained from the engineering walkdown. Design validation i utilized these drawings as input. Therefore the assumptions and models used in i the design validation are consistent with the design drawings. The conduit and j conduit supports were design validated in accordance with the design validation i procedures (References 4.2, 4.'3 and 4.4). 3.0. Corrective'and Preventive Action 74 No additional' issues were identified during the review and resolution of this n) . 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B3).
.3.1 Corrective Action An engineering walkdown was performed to provide as-built information for the conduit and conduit support attributes (Reference 4.1). Conduit and conduit support drawings (Reference 4.5) were revised to incorporate the as-built configurations obtained frem the engineering walkdown. Design validation of conduit and conduit supports have been performed in accordance with the design ,
validation procedures (References 4.2, 4.3 and 4.4), utilizing the as-built l data in Drawing No. 2323-S-0910 design document. ! 3.2 ' Preventive Action New and modified conduit and conduit supports are engineered and the engineering requirements are documented in isometric drawings of the specific conduits with drawings for each individual conduit support in accordance with the engineering procedures (Reference 4.6, 4.7, and 4.10). I h A26-1 4
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SUBAPpENDIX A26-m;
~ , ((I ,, .
, syvy < . .. .. M". Installation is performed in. strict accordance with the drawings as specified M1 :in construction procedure (Reference ~4.8). Subsequent to installation, the M conduit and conduit supports are inspected by Quality Control (QC) for-conformance with-the specific drawing for the conduit and conduit supports in
- Laccordance with the QC inspection procedure (Reference 4.9). The specific
; conduit and conduit. support drawings and/or calculations are updated to reflect g the.as-built conditions. This process- assures that . assumptions and models used-in:the" design are~ consistent with the design drawing and the as-built Configuration.- -
(4.03 References L4.1 CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways for Unit 1 Installation in Unit I and Common Areas," Revision 2, a > dated August 14,'1987. , 4.2' Ebasco Procedure No'. SAG.CP10, " Unit 1 Design Criteria for Seismic
' Category I Electrical. Conduit System,"' Revision 6, dated October 30,
'o 1987.~
,, , l4.3l Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for -
Seismic Category I Electrical Conduit Isometric Validation," cc Revision 1, dated October'16, 1987.
~4.4 Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for; c' - . Design Verification of Electrical. Conduit and Box Supports,"'
y < Revision 4 .' dated October 12, 1987. p 4.5 Drawing No.:2323-S-0910 design' document. 4.6 'Ebasco engineering procedure E-7-CP, " Review / Approval of Drawings, L Diagrams,' and Lists - Nuclear Projects," Revision 7, dated' October
'26,;1987.'
4.7. Ebasco Engineering Procedure E-30, " Preparation of Calculations," Revision 4, dated February 20, 1983. l-4.8 ECP-19, " Exposed Conduit / Junction Box and Hanger Fabrication and Installation", Revision 15, August 31, 1987.
'.4.9 NQA 3.09-2.03, " Conduit Support Field Inspection", Revision 1, September 24,11987.
4.10 CPE-EB-FVM-CS-056, " Design Control and As-Built Data Collection of 1 Electrical Conduit Raceways in Unit I and Common Areas," Revision 1,
~
p dated September 9, 1987. m s . [ A26-2 4
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- w. .c '3 SUBAPPENDIX A27-g.g ' '
WALKDOWN DISCREPANCIES (CYGNA ISSUE NO. 27) 4f a
,7-11'O Definition'of the' Issue .
9 The' issue was'that.someLdiscrepancies were noted between the installed clamps,
, . anchor; bolts and s'u pport members of conduit supports.'and corresponding design T : drawings._ In; addition, some commodity clearances'and anchor-. bolt spacings were m :not in accordance with-design criteria.
n y "2.0; Issue Resolutiorp q, T, TConduitisupporticlamps,. anchor bolts and support members were as-built as part t, '" Tof the engineering walkdown (Reference 4.1).. The as-built configurations were
' documented in the design drawings (Reference 4.5)~. These as-built
'N > configurations were used as. input:to the_ design validation process in
~
M , accordance with the design validation procedures (References 4.2, 4.3 and
'
- 4.4)h This assures consistency 1between design drawings and installed 4 configurations. Commodity clearances are'being validated to the design E criteria' by SWEC Mechanical during the Post Construction Hardware' Validation Program (PCHVP)'(Reference 4.10).; Anchor bolt spacings are being validated to
.the design criteria.by SWEC Civil / Structural during-the PCHVP (Reference 4.11).
3 '. '0 ; Corrective 'and Preventive Action' No' additional issues were identified during the review and resolution of this-
, 7 issue.-
; Q;,r4 .' >'
~
b~ LThis issue was' determined to be; reportable under the provisions of . 3 10CFR50.55(e). .It was reported as Significant' Deficiency Analysis Report (SDAR) CP-85-34 in letter number TXX-6047, dated October 21, 1986 from TU Electric to the NRC((Also see~Subappendix B3). 13.1 Corrective Action ', Conduit? and conduit-supports were.as-built'-(Reference 4.1). and design validated
, .in accordance with design validation procedures (References 4.2, 4.3 and 4.4).
= Commodity clearances.and anchor; bolt spacing are being validated to the design criteria as part-of the. Post. Construction Hardware Validation Program (PCHVP) m >
(References 4.10 and'4.11).
-3.2- Preventive Action L* New and modified conduit and conduit supports are engineered and the engineering requirements are ~ documented in isometric drawings of the specific conduits with drawings for each individual conduit support in accordance with
, the engineering procedures (References 4.6, 4.7, and 4.12). Installation is
,- ~ performed in strict-accordance with the drawings as specified in the-construction. procedure (Reference 4.8).
A27-1 h,, < l l
_7 i \ r SUBAPPENDIX A27 f3 Subsequent to installation, the conduit and conduit supports are inspected by O . Quality Control,(QC) for conformance with the specific drawing for conduit and
- conduit supports in accordance'with the QC inspection procedure (Reference 4.9). The specific conduit and conduit support drawings and/or calculations !
are updated to reflect the as-built conditions. This process assures that assumptions and,models used in the design are consistent with the design drawing and -the as-built; configuration. 4.0- References 4.1 CPE-EB-FVM-CS-033,. " Design Control of Electrical Conduit Raceways !
' for Unit 1 Installation in Unit I and Common Areas," Revision 2, J dated August 14, 1987.
4.2 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic' ' Category.I Electrical Conduit System," Revision 6, dated October 30, 1987. 4.3 Ebasco Procedure No. SAG.CP25, " Unit 1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric Validation," Revision 1, dated October 16, 1987. 4.4 Ebasco Procedure No. SAG.CP17 " Unit 1 Design Criteria for Junction Boxes for Seismic Category I Electrical Conduit System," Revision 7, dated October 12, 1987. 4.5 Drawing No,'2323-S-0910 design document. 4.6 - Ebasco Engineering Procedure E-7-CP, " Review / Approval of Drawings, Diagrams, and Lists - Nuclear Projects," Revision 7, dated October 26, 1987. 4.7 Ebasco Engineering Procedure E-30, " Preparation of Calculations," Revision 4, dated February 20, 1983. 4.8 ECP-19. " Exposed Conduit / Junction Box and Hanger Fabrication and Installation", Revision 15, August 31, 1987. 4.9 NQA-3.09-2.03, " Conduit Support Field Inspection", Revision 1, ;
- September 24, 1987.
4.10 TU Electric CPSES Unit I and Common, SWEC Mechanical Project Status ! Report, Revision 0, i 4.11 TU Electric CPSES Unit I and Common, SWEC Civil / Structural Project
. Status Report, Revision 0.
4.12 CPE-EB-FVM-CS-056, " Design Control and As-Built Data Collection of ~
, Electrical Conduit Raceways in Unit I and Common Areas," Revision 1, dated September 9, 1987.
I h ( A27-2 l " i Q. . _ _ _ _ - - - - _ _ _
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?SUBAPPENDIX A28
' YM <-
'. SYSTEMS' CONCEPT (CYGNA ISSUE NO. 28F 3
l1.0L Definition'of f d ,ugg: J The issue w'as; that for-two-colt mounted supports 1 subjected to eccentrically-
, f ' applied longitudinal loads,. the acceptability of the support was established by
@ s assuming that:the moment' generated by the eccentric load would not be resisted by .the support, but would be balanced by a' load couple equal .to' the-forces
'2; 7 generated:at the support of' interest and.the next. support in the conduit times the' distance between these supports. Possible-differences in support and'
; conduit stiffnesses were not considered..
;2 0: . Issue Resolution'.
*/ . Conduits with concrete surface. mounted supports have been design validated in--
,A ' '
faccordance with designivalidation procedures;(References 4.1 and 4.2) for the
'~e ffects of. moments .resulting from the eccentrically applied longitudinal loads y, f(See Subappendix A25)'. Moment effects were' evaluated based on~ the stiffness of 7 '
Ethe system components,J and the --load couple approach was- not utilized during the W tdesign' validation of the conduit andl conduit supports. f 3.0 Corrective and Preventive' Action g^ -- , c -< JNo additional issues'were identified during the review and resolution of this t issue. E xThis: issue was determined to be' reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-85-34 in. letter number TXX-6047, dated October 21, 1986 from TU Electric to' the NRC (Also see' Subappendix B3). + - 3.11 ! Corrective Adtion w - Concrete surface mounted suppor.ts have been design validated in accordance with
*;; ithe design-validation procedures (References 4.1 and 4.2) which require that-
-the. load eccentricity effects be utilized.
- w-:-
3 2l Preventive ActLqn ' Design validation procedures (References 4.1 and 4.2) require evaluation of
' eccentric load effects. In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis DocumentL(D80);(Reference 4.3).
t4.0 , References 4.1 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic I
$ . Category I Electrical Conduit System," Revision 6, dated October 30, ! *NA 1987. j i ;[ c r A28-1 q
n _ . . _ . - - - -
__7__ .
$4 .
~
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.SUBAPPENDIX A28 w .:,;-y :. ..
4.2 Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for
' ; f,
'- ; Design Verification of Electrical Conduit and Box Supports,"
. Revision 4, dated October 12,~1987.
4.3 L Comanche Peak Steam Electric ' Station Design Basis Document, DBD-CSe090,." Conduit and Conduit Support Design Train A, B and
. Greater Than Two Inch Diameter Train C Conduits," Revision 1.
.'i, 4 .e -
m jl h 1\ l l
.}
m A28-2
. .. _ _ _ _ = _ -
L i SUBAPPENDIX A22 i I' i , CUMULATIVE EFFECT OF REVIEW ISSUES (CYGNA ISSUE NO. 29)
- . j o>
I 1.0- Definition of the Issue
'The issue was that although.a number of issues cited may lead to small unconservatisms when occurring singly in a support design, and can usually be neglected, there may be a more significant cumulative effect when a support is impacted by more than one issue.
2.0 Issue Resolution All-issues in the conduit supports Review Issues List (RIL) (Reference 4.8) have been individually addressed in the design validation program of conduit and conduit supports and regardless of their significance, no issue effects were neglected. 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the NRC (Also see Subappendix B3). g n) 3.1 Corrective Action The conduit and conduit support design validation program has addressed the Comanche Peak Response Team (CPRT) and external issues individually. Regardless of their significance, no issue effects were neglected. 3.2 Preventive Action I The design validation procedures (References 4.1 through 4.5) and design drawings-(Reference 4.7) provide design criteria which consider the issues raised. In addition, the design criteria used for the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.6). i A29-1
- a. _ __.
{"' b r A' SUBAPPENDIX A29 bI)
-v 4.0 References
' 4.1 ' 'Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic Category I Electrical _ Conduit System," Revision 6 dated October 30,.1987.
4.2 Ebasco-Procedure No. SAG. cpl 7, " Unit 1 Design Criteria for Junction Boxes for Seismic Category.I Electrical Conduit Systems," Revision 7,~ dated October 12, 1987.
'4.3. Ebasco Procedure No. SAG.CP21, " Unit 1 Tet.hnical Guidelines for Thermal Analysis of Seismic Category I Electrical Conduit System,"
Revision 3, dated October 13,.1987. 4.4 Ebasco Procedure No. SAG.CP25, " Unit-1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric Validation," Revision.1, dated October 16, 1987.
, L4. 5 Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for Design -Verification of Electrical Conduit and Box Supports,"
. Revision 4, dated October 12, 1987.
' 4'. 6 Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit' Support Design Train A, B and Greater than Two Inch Diameter Train C Conduits," Revision 1.
g. (f 4.7- Drawing No. 2323-S-0910 design document. 4.8- CYGNA, Conduit Supports Review Issues List, Revision 3, November 20, 1985. 4 9 A29-2 1 v
m SUBAPPENDIX A30
'A CONDUIT UNIONS (CPRT-00C ISSUE) 31.0 Definition of'the ' Issue The' issue was that during the walkdown of conduits by Comanche Peak Response Team (CPRT). Quality of Construction (QOC) program several instances were identified where the unions joining conduit sections were found to be loose.
Loose unions lin conduits could result in the two ends of the conduit becoming free due to vibration. The structural continuity of the conduit could not be assured and the cable' housed within could be subject to a load not-specifically considered. 2.0 Issue Resolution The engineering walkdown procedures (Reference 4.1 and 4.4) require the identification of the unions in conduit runs. The tightness of the unions is being verified in accordance with construction procedure (Reference 4.2) and is Quality Control.(QC). inspected ~in accordance with the QC inspection procedure (Reference 4.3). 3.0 Corrective and Prev.gntive Action No additional . issues were identified during the review and resolution of this issue..
,e3 - 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-87-23.in letter number TXX-6565, dated July 27, 1987 from TV Electric to the NRC..
3.1 Corrective Action Conduit runs with unions were identified as required by the walkdown procedures (References 4.1 and 4.4). Construction and Quality Control (QC) Inspection
. procedures (References 4.2 and 4.3) were modified to include requirements for verification of the tightness of a union and this verification is in progress.
3.2 Preventive Action Construction and Quality Control (QC) Inspection procedures (References 4.2 and 4.3) contain requirements to preclude the occurrence of loose unions in conduit runs. 4.0 References 4.1 CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways for Unit 1 Installations in Unit 1 and Common Areas," Revision 2, dated August 14, 1987 l rk
'\ .
!. A30-1 L- ----------------------_i
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p L SUBAPPENDIX A30 r s ('y.gr 1.4. 2 L ECP-19, " Exposed Conduit / Junction Box and Hanger Fabrication and Installation, Unit- No,'1, " Revision 15, August 31, 1987.
*)
[ 4.3l NQA-3.09-2.03, " Conduit Support-Field: Inspection", Revision 1, September.24, 1987.. 4.4 CPE-EB-FVM-CS-014,"DesignCondrolofElectricalConduit Raceways'for Unit 2 Installation in Unit 1 and Common Areas", Revision _5,-dated. July 29, 1987. 4 r ,
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ij"
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- APPENDIX B' W h. k [ ISSUES'IDENTIFIEDDURING'THEPERFORMANCEOF-THE CORRECT] VE ACTION PROGRAM (CAP).
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lThis ' appendix describes the details ~of the. resolution of-issues identified
?during_ the performance of the conduit and conduit. supports Corrective Action Program'(CAP).. Included in'this appendix are conduit and conduit support:related- Significant Deficiency-' Analysis Reports (SDARs) initiated
'by TU- Electric. ' Specific' references to the criteria,' procedures,-
6 ; engineering studies, andl tests which have resolved the issue are provided. n~ ' To report the resolution of issues identified during the performance of y :the: Corrective Action, Program (CAP), an individual Subappendix was
? developed for each issue. . Each Subappendix includes: La definition of the issue;. issue resolution;' and corrective and. preventive: action.
The preventive actionLis embodied in the! procedures and Design Basis; DocumentJ(DBD) developed-and used in the conduit and conduit supports
- Corrective Action Program (CAP). : These procedures and Design Basis .
; Document < (D80) resolve the conduit and conduit supports Corrective Action s Program (CAP): issues. : Implementation of these preventive actions will-
, ,'Jassure;that the design.and hardware for CPSES Unit.1 and Common conduit
',< and; conduit supports will: continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4.
, Ebascot has reviewed the Safeti Evaluation Report (SER) and Supplomants SN Lthereto'(SSERs) and' determined that the conduit and conduit support design criteria,Tdesign procedures and validated hardware are consistent with the 3 "
- NuclearlRegulatory Commission (NRC) staff positions stated i_n the SER and
.its Supplements (SSERs)..
Corrective Action Program (CAP).~1ssues' contained in' Appendix.B are listed ~
, .below: ,
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. Issue No. " Issue Title -
Blu m SDAR-CP-85-19'- Conduit Support. Spans
;B2: SDAR-CP-85 Electrical Raceway Support System
-B3 SDAR-CP-85 Conduit ~ Support Design
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B4- SDAR-CP-86 Seismic' Design of Conduit I f ibT B-1 o
i i SUBAPPENDIX B1 g SDAR CP-85-19. CONDUIT SUPPORT SPANS
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LI l.0 ' Definition of the Issue s W. 'The issue was that different yield stress values based on test data were ! utilized for each' conduit size.- Also, documentation was not provided to l substantiate the applicability of the test data for conduits installed at
.CPSES. The issue was initially developed by CYGNA for a limited 1 1 application'in fire protected conduit and was subsequently determined by l
.Ebasco to apply to all conduit. l
.2.0 Issue Resolution The design validationLprocedure (Reference 4.1) was revised to specify a yield stress of 25,000 pounds per. square inch (psi) for all conduit
; sizes. This was consistent with the lowest published yield stress fer
. commercially available steel-used in conduit. The conduit spans were design' validated in accordance with References 4.1 and 4.2.
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 f,).. .10CFR50.55(e). It was reported as Significant Deficiency Analysis Report
.(, -(SDAR) CP-85-19 in letter number TXX-6046, dated October 21, 1986 from.TV
. Electric to the NRC.
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l 3.1. Corrective Action i
' Conduits,' including those with fire protection, were design validated l utilizing a yield stress which does not vary with the conduit size and which is based on the lowest yield stress of any commercially available
- steel used for conduits.
3.2 Preventive Action-The design validation procedures (Reference 4.1 and 4.2) require use of a
' conduit allowable stress which does not vary with size and which is based on the lowest yield stress for any commercially available steel used for conduits. In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis Document'(DBD) (Reference 4.3). j 4.0' References 4.1 Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for I j
Seismic Category I Electrical Conduit System," Revision 6, October 30, 1997. h: l B1-1 l l
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SUBAPPENDIX Bl. !. W 4;2 Ebasco Procedure No. SAG.CP25, " Unit 1 -Technical Guidelines for L:- U '^
- Seismic Category I Electrical Conduit Isometric Validation",
'RevisionL1, dated October 16, 1987.'
L, ,' 4.3 Comanche Peak Steam Electric Station Design Basis Document,
; 0BD-CS-090,'" Conduit and Conduit Support, Train A, B and Greater
.M than Two Inch Diameter Train C Conduits", Revision 1.
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y ___ li v l 0 SUBAPPENDIX B2 W. SDAR CP-85-31. ELECTRICAL RACEWAY SUPPORT SYSTEM C) : L1.0 Definition of'the Issue
' Separation' Barrier Material (SBM) and Radiant Energy Shield (RES) material were. installed on Class 1E electrical raceways. (cable trays and conduits) i
.in' order:to meet the FSAR and Regulatory Guide 1.75 electrical separation l
. criteria (Reference 4.1).' The issue was that the design of conduit and j
' conduit . supports' constructed prior to the installation of the SBM and RES I
.did not account for the-additional weight imposed. '
2.0 Resolution of the Issue Conduit and conduit supports with Separation Barrier Material (SBM) and Radiant Energy Shield (RES) material were' design validated in accordance with the design validation procedures (Reference 4.2) including SBM and RES weights.
~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 p (SDAR) CP-85-31'in ' letter number TXX-6138, dated December 5, 1986 from TU V Electric.to NRC.
- 3.1 . Corrective Action The conduit and conduit supports with Separation Barrier Material (SBM) and Radiant Energy. Shield (RES) material have been design validated.in accordance with design. validation procedure (Reference 4.2). As a result
< of the design validation, modifications were identified, issued and are
.being implemented.
3.2 Preventive Action ,. 4 The procedure governing design changes (Reference 4.3) requires that when l Separation Barrier Material (SBM) and Radiant Energy Shield (RES) material ' are added to electrical raceways, the conduit and conduit supports discipline group be notified.' Design criteria requirements have been i included in the design validation procedure (Reference 4.2). In addition, the design criteria requiring design validation of conduit and conduit , supports with Separation Barrier Material (SBM) and Radiant Energy Shield i (RES) material have'been documented in the Design Basis Document (DBD) (Reference 4.4). O B2-1
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4' , SUBAPPENDIX-82 L. ..
=4;0 . References x }m .
LV 4.1: Regulatory Guide:1.75,:" Criteria for Separation of Redundant Classt 1E Equipment ~ and Circuits Installed 'at- Nuclear Power Plant," Revision 1, dated January, 1975.
- 4.2 Ebasco Procedure No. SAG.CP25, " Unit 1. Technical Guidelines for Seismic Category. I Electrical Conduit-Isometric Validation," i Revision 1,. dated October 16, 1987. l
- 4.3 ECE 5.01-I3, " Design Change" Authorizations",-Revision 0,. dated March 2, 1987.
4.4' Comanche Peak Steam Electric Station Design Basis Document, DBD-CS-090, " Conduit and Conduit Supports Design Train'A, B and
. Greater Than Two Inches Diameter Train C Conduits," Revision 1.
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, SUBAPPENDIX B3
;g SDAR CP-85-34. CONDUIT SUPPORT DESIGN Q
, ! 1.0- Definition of the Issue The? issue was that discrepancies.may have existed between as-built and as-designed conduit and conduit support configurations (Reference 4.1) and that original design criteria may not have appropriately addressed certain k design requirements. A description of these concerns is provided in Subappendices Al through A20 and A23 through A29 of this Project Status Report (PSR).
2.0L Issue Resolution To resolve this issue, TU Electric initiated the' conduit and condait support 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 (References 4.2 through 4.7, 4.9 and 4.10) that include the following: Use of as-built data as design input for conduit and conduit support validation. Validation of conduit and conduit supports to design criteria that is in compliance with CPSES licensing commitments, and responsive to ft. all Comanche Peak Response Team (CPRT) and external issues.
! Testing to establish allowable load capacities and suitable methods for modification of conduit.
Engineering studies implemented to provide additional confidenca in i the conservatism of the design validation procedures used for conduit and conduit supports.
' Implementation of hardware modifications as necessary to assure that {
all' conduit and conduit supports comply with the validated design. 1 I Resolutions to the related issues are discussed in Subappendices Al through A20 and A23 through A29 of this Project Status Report (PSR). 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-85-34 in letter number TXX-6047, dated October 21, 1986 from TV Electric to the NRC.
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Y e' ;SUBAPPENDIX B3 fc il;.CorrectiveAction. d' +: Conduit and conduit supports have been design validated in accordance with y : the design. validation _ procedures (References 4.2 through 4.7). These
. procedures: include the design criteria'that comply with the CPSES licensing commitments, and are responsive.to the Comanche Peak Response , Team (CPRT).and~ external l issues. The hardware is being validated to the validated design in accordance with'the Post Construction Hardware Validation Program (PCHVP) (Reference 4.8).
3.2- Preventive Action. The' design criteria and. procedures (References 4.2 through 4.7) responsive
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to the Comanche: Peak Response Team (CPRT) and external issues (Reference L 4.1).have been utilized in the design validation. In addition, the design criteria used in the design validation of conduit and conduit supports have been documented in the Design Basis Document (DBD) (Reference 4.11). 4.0- References 4.1: Comanche Peak Response' Team Action Plan, DSAP VIII, " Civil / Structural Discipline Specific Action Plan", Revision 1, January 24, 1986. 4.2- Ebasco Procedure No. SAG.CPIO, " Unit 1 Design Criteria for Seismic . Category I Electrical Conduit System," Revision 6, yE dated October 30, 1987. r b. 4.3 .Ebasco Procedure.No.-SAG.CP17, " Unit'l Design Criteria for Junction Boxes?for Seismic Category I Electrical Conduit System," Revision 7, dated October 12, 1987. 4.4 Ebasco Procedure No. SAG.CP20,." Unit 1 Technical Guidelines for
' System Analysis of Conduit Span Configurations," Revision 4,.
dated October 13, 1987. .
.4.5 Ebasco: Procedure.No. SAG.CP21, " Unit l' Technical Guidelines for i Thermal Analysis of Seismic Category I Electrical Conduit !
7 System," Revision 3, dated October 13, 1987. ' 4.6 Ebasco Procedure No. SAG. CP25, " Unit 1 Technical Guidelines for Seismic Category I Electrical Conduit Isometric l Validation," Revision 1, dated October 16, 1987.
' 4.7. Ebasco Procedure No. SAG.CP29, " Unit 1 General Instructions for Design Verification of Electrical Conduit and Box Supports,"
Revision 4, dated October 12, 1987. O - B3-2 l _ _ _ _ _ _ _ _ _ _ _ _ a
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'SUBAPPENDIX B3 r'~'i -
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4.8- ' CPE-EB-FVM-CS-033, " Design Control 'of Electrical Conduit.
- . Raceways for. Unit 1 Installation in Unit 1 and Common Areas,"
,. Revision 2; dated August 14, 1987. -
l 9 . 4.9 ' Ebasco Calculation No TNE-CS-CA-CA-la, " Design of Conduit Support Capacities for CA-la and CA-2a type UNISTRUT i .: Supports," Revision 2, October 5, 1987.
.4.10 Ebasco Calculation No. TNE-CS-CA-CA-2b, " Design of Conduit l
- Support Capacities for CA-2b type UNISTRUT Supports," Revision
- p. ,
~1,. dated October 16, 1987.
, 4.11 Comanche Peak Steam Electric Station Design Basis Document, LDBD-CS-090, " Conduit and Conduit Support Design Train A, B and
. Greater Than Two Inch Diameter Train C_ Conduits", Revision 1.
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.3-SUBAPPENDIX B4 d) - SDAR CP-86-53. SEISMIC DESIGN OF CONDQ l.0- Definition of the Issue L The issue was that a design deficiency occurred whenever a rigid overhang conduit changes direction and terminates in an airdrop with no support
- provided between the change in direction and the airdrop and a threaded fitting is present' prior to the change in direction ~(See Figure 5-4).
During a seismic event, the unsupported portion of the conduit may place a
' torsional moment on the threaded fitting. The inability of the threaded
' fitting to resist the torsional moment could result in excessive motions at the free end of the conduit. Motions in these free end configurations
.would then be resisted by the cable. Neither the cables nor the terminations have been specifically designed for the loads imposed by such motion.
2.0 h sue Resolution The engineering walkdown procedure (Reference 4.1) requires the identification of threaded fitting (s) in a rigid overhanging conduit. A test program conducted at Corporate Consulting and Development Company, Ltd.-(CCL)-has shown that wrapping the threaded fitting and adjacent areas with fiberglass cloth impregnated with Scotch Cast Product produces the required torsional resistance (Reference 4.2). Accordingly, all such instances are being corrected either by fiberglass cloth wrapping or by
' -O edditio of suo9erts ia the overhea91a2 9ertioa of the coaduit to preveat excessive movement of the conduit.
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-86-53 in letter number TXX-6054 dated October 21,1986 from TU Electric to the NRC. 3.1 Corrective Action The engineering walkdown procedure (Reference 4.1) requires the i identification of threaded fittings in rigid overhanging conduit. The I identified conduit runs with threaded fitting (s) on the overhang are being modified by either installing fiberglass cloth wrapping or by providing supports-in the overhang portion of the conduit. ! l . n 4 l' L.] B4-1 i L e _-____-__-__A
t -( y SUBAPPENDIX B4
- 3.2 Preventive Action ,
'^'f"a -l LCanstruction;and' inspection procedures (References;4.3 and 4.4) have been established to: preclude recurrence of this issue.
4.0- References-
'4.1 ~ CPE-EB-FVM-CS-033, " Design Control of Electrical Conduit Raceways for Unit 1 Installations in Unit 1)and Common Areas,"
- Revision 2, dated August 14, 1987. _
6 s s 4.2. CCL ReportiNo. A-746-87,'" Static and Cytlic Test of Conduit
' Couplings,"-dated June 10, 1987. p 4.3 ECP-19, " Exposed Conduit /Junctico, Box End Fanger Fabrication and Installation,"' Revision 15[ Ad9 test 31,1987.
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'4.4~'NQA-3 09-2.03 "Condtit Support Field Inspection", Revision 1, September 24,~ 198?i. t l, { , e .
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