ML20245C917

Rev 0 to Large Bore Piping & Pipe Supports, Project Status Rept

ML20245C917
Person / Time
Site:	Comanche Peak
Issue date:	11/02/1987
From:	Klause R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20245C905	List: ML20245C917 TXX-6845, Forwards Rev 0 to Large Bore Piping & Pipe Supports, Project Status Rept.Resolution of Issues Identified in Large Bore Pipe Stress & Pipe Support Generic Issues Rept Contained in App a & B of Encl Rept
References
TAC-R00242, TAC-R242, NUDOCS 8711040204
Download: ML20245C917 (199)

Text

O COMANCHE PEAK STE AM ELECTRIC STATION UNIT 1 and COMMON CORRECTIVE ACTION PROGRAM O

PROJECT STATUS REPORT l

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LARGE BORE PIPING AND PIPE SUPPORTS

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>4 I II 'u l R I'v O Generating Division I R$A*1888287ss8Ls s

A PDR 1

I l Revision 0 l

l TU ELECTRIC COMANCIE PEAK STEAM ELECTRIC STATION UNIT 1 AND COMMON l

STONE & WEBSTER ENGINEERING CORPORATION PROJECT STATUS REPORT LARGE BORE PIPING AND PIPE SUPPORTS l

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R. P. Klause Project Manager l

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TABLE OF CONTENTS )

Section Title Page  !

EXECUTIVE

SUMMARY

iv ABBREVIATIONS AND ACRONYMS vii  :

1.0 INTRODUC.fION 1-1 Figure 1-1 Large Bore Piping and Pipe Support Corrective Action Program (CAP) ,

2.0 PURPOSE 2-1 3.0 SCOPE 3-1 1 4.0 SPECIFIC ISSUES 4-1 1 5.0 CORRECTIVE ACTION PROGRAM 5-1 i METHODOLOGY AND RESULTS 5.1 METHODOLOGY AND WORK PERFORMED 5-1 5.1.1 Licensing Commitments, Design Criteria, 5-1 l and Procedures

( 5.1.1.1 Verification and Validation of Design 5-2 l I

Methodology 5.1.1.2 Resolution of Piping-Related Design Issues 5-3 5.1.2 Design Validation Process 5-6 5.1.2.1 Piping System Input Validation 5-6 5.1.2.2 Pipe Stress Analysis 5-7 ,

5-10 5.1.2.3 Pipe Support Analysis 5.1.2.4 Validation of Seismic Category II 5-12.

Large Bore Piping and Pipe Supports Over Seismic Category I Equipment 5.1.2.5 SWEC-PSAS Clearance Walkdowns 5-12 5.1.2.6 Testing 5-12 5.1.2.7 Final Reconciliation of Large Bore Piping 5-14 and Pipe Supports 5.1.3 Post-Construction Hardware Validation Program 5-15 (PCHVP) ,

5.1.3.1 Post-Construction Hardware Validation Program 5-19 (PCHVP) Procedures 5.2 RESULTS 5-23  !

?1 5.2.1 Pipe Stress Analysis Results 5-23 ]

5.2.2 Pipe Support Analysis Results 5-24 i l

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Section Title. Page (m) b 5.2.2.1 Pipe Support Modifications Identified Prior 5-24 to Stress Analysis i 5.2.2.2 Special Pipe Support Frame Analyses 5-26 5.2.2.3 SWEC As-Built Verification of Modifications 5-26 5.2.3 Post-Construction Hardware Validation Program 5-26 l (PCHVP) Results 5.3 QUALITY ASSURANCE PROGRAM 5-28 5.3.1 Summary of SWEC Engineering Assurance (EA) 5-30 Audits 5.3.2 Summary of Audits by TU Electric - QA/ TAP, 5-31 NRC-VPB, and SWEC-QAAD 5.4 CORRECTIVE AND PREVENTIVE ACTION 5-33 Figure 5-1 Corrective Action Program (CAP) Flow Chart and Governing Procedures - Large Bore Piping and Pipe Supports Figure 5-2 Corrective Action Program (CAP) Technical Interfaces - Large Bore Piping and Pipe Supports Figure 5-3 SWEC-PSAS Pipe Stress Validation Flow Chart Figure 5-4 SWEC-PSAS Pipe Support Validation Flow Chart Figure 5-5 Post-Construction Hardware Validation Program O. Table 5-1 (PCHVP)

Piping System Input Data l

Table 5-2 Fluid Transient Loadings Table 5-3 PCHVP Reinspection Attributes and Resolutions in Response to CPRT Quality of Construction ISAP-VII.C Results Report Table 5-4 Unit I and Common Large Bore Pipe Supports Modification Summary Table 5-5 Summary - Cinched U-Bolt Trapeze Support Modi-fications Table 5-6 Seismic Category II Large Bore Piping Over Seismic Category I Equipment Piping Check-list Table 5-7 PCHVP Large Bore Piping and Pipe Supports -

Installation / Inspection Procedures l Table 5-8 Seismic Category II Large Bore Piping Over Seismic Category I Equipment Pipe Support Checklist Table 5-9 Typical SWEC-PSAS Technical and Design Control Practices Table 5-10 Summary of SWEC Engineering Assurance Audits Table 5-11 Summary of TU Electric Audits f

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Section Title h ge V

6.0 REFERENCES

6-1 APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) AND EX- A-1 TERFAL ISSUES APPENDIX B ISSUES IDENTIFIED DURING PERFORMANCE OF THE B-1 ,

CAP 'l APFENDIX C. PREVENTIVE ACTIONS C-1 I

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EXECUTIVE

SUMMARY

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This Project Status Report (PSR) summarizes the systematic validation process for safety-related large bore piping (larger than 2 in. nominal pipe size) and k pipe supports implemented by Stone & Webster Engineering Corporation - Pipe Stress Analysis and Support Project (SWEC-PSAS) at Comanche Peak Steam Electric Station (CPSES) Unit I and Common1 . This Project Status Report (PSR) presents the results of the design validation and describes the Post-Construction Hard-ware Validation Program (PCHVP). SWEC-PSAS's activities were governed by the TU Electric Corrective Action Program (CAP) which required SWEC-PSAS to:

1. Establish a consistent set of CPSES safety-related piping and pipe support design criteria that complies with the CPSES licensing commitments.

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

3. Evaluate systems, structures, and components, and direct the correc-tive actions recommended by the Comanche Peak Response Team (CPRT) and those determined by the Corrective Action Program (CAP) inves-tigations to be necessary to demonstrate that systems, structures, and components are in co-formance with the design.

4. Assure that the validation resolves the piping-related design and p hardware issues identified by the Comanche Peak Response Team (CPRT),

external sources 2, and the Corrective Action Program (CAP).

3 Common refers to areas in CPSES that contain both Unit I and Unit 2 sys- ,

tems, structures, and components 1 2 External issues are issues identified by the following:

NRC Staff Special Review Team (SRT-NRC)

NRC St'ff a Special Inspection Team (SIT)

NRC Staff Construction Appraisal Team (CAT)

Citizens Association for Sound Energy (CASE)

Atomic' Safety and Licensing Board (ASLB)

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

CYGNA Independent Assessment Program (IAP)

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

CPRT Design Adequacy Program (DAP)

C.?RT Quality of Construction Program (QOC) i l

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5. Validate that the design of sa:fety-related piping systems is in con-

[ formance with the licensing commitments and that the installed hard-  !

ware is in conformance with the validated design.

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

A consistent set of design criteria for CPSES safety-related piping and pipe supports has been developed and used by SWEC-PSAS for the design validation process. This set of design criteria and methodologies is in conformance with the CPSES licensing commitments. It has been independently and extensively reviewed and was accepted by Comanche Peak Response Team (CPRT) and by CYGNA Energy Services (CYGNA).

SWEC-PSAS established design control procedures to implement the design cri-teria and methodologies described above, and to govern the work flow and technical interfaces with other disciplines, for both the design and hardware validation processes. These procedures specify the processes (such as the validation of piping system inputs, piping and pipe support checklists, docu-mentation control, and final reconciliation) that have been implemented  ;

throughout the safety-related large bore piping and pipe supports Corrective  !

Action Program (CAP).

SWEC-PSAS has performed analyses to validate the design of as-built CPSES Unit 1 and Common safety-related large bore piping and pipe supports 3 The results are documented in 384 pipe stress analysis packages4 that contain approximately 12,020 pipe supports. The as-built hardware for safety-related large bore piping and pipe supports is being validated to the design by the Post-Construction Hardware Validation Program (PCHVP).

t Methodologies have been incorporated into the SWEC-PSAS design criteria and the Post-Construction Hardware Validation Program (PCHVP) implementation procedures which have resolved the piping-related design and hardware issues identified by the Comanche Peak Response Team (CPRT), external sources, and the Corrective Action Program (CAP). Consequently, the validated design of the CPSES safety-related large bore pipe and pipe supports has resolved these piping-related issues.

The Post-Construction Hardware Validation Program (PCHVP) assures that the safety-related large bore piping and pipe supports are installed in confor-7 3 Analysis of the ASME Section III (Reference 22) Code Class 1 piping for the Corrective Action Program (CAP) was performed by Westinghouse. SWEC performed the analysis of the ASME Section III Code Class 1 pipe supports as well as "

the ASME Section III Code Class 2 and 3 piping and pipe supports.

4The term " pipe stress analysis package" is used in this Project Status Report to describe the engineering documentation required to validate the design adequacy of piping.

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f p mance with the validated design. SWEC-PSAS has reviewed and revised the CPSES l t] piping-related installation specifications, construction procedures, and  !

reviewed quality control inspection procedures to assure that the validated i design requirements are implemented. The Post-Construction Hardware Validation l Program (PCHVP) for safety-related large bore piping and pipe supports, in- l cluding the 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.

SWEC-PSAS will provide TU Electric a complete set of validated design documen-tation for CPSES safety-related large bore piping and pipe supports, including the pipe stress and pipe support calculations, drawings, and interface disci- 1 pline transmittals. This documentation, in conjunction with the updated speci-  !

fications and procedures, can provide the basis for CPSES configuration con-tro15 to facilitate maintenance and operation throughout the life of the plant. )

In-depth quality and technical audits have been performed by SWEC Quality Assurance, TU Electric Quality Assurance, and the independent Engineering )

Functional Evaluations (EFE). These audits, in addition to the third party j overview performed by TENERA, L.P. (TERA) for Comanche Peak Response Team '

(CPRT) assured that the SWEC-PSAS procedures and the established design criteria complied with the licensing commitments. .

The Unit 1 and Common safety-related large bore piping and pipe supports Cor-redtive Action Program (CAP) validates that: '

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• The design of the large bore piping and pipe supports complies with O the CPSES licensing commitments. I

• The as-built safety-related large bore piping and supports comply with the validated design.

• The large bore piping and pipe supports comply with the CPSES licens-ing commitments and will perform their safety-related functions, configuration control is a system to assure that the design and hardware remain in compliance with the licensing commitments throughout the life of the plant.

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ABBREVIATIONS AND ACRONYMS AISC American Institute of Steel Construction ANSI American National Standards Institute ARS Amplified Response Spectra ASLB Atomic Safety and Licensing Board ASME Section III American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section III, Division 1, Nuclear Power Plant Components BRP Piping Isometric Drawing CAP Corrective Actica Program (TU Electric)

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

CFR Code of Federal Regulations CMC Component Modification Card CPE Comanche Peak Engineering (TU Electric)

CPPP Comanche Peak Project Procedure CPRT Comanche Peak Response Team (TU Electric)

CPSES Comanche Peak Steam Electric Station CYGNA CYGNA Energy Services DAP Design Adequacy Program (CPRT)

DBCP Design Basis Consolidation Program (SWEC-PSAS)

DBD Design Basis Document DCA Design Change Authorization DIR Discrepancy Issue Report (CPRT-DAP) g g

DR DSAP Deviation Report Discipline Specific Action Plan (CPRT)

DVP Design Validation Package DWG Design Drawing EA Engineering Assurance (SWEC)

Ebasco Ebasco Services Incorporated EFE Engineering Functional Evaluation FSAR Final Safety Analysis Report FVM Field Verification Method GIR Generic Issues Report HELB High-Energy Line Break HVAC Heating, Ventilation, and Air-Conditioning IAP Independent Assessment Program (CYGNA)

IEB Inspection and Enforcement Bulletin (NRC)

Impell Impell Corporation ISAP Issue-Specific Action Plan (CPRT)

IWA Integral Welded Attachment LOCA Loss-of-Coolant Accident MELC Moderate Energy Line Crack NCR Nonconformance Report NOV Notice of Violation (NRC)

NRC United States Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation (NRC)

NSSS Nuclear Steam Supply System (Westinghouse) vii

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NUREG NRC Document NUREG/CR NRC Document Developed by NRC Contractor p)s

(, PCHVP Post-Construction Hardware Validation Program PM Project Memorandum PSAS Pipe Stress Analysis and Support PSR Project Status Report PWR Pressurized Water Reactor QA Quality Assurance QAAD Quality Assurance Auditing Division (SWEC)

Quality Control I QC QOC Quality of Construction and QA/QC Adequacy Program (CPRT)

RIL Review Issue List (CiGNA)

SDAR Significant Deficiency Analysis Report (TU Electric)

SER Safety Evaluation Report (NRC, NUREG-0797)

SIT Special Inspection Team (NRC Staff)

SRT Senior Review Team (CPRT)

SRT-NRC Special Review Team (NRC)

SSE Safe Shutdown Earthquake SSER Supplemental Safety Evaluation Report (NRC,

.NUREG-0797)

SWEC Stone & Webster Engineering Corporation SWEC-PSAS Stone & Webster Engineering Corporation - Pipe Stress and Support Project TAP Technical Audit Program (TU Electric)

TERA TENERA, L. P.

TET Thermal Expansion Testing

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

Ultrasonic Testing VMG Vibration Monitoring Group VPB Vendor Program Branch (NRC) viii

1.0 INTRODUCTION

' In October 1984, TU Electric established the Comanche Peak Response Team (CPRT) to evaluate issues that have been raised at CPSES and to prepare a plan for resolving those issues. The Comanche Peak Response Team (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 80 and 81). This review identified that the Comanche Peak Response Team (CPRT) issues were very broad in scope and included each discipline. TU Electric decided that the appropriate method to correct the issues raised and to identi-fy and correct any other issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue. .

TUElectricdecidedtoinitiateacomprehensiveCorrectiveActionProgram(CAP) l (Reference 49) to validate the entirety of CPSES safety-related designs.1,'

The scope of the Corrective Action Program (CAP) has the following objectives:

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

• Demonstrate that the existing systems, structures and componenta are in compliance with the design; or develop modifications which will bring systems, structures, and components into compliance with design.

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

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

2 Portions of selected nonsafety-related systems, structures and components are included in the Corrective Action Program (CAP). These are Seismic Cate-gory 11 systems, structures and components, and Fire Protection Systems.

2 Nuclear Steam Supply System (NSSS) design and vendor hardware design and i their respective QA/QC programs are reviewed by the NRC independently of CPSES, and are not included in the Corrective Action Program (CAP) as noted in SSER 13; however, the design interface is validated by the CAP.

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TU Electric contracted and provided overall management to Stone & Webster Engi-O,' neering Corporation (SWEC), Ebasco Services Incorporated (Ebasco), and Impell Corporation (Impell) to implement the Corrective Action Program (CAP) and di-vided the CAP into eleven disciplines as follows:

Discipline Responsible Contractor Mechanical SWEC

-Systems Interaction Ebasco

-Fire Protection Impell Civil / Structural SWEC Electrical SWEC Instrumentatica & Control SWEC Large Bore Piping and Pipe SWEC-PSAS Supports Cable Tray and Cable Tray Hangers Ebasco/Impell Conduit Supports Trains A,B, & C >2" Ebasco Conduit Supports Train C $ 2" Impell Small Bore Piping and Pipe Supports SWEC-PSAS Heating, Ventilating, and Air Ebasco Conditioning (HVAC)

Equipment Qualification Impell A Design Basis Consolidation Program (DBCP) (Reference 30) was developed to define the methodology by which SWEC-Pipe Stress and Support Project (SWEC-PSAS) performed the design and hardware validation. The approach of this DBCP is consistent with other contractors' efforts and products.

O 5- The design validation portion of the Corrective Action Program (CAP) identified the design-related licensing commitments. The design criteria were developed from the licensing commitments and consolidated in the Design Basis Documents (DBDs) (References 1, 2, 3, 61, and 62). The DBDs identify the design criteria for the design validation effort. If the existing design did not satisfy the design criteria, it was modified to satisfy the criteria. The design valida-tion effort for each of the eleven Corrective Action Program (CAP) disciplines is documented in Design Validation Packages (DVPs). The Design Validation Packages (DVPs) provide the documented assurance (e.g. , calculations and draw-ings) that the validated design meets the licensing commitments, including res-olution of all Comanche Peak Response Team (CPRT) and external issues.  ;

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

l The hardware validation portion of the Corrective Action Program (CAP) is im-plemented by the Post-Construction Hardware Validation Program (PCHVP), which demonstrates that existing systems, structures, and components are in compli-ance with the installation specifications (validated design), including the modifications that are necessary to bring the hardware into compliance with the validated design.

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The results of the performance of the Corrective Action Program (CAP) for each

d discipline are described in a Project Status Report (PSR). This Project Status Report (PSR) describes the results for the Large Bore Piping and Pipe Supports - Corrective Action Program (CAP).

l SWEC-PSAS performed a comprehensive design validation of safety-related large bore piping and pipe supports for Comanche-Peak Steam Electric Station (CPSES) in order to demonstrate that the design of piping systems and supports complies with licensing commitments, and is performing the Post-Construction Hardware Validation Program (PCHVP) to demonstrate that the as-built piping and pipe supports comply with the validated design. SWEC-PSAS was initially contracted by TU Electric in 1985 to validate large bore piping and pipe supports at CPSES. When the TU Electric Corrective Action Program was created in 1986, it incorporated and expanded the existing SWEC-PSAS program. The validation pro- l cess is conducted in accordance with the Piping - Design Basis Consolidation Program (Piping-DBCP), which controls implementation of the piping portion of the TU Electric Corrective Action Program (CAP). The Large Bore Piping and Pipe Support Corrective Action Program (CAP) encompassed the Comanche Peak i Response Team Action Plan DSAP IX, Piping and Pipe Supports Discipline Specific i Action Plan (CPRT-DSAP IX) (Reference 4). The Piping and Pipe Supports -

Corrective Action Program (CAP), shown schematically in Figure 1-1, was developed by SWEC-PSAS to implement the corrective actions for the large bore piping and pipe supports discipline following the directions specified in the TU Electric's Corrective Action Program (CAP). The design bases of the Large Bore Piping and Pipe Support - Corrective Action Program (CAP) are contained within a consolidated set of CPSES Design Basis Documents (DBDs) for safety-related piping and pipe supports.

d Validation of the CPSES large bore piping and pipe supports is accomplished by pipe stress and pipe support analyses and implementation of required field mod-ifications. The results and the methodology used in implementing both the de-sign and hardware-related validations for Unit 1 and Common large bore piping and pipe supports are presented in this Project Status Report (PSR).

This Large Bore Piping and Pipe Supports Project Status Report (PSR) represents a road map of the validation effort from the early stages of design criteria j

development through the establishment and implementation of the detailed design and design control procedures. The report traces the updating of design /

installation specifications, construction and Quality Control (QC) procedures, l the implementation of the Post-Construction Hardware Validation Program (PCHVP) to validate the as-built piping and pipe support design, and the completion of the Unit I and Common large bore pipe stress analysis packages and pipe support calculations.

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FIGURE 1-1 O LARGE BORE PIPING AND PIPE SUPPORT CORRECTIVE ACTION PROGRAM (CAP)

(DENTIFY LICENSING I FSAR i COMMITMENTS ( OTHER LICENSING DOCUMENTS DEVELOP DESIGN BASIS DOCUMENTS (DBDs)

PERFORM DESIGN I CPRT (DAP & OOC) ISSUES VALIDATION j EXTERNAL ISSUES:

-NRC (SRT, SIT, TRT, CAT)

-CYGN A (I AP)

-CASE

.ASLB

.NRC INSPECTION REPORTS gg YES O MODIFICATION REQUIRED

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F DESIGN MODIFICATIONS NO 1 P 1 P POST CONSTRUCTION H ARDWARE VALIDATION 2 BUILD / INSPECT

' MODIFICATION PROGR AM (PCHVP)

FIN AL DESIGN RECONCILIATION IS

YES ADDITIONAL l VALIDATION l REQUIRED

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NO FINAL DOCUMENTATION (DESIGN VAllDATION PACKAGES)

A 2.0 PURPOSE s

The purpose of this Project Status Report (PSR)' is to demonstrate that the safety-related large bore piping and pipe-supports in Unit I and Common are in conformance with the CPSES licensing commitments, satisfy the design criteria, and will satisfactorily perform their safety-related functions.

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3.0 SCOPE The , scope of.the Corrective Action Program (CAP) implemented for CPSES Unit 1 and Common L large ~ bore piping and pipe supports as summarized in this Project Status Report-(PSR) includes:

1. Seismic Category I I-i

• ASME Section III Code Class 2 and 3 piping and pipe supports.

• ASME Section III Code Class 1 pipe supports.

2. Seismic Category II 2

• Pffng and supports required to be included as extensions of a Seismic Category I Pipe Stress Analysis Package.

• Piping and supports of high and moderate energy lines which are computer analyzed (for break and crack postulation purposes) .

• Other piping'and supports, the failure of which could cause dam-age to Seismic Category I structures, systems, or components.

The ' CPSES Piping - and Pipe Supports Corrective Action Program (CAP) is shown schematically in Figure 1-1 and discussed below. The program requires:

1. Establishment of large bore piping and pipe support design criteria which comply with licensing commitments.

2. Development of the Design Basis Documents (DBDs) for CPSES large bore piping and pipe supports, which contain the design criteria. These IStructures, systems, and components that are designed and constructed to with-stand 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 78). All ASME Section III Code Class 1, 2, l' and 3 piping and pipe supports in CPSES are Seismic Category I.

2Those portions of structures, systems, or components whose continued function is not required, but whose failure could reduce the functioning of any. Seismic Category I system or component required to satisfy the requirements of Regu-latory Guide 1.29 to an unacceptable safety level or could result in inca-pacitating inj ury to occupants of the control room, are - designated Seismic Category II and are designed and constructed so that the Safe Shutdown Earth-quake (SSE) would not cause such failure.

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Design Basis Documents (DBDs) provide the basis for corrective and (N's) preventive actions through the life of the plant.

also identify the updated design / installation specifications, Quality These documents Control (QC)/ Construction procedures, and technical and design control procedures used in the validation process.

3. Implementation of design and hardware validations, consisting of anal-ysis, identification and implementation of necessary modifications, and field verifications as identified in the Post-Construction Hard-ware Validation Program (PCHVP). The as-built design of all large bore piping and pipe supports is validated by Quality Control (QC) inspections, engineering walkdowns, and engineering evaluations.

Analysis results are documented in Large Bore Piping Design Validation Packages (DVPs).

4. Resolution of the design and hardware-related issues of CPSES large bore piping and pipe supports and implementation of a corrective ac-tion plan for closure of these issues. These issues include external issues, Comanche Peak Response Team (CPRT) issues, and issues identi-fled during the performance of the Corrective Action Program (CAP)

(See Section 4.0).

5. The validated design documentation forms the basis for configuration control of CPSES large bore piping and pipe supports. The validated design documentation and updated procedures / specifications will be provided to TU Electric to facilitate operation, maintenance, and fu-ture modifications following issuance of an operating license.

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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 the procedures were developed. Th e technical and design control procedures, in conjunction with the CPSES quality assurance procedures and design and in-stallation specifications that were updated to meet the corrective actions for large bore piping and supports, are consolidated in the CPSES Design Basis Docu-ments (DBDs).

Section 5.1.2 describes the design validation process, including the calculation i input / output reviews and interface requirements with other disciplines, and the preoperational testing program.

Section 5.1.3 describes the Post-Construction Hardware Validation Program (PCHVP) process and the procedures for field verifications (inspections, engi-neering walkdowns , and engineering evaluations) required to be implemented to validate that the as-built large bore piping and pipe supports are in compliance with the design documentation.

Section 5.2 presents a summary of the design validation and Post-Construction Hardware Validation Program (PCHVP) results, including the hardware modifica-tions resulting from the Corrective Action Program (CAP).

I l Section 5.3 describes the quality assurance program implemented for the valida-tion process, including the SWEC Engineering Assurance audits, the Engineering

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r^ Functional Evaluation (EFE) audits, and the TU Electric Technical Auditing Pro-f ts , gram audits.

Section 5.4 describes the SWEC-PSAS inputs to the TU Electric preventive actions including the training of TU Electric Comanche Peak Engineering (CPE) personnel and the transfer of a complete set of the validated design documentation and j procedures to CPE. This documentation and procedures can provide the basis for ] 1 CPSES configuration control throughout the life of the plant.

The design of the Unit 1 and Common large bore piping and pipe supports has been validated as follows:

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Number of Large Bore l Pipe Stress Analysis Number of Description Packages Pipe Supports Unit I and Common - ASME 338 (SWEC-PSAS) 10,459 (SWEC-PSAS)

Section III Code Class 2 and 3 (Seismic Category I)

Unit 1 and Common - ASME 30 (Westinghouse) 990 (SWEC-PSAS)

Section III Code Class 1 (Seismic Category I)

Unit 1 - High Energy 16 (SWEC-PSAS) 574 (SWEC-PSAS)

(Seismic Category II)

TOTAL 384 12,023 Appendix A of this Project Status Report (PSR) describes the details of Correc-tive Action Program (CAP) resolution of the Comanche Peak Response Team (CPRT) and external issues.

Appendix B of this Project Status Report (PSR) describes the details of resolu-tions of issues identified during the performance of large bore piping and pipe supports Corrective Action Program (CAP). These issues are Significant Defi-ciency Analysis Reports (SDARs) (10CFR50.55(e)) (Reference 58) initiated by TU Electric.

! Appendix C of this Project Status Report (PSR) describes the preventive action taken resulting from the implementation of the large bore piping and pipe sup-ports Corrective Action Program (CAP).

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4.0 SPECIFIC ISSUES i

The large bore piping and pipe supports Corrective Action Program (CAP) re-solved all the Comanche Peak Response Team (CPRT) issues, external issues, and issues identified during the performance of CAP. This section presents a listing of piping-related issues addressed in this Project Status Report (PSR).

Technical review and resolution of external and Comanche Peak Response Team (CPRT) issues are described in Appendix A, including responses to the NRC staff evaluations within the CPSES Supplements to Safety Evaluation Report (SER)

.(Reference 28). Resolutions and corrective action taken for issues identified during 'the performance of the Corrective Action Program '(CAP) are described in Appendix B.

External issues were identified in the Large Bore Piping and Pipe Supports Ge-neric Issues Report (GIR) (References 5 and 35). This Generic Issues Report (GIR)'was transmitted to NRC, Citizens Association for Sound Energy (CASE), and CYGNA Energy Services (CYGNA). Comanche Peak Response Team (CPRT) contracted TENERA , . L . P . (TERA)- to perform the Third Party overview (Reference 79) for the completeness and adequacy of these issues / resolutions, and the overview of cor-rective actions implemented by SWEC-PSAS to resolve these issues. The results

.of these Third Party overviews are presented by TENERA, L.P. (TERA) in the Dis-cipline Specific Results Report (Reference 46).

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

Issue No. Issue Title Al Richmond Inserts A2 Local Stress in Piping A3 Wall-to-Wall and Floor-to-Ceiling Supports A4 Pipe Support / System Stability A5 Pipe Support Generic Stiffness A6 Uncinched U-Bolt Acting as a Two-Way Restraint A7 Friction Forces A8 AWS Versus ASME Code Provisions A9 A500, Grade B, Tube Steel A10 Tube Steel Section Properties All U-Bolt Cinching A12 Axial / Rotational Restraints A13 Bolt Hole Gap A14 OBE/SSE - Damping A15 Support Mass in Piping Analysis A16 Programmatic Aspects and QA Including Iterative Design A17 Mass Point Spacing A18 High-Frequency Mass Participation A19 Fluid Transients A20 Seismic Excitation of Pipe Support Mass A21 Local Stress in Pipe Support Members A22 Safety Factors A23 SA-36 and A307 Steel 4-1

l A24 U-Bolt Twisting (s~s)

%d Issue No. Issue Title A25 Fischer/ Crosby Valve Modeling/ Qualification A26 Piping Modeling A27 Welding A28 Anchor Bolts /Embedment Plates A29 Strut / Snubber Angularity A30 Component Qualification A31 Structural Modeling for Frame Analysis A32 Computer Program Verification and Use A33 Hydrotest A34 Seismic /Nonseismic Interface A35 Other Issues A36 SSER-8 Review A37 SSER-10 Review A38 SSER-11 Review A39 CPRT Quality of Construction Review on Piping and Pipe Supports Issues identified during the performance of the Corrective Action Program (CAP) are listed below (issue number corresponds to subappendix number in Appendix B):

Issue No. Issue Title SDAR-CP-86-33, Stiffness Values for Class 1 Stress

(,)

/"~% B1 Analysis 4

B2 SDAR-CP-86-36, Large Bore Piping and Pipe Supports B3 SDAR-CP-86-63, Pipe Support Installations B4 SDAR-CP-86-67, Preoperational Vibration Test Criteria B5 SDAR-CP-86-73, ASME Snubber Attachment Brackets I

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u____-____---- l

5.0 CORRECTIVE' ACTION PROGRAM METH'0DOLOGY AND RESULTS 5.1 METHODOLOGY AND WORK PERFORMED 5.1.1 Licensing Commitments, Design Criteria, and Procedures SWEC-PSAS reviewed the piping-related CPSES licensing documentation (such as the FSAR (Reference 26), NRC Regulatory Guides, NRC Inspection and Enforcement Bulletins, ASME Section III Code, and NRC/TU Electric correspondences) and .

Identified licensing commitments related to the large bore piping and pipe sup- I ports. SWEC-PSAS established design criteria to assure compliance with the licensing commitments. The design criteria are documented in the Design Basis  ;

l Documents (DBDs). SWEC-PSAS then developed design procedures which encompass l l the following:

• Design criteria

• Resolution of Comanche Peak Response. Team (CPRT) and external issues

• SWEC's experience gained through the design of piping and pipe sup-ports for several recently licensed and operating United States nu- 1

clear power plants p

l

• Regulatory. and Professional Society Guidance, such as applicable codes and standards; Welding Research Council Bulletin 300, Technical Positions on Criteria Establishment (Reference 13); and Sections 3.6, 3.7, and 3.9 of NUREG-0800 (Reference 7).

\

SWEC-PSAS Procedures CPPP-7 (Reference 8) and CPPP-6 (Reference 9) are the pri-mary technical and design control procedures, respectively, for the large bore piping and pipe supports Corrective Action Program (CAP).

Engineering methodology, based on SWEC-PSAS experience, has been incorporated within the SWEC-PSAS procedures. A list of typical technical and design con-trol practices that are specified within the SWEC-PSAS procedures is presented in Table 5-9.

The governing procedures implementing the Corrective Action Program (CAP) of )

large bore piping and pipe supports are shown in Figure 5-1. These procedures j assure compliance with the design criteria and the resolution of the Comanche l Peak Response Team (CPRT) and external issues. )

l l

To assure that the licensing commitments related to large bore piping and pipe  ;

supports have been identified, appropriate design criteria established, and 1 procedures developed which comply with the design criteria, several audits and overviews were conducted by the SWEC Corporate Quality Assurance Program and the Comanche Peak Response Team (CPRT). SWEC Quality Assurance 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 SWEC-PSAS implementation is performed by the TU Electric Technical Audit Program (TAP).

The TENERA, L.P. (TERA) conclusions are discussed in detail in the TERA 5-1

1 Discipline Specific Results Report: Piping and Supports (DAP-RR-P-001),

(TERA) states on page 1-2:

{

u Revision 1. In this report, TENERA, L.P.

"SWEC procedures were reviewed for compliance with applicable CPSES FSAR and licensing criteria. Licensing commitments applicable to CPSES were used to establish a listing of criteria which were then used to check SWEC procedures. The procedures were determined to be in compliance either with the existing criteria or criteria changes that were accepted by the NRC for submittals as FSAR amendments (see NRC letter to TUGC0 dated November 4, 1986, Reference 7.4)."

The TU Electric Technical Audit Program (TAP) is auditing the Corrective Action Program (CAP) to assure that the design criteria are reconciled with the li-censing commitments. In addition, CYGNA Energy Services (CYGNA) has reviewed and accepted SWEC-PSAS's resolution of piping and pipe supports issues that were identified by the Independent Assessment Program (IAP) of CYGNA. >

5.1.1.1 Verification and Validation of Design Methodology SWEC-PSAS performed tvo separate walkdowns of samples of Unit 1 and Common as-built large bore piping systems to verify and refine the design methodology used for the design validation process. These walkdowns were performed by ex-perienced SWEC-PSAS personnel and are described below.

The first walkdown, called the Large Bore Walkdown, was conducted in accordance with SWEC-PSAS Procedure CPPP-5 (Reference 14). The results of this walkdown l

7 are documented in Reference 15. The large bore piping walkdown was performed to determine whether the existing design documentation was adequate to initiate

(\--) the pipe stress analyses. As a result of this walkdown, the tolerance for ori-entation of pipe supports was tightened. The orientation of all large bore pipe supports, valves with extended operators, and component supports was rein-spected, and the as-built condition was documented. Other design documentation which was inspected and reviewed was determined to be adequate to initiate pipe stress analyses.

The second walkdown, called the Engineering Walkdown, was performed in accor-dance with SWEC-PSAS Procedure CPPP-8 (Reference 10) to determine:

• Whether there were any additional technical issues related to the functional behavior of the piping system that should be evaluated during the Corrective Action Program (CAP).

• Whether additional design inputs (or refinements thereof), guide-l lines, or procedures were necessary to complete the large bore piping i and pipe support validation effort.

The engineering walkdown was performed by 10 teams composed of both SWEC-PSAS pipe stress and pipe support engineers and encompassed 70 Unit 1 and Common large bore pipe stress analysis packages, including approximately 2,400 pipe supports. The results of this walkdown are documented in Reference 11. This walkdown identified the need for additional refinements that were then O

5-2 t

I E

incorporated into the technical procedure, CPPP-7, and design control proce-dure, CPPP-6 (such as the requirement to validate the valve stem extension de-picted on the as-built drawing, which was incorporated into CPPP-6, see also O Table 5-9).

V l

The engineering walkdown resulted in assurance that no additional technical issues existed, and that the SWEC-PSAS procedures, with the refinements incor-porated, were satisfactory to perform the validation of the large bore piping and pipe supports.

Evaluation of Deviation Reports from CPRT - Quality of Construction (QOC)

Program

)

l SWEC-PSAS reviewed Deviation Reports (DRs) related to the piping system valida- j tion program generated by the Quality of Construction (QOC) program of the (

Comanche Peak Response Team (CPRT), as discussed in Subappendix A39. This re-view was performed in accordance with SWEC- PSAS Procedure CPPP-18 (Refer-ence 17). The purpose of the review was to determine whether any additional j refinement of SWEC-PSAS's design procedures was necessary, and to identify any l deviations that should be specifically or generically addressed for potential l impact on the piping Corrective Action Program (CAP). The review concluded l that there were no changes required in the design procedures to account for the i Deviation Reports (DRs) identified by the Quality of Construction program (QOC) l (Reference 18). However, certain attributes for piping and pipe supports were ,

added to the piping and pipe supports Post-Construction Hardware Validation Program (PCHVP) inspection attribute matrix as a result of the Deviation Report {

i (DR) reviews. Corrective action for the hardware-related concerns identified i by the Quality of Construction program (QOC) or SWEC-PSAS , such as missing l washers, spacers, and locking devices, is implemented through the TU Electric l Post-Construction Hardware Validation Program (PCHVP) as described in l Section 5.1.3. '

5.1.1.2 Resolution of Piping-Related Design Issues l l

SWEC-PSAS evaluated the issues described in Section 4.0 and Appendixes A and B, l and developed technical and design control procedures to resolve the issues. l The resolution of all issues in Appendix A were reviewed by TU Electric i Comanche Peak Engineering (CPE), and resolution of issues in Subappendixes Al through A35 were reviewed by TENERA, L.P. (TERA). The resolutions of the is-sues in Appendix B were reviewed by Comanche Peak Engineering (CPE) and the 4 TU Electric Technical Audit Program (TAP). These resolutions were incorporated into the updated design and installation specifications, as well as the CPSES l quality control and construction procedures. I The issue resolution and implementation processes were as follows:

1. For each issue that affected the large bore piping and pipe supports validation effort, SWEC-PSAS reviewed the associated documentation to gain an understanding of the background. SWEC-PSAS then defined its understanding of the issue.

( l 5-3 V

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_.____________-__-m.-.__

. _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _----------y I

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2. I With the issue thus defined, SWEC-PSAS developed and executed an ac-  !

tien plan to resolve the issue.

m ij 3.

The resolutions were implemented in appropriate SWEC-PSAS project 1

procedures used for the CPSES Corrective Action Program (CAP). Com- i pliance with these procedures is assured by the SWEC Corporate Quali- f ty Assurance program.

1 Third Party Overview Results W

The methodology to resolve Comanche Peak Response Team (CPRT) and external is-sues was documented in SWEC-PSAS's Evaluation and Resolution of Generic Techni-cal Issues Report dated June 27, 1986. Final revision to this Generic Issues Report current (GIR) dated July 24, 1987, updates the resolution sections to encompass I revisions of SWEC-PSAS's procedures and memorandums, and its contents have been incorporated into Appendix A of this report.

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

scope of third party overview included the completeness of issue identifica-tion, adequacy of issue resolution, and techni, cal procedures implemented by SWEC-PSAS.

During performance of Design Adequacy Program (DAP) -ove rview, TENERA , L. P . (TERA) identified and documented issues in Discrepancy Issue Re-ports (DIRs).

SWEC-PSAS has responded to and closed all of the 972 Discrepancy Issue Reports (DIRs) received from TENERA, L.P. (TERA).

C

\

TENERA, L.P. (TERA) has completed the third party overview and presented the results in the Discipline Specific Action Plan Results Report for Piping and Pipe Supports. j As described on page 2-1 of Reference 46, three areas of over-view identified in the Discipline Specific Action Plan IX (DSAP-IX) are dis-cussed as follows:

{

1. Issues i "The Third Party identified, reviewed, and tracked external source identified issues which were raised regarding pipe analysis and pipe support design. This effort also included consideration of TRT Issue j V.c (Reference 7.5), which addresses design considerations for piping '

between seismic Category I and nonseismic Category I buildings. The criteria and methodology used by the Project (SWEC) for analysis of these systems were reviewed by the Third Party. This review provides reasonable assurance that the external tource issues have been identified and that criteria and methodology used by the Project '

address all identified issues."

2. Commitment Verification j i

"The Third Party verified that commitments which establish piping and i

) support-related design criteria and standards are adequately l O

v 5-4 l

t.-__m____-_m___

i addressed in procedures and other Project documents. The commitment sources included the FSAR, design specifications, and the ASME Codes f of Record for piping . (Reference 7.6) and piping supports (Refer-4 ence 7.7). For each criterion source and standard identified, the appropriate criteria and commitments were summarized. These criteria were used in the development of checklists for the review of specific program areas. This review ensures that Project procedures are con-sistent with applicable criteria and commitments.

i Where criteria changes have been submitted by the project to resolve differences between the approved FSAR and Project procedures (docu-mented on C-DIRs) closure is based on the assumption that the NRC will approve the amendments."

3. Procedure Review "The Third Party reviewed procedures (including appropriate SWEC Pro-ject Management memoranda) developed by the Project (SWEC) for the performance of the SWEC scope involving large bore piping analysis and support design to verify, by evaluation of the supporting analys-es, that they are adequate to achieve their intended purpose. This )

review verifies that the proj ect procedures resolve the external source issues." ,

TENERA, L.P.'s (TERA) conclusion on the Third Party review is cited in their Discipline Specific Action Plan Results Report No. DAP-RR-P-001 on page 1-2.

"For each of the thirty-two issues, the resolution methodology has been O reviewed by the Third Party and found to be responsive to the concern and in compliance with applicable FSAR and licensing criteria. The Third Party has concluded that the overall objectives of the review have been I met, and considers all piping-related external source issues applicable to the large nore piping scope to be closed with respect to the methodology being applied to the requalification effort assuming the NRC approves the FSAR amendments."

j CYGNA Independent Assessment Program CYGNA Energy Services (CYGNA), a consulting firm, was originally contracted by TU Electric to perform a project review identified as the Independent Assess- i ment Program (IAP). As a result of this review, CYGNA Energy Services (CYGNA) identified issues which they summarized in the CYGNA Pipe Stress Review Issues List, Revision 4 (Piping-RIL) (Reference 81) and the Pipe Support Review Issues List, Revision 4 (Supports-RIL) (Reference 16).

CYGNA Energy Services (CYGNA) and SWEC held public meetings on November 13 and 14, 1986, at SWEC's Cherry Hill office and December 15 and 16,1986, at CPSES site to discuss the issue resolutions contained in the CYGNA Review Issue List (RIL) in conjunction with SWEC project procedures CPPP-7 and CPPP-6. CYGNA l

Energy Services (CYGNA) then performed audits on the basis of SWEC-PSAS design {

criteria between November 1986 and May 1987. l

, p 5-5 l V l

J l l

At the public meeting in Glen Rose, Texas, on May 19, 1987, CYGNA Energy Ser-vices (CYGNA) announced that all pipe stress and pipe support issues were

,~ closed. All issues relating to embedment plate design, anchorage allowables, spacing, and edge distances were transferred to the Civil / Structural Review Issues List, Revision 0, dated July 12, 1987 (Reference 19), and their resolu-tion is reported in the Civil / Structural Project Status Report (PSR)

(Reference 63).

5.1.2 Design Validation Process The SWEC-PSAS design validation program assures that the design conforms to the licensing commitments. The program can be visualized as a three-step process.

The first step, described in Section 5.1.2.1, is to establish the input and the analytical models of the pipe stress analysis packages, to identify and imple-ment the necessary pipe support optimization and modifications in the analys-es, and to produce a set of pipe stress analysis results (e.g., pipe stresses, support loads, and equipment nozzle loads). The first-step results, described in Section 5.1.2.2, provide the pipe support design loads and determine that the computerized pipe stress analysis results are within the ASME Section III Code allowables. The second step includes the detailed evaluation and design of pipe supports (described in Section 5.1.2.3), the local stresses in piping (integral welded attachments), equipment nozzle and containment penetration loads, valve accelerations, pipe break locations, and floor-to-ceiling / wall-to-wall supports, as specified in SWEC-PSAS Procedures CPPP-6 and CPPP-7. Dis-crepancies identified in this step are resolved either by support modifications or by additional analyses. The third step, or final reconciliation, described in Section 5.1.2.7, is the final process to consolidate analysis, hardware mod-ifications, and inspection documentation from Step 2 into the piping design (V ] documentation. The technical interfaces and flow charts for the large bore piping and pipe supports Corrective Action Program (CAP) are shown schematical-ly in Figures 5-2, 5-3, and 5-4.

5.1.2.1 Piping System Input Validation The design validation process of piping and supports requires a large quantity of input information, as identified in Table 5-1. The SWEC-Mechanical Group and the SWEC-Civil / Structural Group validate the piping system input. The pip-ing system input validation by SWEC and the design inputs developed by SWEC-PSAS are described below.

SWEC-Mechanical Group The SWEC-Mechanical Group reviewed CPSES system design and operating condi-tions, which describe the temperatures and pressures of piping systems. These design and operating conditions are evaluated and revised as necessary based on the validated design. Design and operating system temperatures and pressures for a wide range of plant conditions were documented and transmitted to the SWEC-PSAS pipe stress analysts for use in validation. The SWEC-Mechanical ,

i Group validation effort is described in the Mechanical Project Status Report I

)pV 5-6 i

i

p (PSR) (Reference 64). The SWEC-Mechanical Group identified essentia1 safety-1 related piping systems and components, high energy lines, and potential system fluid transients for evaluation by the SWEC-PSAS Fluid Transients Group. These fluid transients (such as quickly opening or closing control valves, relief valve discharge, pump startup or trip) were identified by following the guidance given in NUREG-0582 (Reference 23), using SWEC's past experience with other pressurized water reactors (PWRs), and by an overall review of the CPSES system design descriptions and flow diagrams.

The SWEC-Mechanical Group reviewed the CPSES flow diagrams and stress boundary isometric drawings (BRPs) to assure that applicable piping lines were included in the pipe stress analysis packages.

SWEC-PSAS Fluid Tranyient Group The SWEC-PSAS Fluid Transient Group was responsible for developing the fluid transient loads (e.g. , water hammer or steam hammer) from the potential tran-sients identified by the SWEC-Mechanical Group. These loads were used to vali-date the design of safety-related piping systems. These efforts were necessary to address the issue of Subappendix A19. The fluid transient loads developed >

by SWEC-PSAS for saf ety-related piping are summarized in Table 5-2.

The fluid transient loads used for CPSES design validation process are docu-mented as specified in CPPP-10 (Reference 21). Criteria for evaluation of the piping system responses due to fluid transient loads are described in CPPP-7.

SWEC-Civil / Structural Group The SWEC-Civil / Structural Group has provided validated seismic Amplified Response Spectra (ARS), as discussed in the Civil / Structural Project Status Report (PSR) (Reference 63).

5.1.2.2 Pipe Stress Analysis Stress analysis of piping computes the responses (such as pipe stresses, load-ing on pipe supports, valve accelerations, and equipment nozzle loads) of a piping analytical model under the specified loading combinations (such as loads from deadweight, thermal, pressure, seismic, fluid transients, and Loss of Coolant Accident [LOCA)). In Unit 1 and Common, there are 384 large bore Seis-mic Category I and Seismic Category II pipe stress analysis packages with ap-proximately 12,020 pipe supports.

SWEC-PSAS has validated 341 ASME Section III Code Class 2 and 3 (Seismic Cate-gory I) and 16 high energy Seismic Category II pipe stress analysis packages.

TEssential systems and components are required to shut down the reactor and mitigate the consequences of a postulated piping failure, without offsite power. ,

l O 5-7 i - - - _ _________o

p Westinghouse validated the other 30 ASME Section III Code Class 1 (Seismic  !

Category I) pipe stress analysis packages, including the continuations of Class 2 and nonsafety-related piping within the pipe stress analysis package boundary. The pipe stress validation flow chart is shown schematically in Figure 5.3.

SWEC-PSAS Piping and Pipe Support System Review Prior to the initiation of the pipe stress analysis, each pipe stress analysis package, including the associated pipe supports, was jointly reviewed as a sys-tem by the pipe stress and pipe support engineers. The purposes of this review were to establish the piping physical configuration, to determine the location and orientation of the pipe supports with respect to the piping configuration, to evaluate the appropriateness of support types, and to identify areas of pip-ing or pipe support designs which may require special modeling techniques to account for the interactions between the pipe and the pipe supports.

SWEC-PSAS reviewed the pipe support drawings and support location drawings to determine whether the existing supporting system was appropriate and could per-form its safety-related function. SWEC-PSAS reviewed the pipe support drawings to determine the appropriate stiffness values for the input to the pipe stress analysis. The piping and pipe support system review also determined whether certain snubbers or other supports should be considered for elimination and whether additional pipe support optimization should be performed.

The results of this review were documented as a separate piping system O review / stiffness assessment calculation for each pipe stress analysis package, V which was used as design input for the pipe stress analysis. By the incorpo-ration of this review into the validation process, SWEC-PSAS has assured that an integrated process, with consistent criteria for both pipe stress analysis and pipe support design, was used.

Piping Analytical Model The first step in the pipe stress analysis is the formation of the pipe stress isometric drawings and mathematical models, which are developed by using the input information shown in Table 5-1, in conjunction with the results of the Piping and Pipe Support System Review.

The mathematical model analytically describes the piping configuration, mass, and boundary conditions. Piping mass is considered, including the applicable pipe support mass that affects the dynamic responses. Eccentric masses such as valve operators also are accounted for in the pipe stress analytical model.

Sufficient mass points are included to assure that all significant dynamic modes are represented. Appropriate representation of pipe support stiffness from the piping and pipe support system review is included.

Static and dynamic piping analyses were performed using the computer program NUPIPE-SW (Reference 24). The computer program output consists of pipe stress-es, displacements, valve accelerations, and interface loadings (e.g. , loadings ,

at pipe supports and equipment nozzles). This output was used to qualify the l D

5-8 1

piping,. pipe supports, and related components in accordance with the applicable codes and licensing commitments as specified in the governing Design Basis Doc-uments (DBDs).

Static _ analysis was used for deadweight, thermal, and anchor movement loading cases. The time-history analysis method2 was used for fluid transient loading cases, and the response spectrum analysis method2 was used for seismic loading cases. Modal contributions above the cutoff frequency in the response spectrum method analyses were addressed by an analytical technique in accordance with NUFr /CR-1161 (Reference 25). This technique, which incorporated the resolu-tion for the issues in Subappendix A18, assures that high frequency dynamic responses are included in the response spectrum analysis.

Based on the mathematical model and specified inputs, the computerized pipe stress analysis validates the following: the piping pressure boundary integri-ty, the piping system structural adequacy, and that maximum calculated stresses are within the specified Code allowables.

Additional results (other than the computed pipe stresses) that were generated from the computerized pipe stress analysis and transmitted to other interfacing disciplines for acceptance (see Figure 5-3), are summarized as follows:

Pipe Stress Analysis Results

1. Pipe support loads

2. Equipment nozzle loads

3. Containment penetration loads

4. Expansion joint movements

5. Valve accelerations ,

6. Valve operator support loads

7. Valve nozzle loads

8. Flange loads l 9. Pipe movements at wall or floor sleeves

! 10. Instrument root valve movements '

11. Pipe movements at branch lines

12. Pipe movements at pipe rupture restraints

13. Stress levels for pipe break / crack evaluations i i

Transmittal of Pipe Stress Analysis Results Package

]j Following completion of each pipe stress calculation, a results package that l contains a summary of pipe stress analysis results was compiled and distributed  !

to the SWEC-PSAS Pipe Support Group and other interfacing disciplines as shown i l in Figure 5-2. The results package, consisting of information such as the l equipment nozzle loads and valve accelerations, was sent to other disciplines j

% Analytical technique used to determine the responses of structures to dynamic loads.

5-9

. - _ - - - _ -_ . _ - -__ .__-__________-____-_-__________a

for acceptance. The pipe support summary transmittal identifies supports re-

[,_ ' quiring modification and/or deletion and lists for each pipe support the sup-port function, orientation, loads, and movements.

Integral Welded Attachment Analysis A separate analysis was performed for each location on the piping which is fit-ted with an integrally welded pipe support attachment to assure that the local piping stress is within the allowable stress limit. For Integral Welded At-tachments (IWAs) that could not be validated by the standard methods used by SWEC-PSAS for typical lug and trunnion configurations, the validation was based on finite element analysis techniques for the specific support, comparison to a similar specific support analysis, or comparison to a parametric finite element analysis study.

Pipe Break / Crack Analysis As part of the CPSES licensing commitments, the locations of the postulated high energy line breaks (HELBs) and moderate energy line cracks (MELCs) have been evaluated and assessed using the validated results of SWEC-PSAS pipe stress analysis. Piping stresses, including the local pipe stress from Inte-grally Welded Attachment (IWA) pipe supports, were reviewed to postulate break and crack locations in accordance with SWEC-PSAS Procedure CPPP-20 (Refer-ence 65). New mandatory break and crack postulation points were compared to previous locations, and the results were forwarded to the Ebasco Services In-corporated (Ebasco) - System Interaction Group to determine the impact. This s impact may include elimination or addition of pipe rupture restraints or jet

() impingement shields, jet impingement system interaction studies, or reanalysis of the pipe stress if the consequences of the new postulated break locations are unacceptable. The evaluation results from System Interaction Group are described in the Mechanical Project Status Report (PSR).

Piping and Pipe Supports Attached to Secondary Walls Special pipe stress analyses were performed in accordance with SWEC-PSAS Proce-dure CPPP-35 (Reference 59) to validate supports / penetrations that have been identified as being attached to a secondary wall.

5.1.2.3 Pipe Support Analysis Based on the pipe support loads from the SWEC and Westinghouse stress analyses results (see Figures 5-3 and 5-4), individual calculations for all Jarge bore pipe supports were prepared to assure code compliance with the design criteria.

The pipe support validation process is shown schematically in Figure 5-4 and can be summarized as a process whereby the support analysis in conjunction with required modifications provide the final validation of the pipe support design.

Pipe support analysis results are distributed to the interfacing organizations for acceptance as shown in Figure 5-4. The validated pipe support calculations and drawings are distributed and filed in accordance with project procedures and are included within each Piping - Design Validation Package (DVP).

N/ m 5-10

L The CPSES Unit 1 and Common pipe supports can be categorized into three types j O)

\~/

as follows:

1. Standard Component . Supports - Struts, spring hangers, and snubbers l

2. Structural Frame Supports Including supports for multiple pipes

3. Integrally Welded Attachment (IWA) Supports - Trunnions and' lugs Validation of these pipe support types is described below.

Standard Component Supports Standard component supports were evaluated to assure that they are suitable to perform their design function. Loads from the pipe stress analysis were com-pared with the - manufacturer's standard component support capacities. In addi-tion, 'the relative displacements under all specified load conditions were evaluated to validate the displacement ranges and swing angles of standard components.

Structural Frame Supports Frame type supports were validated by using hand calculations with ' standard structural analysis methods for simple designs or by computer analysis using STRUDL, STRUDAT, and SANDUL computer programs (described in CPPP-7) for more complex designs. In addition to validating the adequacy of local stresses in the pipe, the validation included the evaluation of:

• Member stress versus applicable stress allowables

• Reactions at support joints, including local stress effects on tube steel members

• Weld adequacy at welded joints

• Adequacy of bolted connections, including washer plate design and local stress effects on tube steel members

• Adequacy of concrete anchors and base plates

• Adequacy of clearances between piping and the frame Special Pipe Support Frame Analysis Two special groups of pipe support frames, (i) the wall-to-wall and floor-to-ceiling supports and (ii) corner supports, required special analysis to address the effects of differential building movement at the support attachment loca-tions to the building and for restrained thermal expansion of the wall-to-wall l and floor-to-ceiling supportt.. These designs are validated in accordance with the criteria contained in Attachment 4-19 of CPPP-7 in resolution of the exter-p nal issue described in Subappendix A3.

5-11 I

l

~

Integral Welded Attachment Analysis

((,,)/ A separate analysis was performed for each location on the piping with an inte-grally welded pipe support attachment to assure that the local piping stresses and support member stresses are within the applicable stress allowables. The piping local stress is discussed in Section 5.1.2.2.

5.1.2.4 Validation of Seismic Category II Large Bore Piping and Pipe Supports Over Seismic Category I Equipment I

SWEC-PSAS developed a Field Verification Method (FVM) CPE-SWEC-FVM-PS-82 l (Reference 52) to validate the integrity of seismic Category II piping and pip, supports in accordance with CPPP-30 (Reference 56). The purpose of this vali-dation process is to provide additional assurance by engineering walkdown and evaluation that during or after a seismic event, Seismic Category II piping systems will not fall and damage nearby Seismic Category I systems, structures, or components. This Field Verification Method (FVM) specifies the engineering field walkdowns necessary to assure that the as-built Seismic Category II pip-ing and pipe supports are in compliance with the acceptance criteria. A de-tailed discussion of this validation process is contained in Section 5.1.3.1.

5.1.2.5 SWEC-PSAS Clearance Walkdowns SWEC-PSAS developed a Field Verification Method (FVM) CPE-SWEC-FVM-PS-80 (Reference 50) to assure that sufficient clearance exists around validated pip-ing in accordance with SWEC-PSAS Project Procedure CPPP-22 (Reference 32).

Clearance is required to permit those anticipated piping displacements that S

could occur under plant operating conditions without any impediment to those

.\'-} displacements. Impediment is defined as any structure, system, or component (e.g., pipe, conduit, cable tray, equipment) that encroaches on the envelope of anticipated pipe displacement. A detailed discussion of this validation pro-cess is contained in Section 5.1.3.1.

5.1.2.6 Testing The CPSES preoperational and startup testing program provides assurance that piping systems, components, supports, and related structures have been adequately designed and installed. The correctness or conservatism of assump-tions made in predicting plant responses is validated by analyzing data ob-tained in a controlled testing environment.

The testing includes verification by observation and measurement (as appropri-ate) to assure that movement, vibration, and expansion of piping and components are acceptable for:

• ASME Section III Code Class 1, 2, and 3 piping systems.

• Other nonsafety-related high energy piping systems inside seismic Category I structures whose failure could reduce the functioning of any seismic Category I structure, system, or component.

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• Seismic Category I portions of moderate energy piping systems located outside the containment.

The testing program consists of the following categories:

Vibration Testing The CPSES vibration testing program is set forth in SWEC-PSAS Procedure CPPP-25 (Reference 57). This program follows the guidelines of NRC Regu-latory Guide 1.68 (Reference 82) and ANSI /ASME Standard OM-3 (Refer-ence 27) for steady state and transient vibration testing of piping systems. Piping systems are classified as Vibration Monitoring Group (VMG) VMG-1, VMG-2, or VMG-3, as defined in Reference 27. Piping systems which have no potential vibration problems are classified as VMG-3. If unexpected vibrations are observed during testing, additional inspections are performed to determine the degree of the problem and the resolution.

If a piping system is identified as posing a potential vibration problem, the affected portion of the system is classified as Vibration Monitoring Group 2 (VMG-2). This piping will be instrumented during testing to pro-vide a means for ascertaining the maximum vibration response.

Piping systems which exhibit a response not characterized by simple piping vibration modes , and piping systems for which the methods of Vibration Monitoring Group 2 (VMG-2) and Vibration Monitoring Group 3 (VMG-3) are not applicable, are classified as Vibration Monitoring Group 1 (VMG-1).

In these cases, rnore refined monitoring methods are utilized during b testing.

U All personnel who perform pipe vibration observations and measurements receive training and must pass a written certification examination (Reference 53).

The vibration data is analyzed subsequent to collection. Transient vibra-tiori test data which does. not meet the acceptance criteria established by l CPPP-25 must be referred to SWEC-PSAS for further analysis and resolution. l When appropriate, corrective action is implemented and retesting is l conducted to verify final acceptance. j For steady-state pipe vibration, if vibration can be visually observed, then vibration measurements are taken. When the measured peak-to-peak pipe velocity exceeds the acceptance criteria, displacement measurements are obtained and compared to calculated allowable values. If the system steady-state displacement exceeds the calculated allowable values, correc-tive action will be implemented and appropriate retesting will be conduct-ed to verify final acceptance. j Thermal Expansion Testing l As part of the piping and pipe support validation program, SWEC-PSAS has j reviewed the impact of analysis and modification on thermal expansion

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tests (TET). Systems or portions of systems which require testing have been identified.

A U SWEC-PSAS Procedure CPPP-24 (Reference 66) sets forth the methods for identifying piping for thermal expansion tests, for identifying the loca-tions and the supports to be monitored, for establishing acceptance crite-ria, for reconciling results, and for recommending modifications to correct discrepancies. Upon completion of all thermal expansion tests, an engineering report will be prepared summarizing the results.

In summary, the CPSES piping and pipe support validation program encompasses appropriate field testing. Rigorous requirements for evaluating and document-ing piping systems under static, dynamic, steady-state, and transient condi-tions are set forth in SWEC-PSAS procedures. The results of field testing will provide physical confirmation that large bore piping and pipe support design and installation comply with the design criteria.

5.1.2.7 Final Reconciliation of Large Bore Piping and Pipe Supports The purpose of final reconciliation is to resolve and incorporate pipe stress and pipe support analysis results (see Figure 1-1) with the final design input and as-built configuration. The final reconciliation process is conducted in j accordance with SWEC-PSAS Procedure CPPP-23, Pipe Stress / Pipe Support Reconcil-iation Procedure (Reference 29). The final reconciliation or large bore piping and pipe supports incorporates the following:

The Post-Construction Hardware Validation Program (PCHVP) results which provide the as-built large bore piping and pipe support config-(V) urations (see Section 5.1.3).

Resolution of the open items in NRC Staff positions in Supplementary Safety Evaluation Reports (SSERs) as described in Subappendixes A36, A37, and A38.

Resolution of the piping-related Comanche Peak Response Team (CPRT) {

issue-specific action plans (ISAPs) and external issues. '

Final reconciliation also includes confirmation that the interfacing organiza-tions have accepted the SWEC-PSAS results as compatible with their validated design. Interfacing organizations receive results as described below and in Figure 5-2:

• SWEC-Mechanical Group - Required reflective insulation removal at sleeves, penetrations, or frame supports; expansion joint movements.

Ebasco System Interaction Group - Postulated pipe break locations; }

pipe movements at pipe rupture restraint locations  ;

Westinghouse - Results of ASME Section III Code Class 1 pipe supports I validation, loads imposed by SWEC-PSAS analyzed piping on ASME Sec- I tion III Code Class 1 piping, support reaction loads on Westinghouse-O

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designed equipment supports, and valve accelerations and equipment nozzle loads for Westinghouse-supplied valves and equipment. ,

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• SWEC-Civil / Structural Group - Structural interface reaction loads, including penetration loads, load patterns on embedments.

• Impell Equipment Qualification Group - Valve nozzle loads, valve ac-celebrations and valve operator support requirements, and pipe move-ments at sealed sleeves, j

• SWEC-Instrument and Control Group - Root valve movements for instru-ment systems.

In addition, the validated piping weld locations are provided to TU Electric .

for the identification of locations for preservice and inservice inspections. '

Closure of open items, observations, and deviations related to large bore pip-ing and pipe supports that were identified by TU Electric Quality Assurance, SWEC Engineering Assurance, and Engineering Functional Evaluation (EFE) are resolved prior to the completion of this reconciliation phase. Open items from the NRC Notices of Violation (NOVs), and the TU Electric Significant Deficiency l Analysis Reports (SDARs) (10CFR50.55[e]) are also resolved during the final reconciliation. .

Each pipe stress analysis package, at the conclusion of final reconciliation, <

will be compiled into the Piping - Design Validation Package (DVP) as described in Section 3.0 and SWEC-PSAS Procedure CPPP-23. The Piping-DVP consists of the pipe ' stress analysis calculations, the hanger location drawings (identifying i the. pipe support locations and stress problem boundaries), the pipe supports  ;

calculations and drawings (including the design changes and as-built modifica-tions) within its pipe stress analysis package boundary, and related interface transmittals.

5.1.3 Post-Construction Hardware Validation Program (PCHVP)

The Post-Construction Hardware Validation Program (PCHVP) (Reference 48) is the portion of TU Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware. The Post-Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 5-5.

I The input to the Post-Construction Hardware Validation Program (PCHVP) is con- 1 tained in the installation specifications. The installation specifications l implement the licensing commitments and design criteria of the Design Basis Documents (DBDs), which were developed during the Corrective Action Program (CAP) Design Validation process.

Final acceptance inspection requirements identified in the validated installa-tion specifications were used to develop the Post-Construction Hardware Valida-

[ tion Program (PCHVP) attribute matrix. This matrix is a complete set of final acceptance attributes identified for installed hardware. The Post-Construction 5-15 l

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Hardware Validation Program (PCHVP), by either physical validations or through

[,, an engineering evaluation methodology, assures that each of the attributes de-fined in the attribute matrix is validated.

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

The Post-Construction Hardware Validation Program (PCHVP) engineering evalua-tion depicted in Figure 5-5 is procedurally controlled to guide the Corrective Action Program (CAP) responsible engineer through the evaluation of each item on the attribute matrix to be dispositioned by the engineering evaluation meth-od. Dispositions of each attribute will be clearly documented. If the techni-cal disposition of the final acceptance attribute is "not acceptable" or the attribute cannot be dispositioned based on available information, an alternate plan consisting of additional evaluations, testing, inspections /walkdowns or modification 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 this evaluation. A major component of the Comanche Peak Response Team (CPRT) program has been the inspection of a comprehensive, random sample of existing hardware using an independently derived set of inspection attributes. The inspection was performed and the results evaluated by third party personnel in accordance with Appendix E to the Comanche Peak Response g Team (CPRT) Program Plan (Reference 33). The scope of the inspection covered g' the installed safety-related hardware by segregating the hardware into homoge-neous populations (by virtue of the work activities which produced the finished product). Samples of these populations were inspected to provide reasonable assurance of hardware acceptability in accordance with Appendix D to the Comanche Peak Response Team (CPRT) Program Plan.

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

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

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

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

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b. Design va lidation resulted in a change to design or to hardware final acceptsace attribute that is more stringent than the original accep-s_/ tance attribute, or Comanche Peak Response Team (CPRT) did not in-spect the attribute.

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

If the Comanche Peak Response Team (CPRT) had no recommendations and Items b or e above do not apply, the attribute under consideration will be accepted. This conclusion is justified by the comprehensive coverage of the Comanche Peak Re-sponse Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective. The at-tribute matrix is then updated to indicate that neither the engineering walk-down nor quality control inspection of the attribute is necessary. A completed evaluation package is prepared and forwarded to the Comanche Peak Engineering (CPE) organization for concurrence. The evaluation package becomes part of the Design Validation Package (DVP) after Comanche Peak Engineering (CPE) concur- l rence is obtained. i l

If any of the three statements are true, it is assumed that the final accep-tance 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 val-

[s\--) idation of the item's acceptability will be performed and documented in accordance with an approved Field Verification Method (FVM).

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

After completing the attribute accessibility review, the responsible engi- ,

neer will update the attribute matrix as necessary to reflect the results 1 of that review.

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

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

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

• Comanche Peak Response Team (CPRT) and external issues l

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• Construction practices 0)

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• .' Quality records

• Test results

• Audit reports

• Authorized Nuclear Inspector (ANI) records

• Surveillance reports

• NCRs, DRs, SDARs, and CARS

• Inspections conducted to date

• Results of Third Party reviews

• Purchasing documents

• Construction packages

• ' Hardware receipt inspections Af ter compill the data identified as pertinent- to the attribute, _ the technical disposition will be performed. The actual steps and sequence of actions required for each technical disposition will differ; however, the tangible results from each technical disposition will . be consistent.

These results will include at a minimum:

a. A written description of the attribute,

b. A written justification by the Corrective . Action Program (CAP) re-sponsible engineer for acceptance of the attribute.

c. A written explanation of the logic utilized to conclude that the at-tribute need not be field validated.

d. A chronology demonstrating that the attribute has not been signifi-cantly altered by redesign.

e. All documents viewed to support the disposition.

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

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

dation Package (DVP). If the Corrective Action Program (CAP) responsible engineer determines that the data reviewed does not provide evidence of r the attribute's acceptability, the documentation will explain why the at-I 5-18 1

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L tribute cannot - be accepted and recommend an alternate course of action.

The alternate course of action may take various forms such as making the

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attribute accessible and inspecting it, or testing to support the at-tribute's acceptability. This alternate plan, after approval by Comanche Peak ' Engineering (CPE), will be implemented to validate the attribute.

'In summary, the Post-Construction Hardware Validation Program (PCHVP) is a com-prehensive process by . which each attribute in the PCHVP attribute matrix = is validated to the validated design. The TU Electric Technical Audit Program l (TAP) will audit the Post-Construction Hardware Validation Program (PCHVP).

This audit program is complemented by the Engineering Functional Evaluation being. performed by an independent team comprised of Stone & Webster, Impell, p and Ebasco engineering personnel working under the Stone & Webster QA Program

[ and subject to oversight directed by the Comanche Peak Fesponse Team's (CPRT)

Senior Review Team. The Post-Construction Hardware Valiuation Program (PCHVP) will provide reasonable assurance that the validated design has been imple-mented for safety-related hardware.

l 'SWEC-PSAS prepared Post-Construction Hardware Validation Program (PCHVP) imple-mentation procedures for large bore piping and pipe supports. The hardware validation process includes modifications, whenever necessary, to bring the piping and pipe supports i .to compliance with the validated design. The at-tributes contained within the Post-Construction Hardware Validation Program (PCHVP) Attribute Matrix for piping and pipe supports incorporate the recom-mended corrective actions in the CPRT-QOC Issue-Specific Action Plan, ISAP-VII.c Results Report (Reference 36), thus resolving the hardware-related l issues (see Subappendix A39). The complete tabulation of piping-related in-

[ spection attributes to address CPRT-QOC recommendations is presented in

' Table 5-3.

5.1.3.1 Post-Constructi in Hardware Validation Program (PCHVP) Procedures SWEC-PSAS developed procedures to validate that the as-built large bore piping and pipe supports are in compliance with the validated design procedures listed in Table 5-7. These procedures are designated as Field Verification Methods (FVMs) and are described below.

FVM-81, Piping and Pipe Supports Inspection and Hardware Validation SWEC-PSAS developed the Field Verification Method (FVM) CPE-SWEC-FVM-PS-81 (Reference 51) to coordinate the Unit I and Common piping and pipe support in-spection validation activities.

These piping inspections are performed and documented by Quality Control (QC) personnel to assure that applicable inspection attributes are acceptable. The piping inspection attributes are as below:

Equipment and piping configuration Piping wall thickness at shop / field bends 5-19

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Radial weld shrinkage at stainless steel piping joints 9 Equipment anchoring-  !

_ (V Remote valve operators Branch connections All pressure boundary items installation / base metal defects l- Valve orientations l ' Pipe / sleeve details l Permanent pipe support installation (no temporary or voided supports) l Verify location (span) dimensions / tolerances Applicable dielectric insulating sleeves over bolts / studs Linear dimensions' of piping segments and in-line components The hardware validation of pipe supports assures that the removable items ou a pipe support are installed as required by the design documentation. The hard-ware validaticn is implemented by Quality Control (QC) personnel in compliance with the validated support drawing. Quality Control personnel verify and docu-ment that all applicable hardware attributes listed on the hardware validation checklists are acceptable. The following pipe support hardware validation checklists are used, as applicable:

Adjacent Weld Checklist Bolted Connection Checklist Hilti Bolt Checklist Pipe Clamp Checklist.

Richmond Insert Checklist Snubber Checklist m Support Checklist Sway Strut Checklist Through Bolt /Eubedded Bolt Checklist U-Bolt / Bolted U-Guide Checklist Variable / Constant Spring Checklist In addition to the hardware validation pipe support inspections, Quality Con- l trol (QC) personnel also conduct inspections for pipe support configuration l attributes as below: l Material acceptability ,

Support configuration compliance with validated design drawing, '

including dimensione.

Support overhang length / tolerance Support projection length / tolerance Sway' strut / snubber pin-to pin dimension / tolerance Alignment and circumferential deviation of shear lugs Hilti bolt size /embedment Weld length of <tractural member on base plate l Welded connection in accordance with validated drawing Edge distance'itr structural members and base plates Slope of bolted part with bolt head or nut Shim size / weld O

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._ FVM-080, Clearance Walkdowns

.(V SWEC-PSAS developed the Field Verification Method (FVM) CPE-SWEC-FVM-PS-80 to assure that sufficient clearance sxists around the validated piping. Clearance is required to permit those anticipated piping displacements that could occur {

under plant operating conditions without any impediment to those displacements. f An impediment is defined as any structure, pipe, conduit, cable tray, equip- I ment, etc, that encroaches on the envelope of anticipated pipe displacement. I This field verification effort is performed by the SWEC-PSAS engineering per-sonnel. SWEC-PSAS has established clearance criteria and is responsible for training the clearance walkdown teams, evaluating clearance problems, and issu-ing design changes to correct any clearance violations, as follows:

1. SWEC-PSAS Site Engineering Group shall establish and train the clear-ance walkdown teams, consisting of a stress engineer, a pipe support engineer, and others as required.

2. Displacement and clearance criteria established by other disciplines will be used in the walkdown (e.g. , conduit displacements, equipment displacements, proximity of heat sources), as applicable.

3. A table will identify each pipe stress analysis package and the asso-ciated maximum displacements for other components, such as equipment, conduit, cable trays, piping, and pipe supports.

p 4. An engineering walkdown is being performed for each pipe stress anal-('j ysis package to validate the as-built clearances acceptance criteria.

A Clearance Evaluation Form shall be completed for each violation of the clearance criteria.

Quality Control (QC) personnel will periodically accompany the SWEC-PSAS engi-neering walkdown teams and perform surveillance inspections to assure compli-ance with the Field Verification Methods (FVMs).

FVM-82, Validation of Seismic Category II Large Bore Piping and Pipe Supports Over Seismic Category I Equipment SWEC-PSAS developed the Field Verification Method (FVM) CPE-SWEC-FVM-PS-82 to validate the integrity of seismic Category II piping and pipe supports over Seismic Category I equipment as specified in CPPP-30. The purpose of this Field Verification Method (FVM) is to assure, by engineering inspection and evaluation, that during or after a seismic event, the Seismic Category II pip-ing systems will not fall and damage nearby Seismic Category I systems, struc-tures, or components. This Field Verification Method (FVM) specifies the engineering field walkdowns required to assure that the installation of the piping and pipe supports is in compliance with the validated design.

The field verification effort is performed by SWEC-PSAS engineering personnel using the acceptance criteria for the configuration of the supports and the tolerances specified in Piping Erection Specification No. 2323-MS-100 (Refer-5-21

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ence 38). Tables 5-6 and 5-8 contain the piping and pipe supports checklists for this field verification effort.

Quality Control (QC) personnel will periodically accompany the SWEC-PSAS engi-neering walkdown teams and perform surveillance inspections to assure compli-ance with the Field Verification Methods (FVMs). ,

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I 5.2 RESLLTS

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k% This section discusses the results of the SWEC-PSAS Large Bore Pipe Stress and Pipe Support Corrective Action Program (CAP).

5.2.1 Pipe Stress Analysis Results

. The pipe stress analysis packages validated by SWEC-PSAS are within the allow-able stress criteria of the ASME Section III Code.

The pipe stress analysis results are described below.

• Pipe Support Optimization (As a Result of Pipe Stress Design Valida-tion Process)

A total of 583 snubber supports were deleted through the pipe support optimization process. Approximately 300 additional snubber supports were converted to rigid supports, bringing the total number of snub-bers eliminated for Unit 1 and Common to 1,182 (some snubber supports contain more than one snubber). This large reduction of snubbers (approximately 50 percent of the original total) is part of the over-all plant improvement incorporated into the SWEC-PSAS validation ef-fort. .It represents a significant improvement in plant reliability and reduction in inservice inspection, worker radiation exposure, and cost of maintenance.

• Integral Welded Attachments (IWAs)

A total of 1,166 Integral Welded Attachments (IWAs) in large bore pipe stress analysis packages within Unit 1 and Common were analyzed, and 309 require modification.

• Pipe Rupture Analysis .

1 High energy piping arrangement in CPSES Unit 1 and Common utilized the design criteria of postulated pipe ruptures protection by physi-cal separation. Consequently, of the 384 large bore pipe stress packages, pipe rupture analyses are required for 68 high energy and 49 moderate energy large bore pipe stress analysis packages. These stress analyses were analyzed with the following results:

High Energy Line Break (HELB) Postulation - A total of 37 manda-tory postulated intermediate breaks were identified.

Moderate Energy Line Crack (MELC) Postulation - A total of 91 mandatory postulated cracks were identified.

• Piping and Pipe Supports Attached to Secondary Walls The piping and pipe support validation procedure for secondary wall displacements, CPPP-35 is used to qualify 377 supports / penetrations i that have been identified as being attached to a secondary wall.

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l Approximately 83 percent of these supports comply with the flexibil-

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( ity criteria of CPPP-35, and no further evaluation is required.

b/ Those supports which did not comply with the flexibility criteria affect 33 large bore pipe stress analysis packages in Unit 1 and Com-J mon. TL.is validation requires the modifications of 10 pipe supports '

that spanned secondary and primary walls within these large bore pipe stress analysis packages. l

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5.2.2 Pipe Support Analysis Re.sults The Pipe Support Analyses validated that approximately 12,020 pipe supports within the 384 large bore pipe stress analysis packages comply with the design criteria. During the SWEC-PSAS pipe support validation process, required sup-port modifications were identified. The pipe support modifications are catego-rized as follows:

1. Prudent - Supports in this category may have been technically accept-able; however, more time and expense would have been involved in the detailed analysis than that required to physically modify the support and qualify the modification.

2. Recent Industry Practice - Modifications implemented to eliminate snubbers to enhance plant maintainability, reduce inservice inspec-tion, and minimize worker radiation exposure during operating plant conditions.

3. Adjustment - Minor modifications (such as retorquing or shimming) p)

(" implemented to meet installation criteria contained in the resolution of the CPRT and external issues.

4. Cumulative Ef fects - Modifications that are required due to the com-bined effect of the previous issues.

From the results of the stress analysis, 1,452 supports were deleted and 186 supports were added (including the addition of 20 pipe anchors). The result of SWEC-PSAS pipe stress and support analysis has identified a total of 5,621 sup-ports that require modification (including deletions and additions). Table 5-4 contains a description of the types of modifications by the above categories.

The plant modifications resulting from the Large Bore Pipe Stress and Support Corrective Action Program (CAP) has been determined by TU Electric to be re-portable under the provisions of 10CFR50.55(e). TU Electric reported to the NRC the large bore piping modifications in the Significant Deviation Analysis Report SDAR-CP-86-36 (see Subappendix B2).

5.2.2.1 Pipe Support Modifications Identified Prior to Pipe Stress Analysis The following types of pipe supports were identified for modification prior to

! stress analysis as a result of the resolution of the CPRT and external issues.

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i Cinched U-Bolts on Single Struts or Snubbers To' avoid lengthy detailed stress evaluations for the pipe, U-bolt, and crosspiece, . all 353 cinched U-bolts on single strut or snubber large bore pipe supports for Unit 1 and Common are identified for elimination or modification.

Cinched U-Bolt Trapeze Supports Of the 693 cinched U-bolt trapeze supports in Unit 1 and Common large bore pipe supports, 266 were identified for deletion, and the remain-ing 427 were identified for modification. Table 5-5 summarizes the types of modifications identified for the cinched U-bolt trapeze

. supports.

Potentially Unstable Supports In addition to the cinched U-bolt supports, both single strut and trapeze, ' Project Procedure CPPP-7, Attachment 4-9, requires that po-tentially unstable supports be modified. Such configurations identi-fied are trapeze supports with zero clearance box frames, spring hangers on trapeze, and spring hangers without a U-bolt. These sup-ports are redesigned or eliminated during the validation process.

• Clearance.on Rigid Supports The ' clearance between the pipe and the restraining surfaces for rigid -

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restraints such as frames, straps, uncinched U-bolts and lugs is in-spected and adjucted where required to meet the clearance require-ments specified in Project Procedure CPPP-7, Attachment 4-11.

• Uncinched U-Bolts on Rigid Frames Uncinched U-bolts on rigid frames for pipe sizes 6 in. and smaller were analyzed and designed as two-way restraints in accordance with Proj ect Procedure CPPP-7, Attachment 4-3. Where they existed on pipes 8 in, nominal size and larger, they were identified for elimi-nation or replacement by a strap or a box frame, as appropriate, dur-ing the validation process.

• Single Tube Steel with Richmond Insert Bolts Supports with single tube steel Richmond insert connections loaded primarily in shear and/or torsion are modified by the addition of

" outriggers" to increase the rigidity of the support.

• Long Tube Steel with Richmond Insert Bolts Pipe supports with long tube steel anchored by Richmond inserts and I subject to LOCA temperature effects are modified by limiting the tube 5-25 i

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steel length. These supports were primarily "run together" multiple 7-s .

pipe supports.

V i 5.2.2.2 Special Pipe Support Frame Results Special analyses were required for certain supports to evaluate the effect of differential movement of the attachment points and/or restrained thermal expansion.

• Wall-to-Wall and Floor-to-Ceiling Supports Twenty-seven well-to-wall and floor-to-ceiling pipe supports were identified in large bore pipe stress analysis packages within CPSES Unit I and Common. These supports were validated by meeting the re-quirements specified in Table 4.7.2-1 and Attachment 4-19 of SWEC-PSAS Procedure CPPP-7, and 19 required modification as a result of differential movement of attachment points and restrained thermal expansion.

• Corner Supports SWEC-PSAS Project Memorandum PM-39 (Reference 54) identifies the pro-cedure for the identification, evaluation, and disposition of corner supports with wall-to-floor or wall-to-ceiling attachments encoun-tered during the validation ef fort, with 221 corner supports identi-fied in the large bore pipe stress analysis packages within Unit I r~' and Common. The design of all corner supports on CPSES Unit 1 and

( Common has been validated by meeting the requirements specified in Table 4.7.2-1 and Attachment 4-19 of SWEC-PSAS Procedure CPPP-7, and no modifications were required as a result of differential building movements.

5.2.2.3 SWEC-PSAS As-Built Verification of Modifications SWEC-PSAS performs the as-built piping validation of the CPSES Unit 1 and Com-mon large bore piping and pipe support modifications in compliance with NRC I&E Bulletin 79-14. This process is conducted as part of the final reconciliation process described in Section 5.1.2.7 in accordance with SWEC-PSAS procedure CPSP-12 (Reference 37). The piping linear dimensions, elevations, valve orien-Lations, angles, wall and floor sleeve penetrations, and interconnecting equip-ment are validated. The modified pipe supports are validated to the as-built drawings, including configuration, mark number, dimensional location, function, angularity, and directions.

5.2.3 Post-Construction Hardware Validation Program (PCHVP) Results The Post-Construction Hardware Validation Program (PCHVP) is implemented through the verification of the hardware-related attributes described in

! Section 5.1.3 for the large bore piping and pipe supports in Unit I and Common.

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l g These field verifications listed below are in progress: {

• Field Verification Method (FVM) for hardware inspection / validation (CPE-SWEC-FVM-PS-081). To date, 2,877 pipe supports within the large {

bore pipe stress analysis packages have been validated to be in con- l formance with the acceptance criteria, l l

• Field Verification Method (FVM) for clearance walkdowns {

(CPE-SWEC-FVM-PS-080).

• Field Verification Method (FVM) for Seismic Category II large bore piping and pipe supports over Seismic Category I equipment (CPE-SWEC-FVM-PS-082),

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/^ 5.3 QUALITY ASSURANCE PROGRAM All activities of the Unit I and Common large bore piping and pipe support Cor-rective Action Program (CAP) were performed in accordance with SWEC's Quality .

Assurance (QA) program. This program is consistent with SWEC's Topical Report  !

SWSQAP 1-74A (Reference 20), Stone & Webster Standard Quality Assurance Pro-gram, which has been approved by the NRC.

In accordance with the Quality Assurance (QA) program, a project-specific QA program (Reference 6) including procedures covering the essentials of the l SWEC-PSAS validation process were developed. These SWEC-PSAS Project Proce-dures were distributed to all supervisory engineers and were readily available to SWEC-PSAS personnel. The issuance of design criteria, validation proce-dures, and major revisions of these documents was followed up with detailed  ;

training programs for applicable personnel. In particular, pipe stress and

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support engineers on the pr' -ct received training in the technical procedure (CPPP-7), and the design cow wl procedure (CPPP-6).

A Project Quality Assurance (QA) Manager, who is directly responsible to the SWEC Vice President of QA and has management experience in auditing and QA pro-gram procedure development for engineering activities, was assigned to the pro-ject in the earliest stages of project mobilization. This reporting respon-sibility assures independence of the Quality Assurance (QA) functions. The SWEC-PSAS Quality Assurance (QA) Manager has a staff of Engineering Assurance ,

(EA) engineers assigned to assist him in his duties. SWEC's EA Division is an integral part of SWEC's QA Program (Reference 20). These individuals provide assurance that the QA program properly addresses all project activities and

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assist SWEC-PSAS personnel to understand and properly implement the QA program.

To date, more than 164,000 man-hours have been expended by SWEC in activities directly attributable to the overall Project Quality Assurance program (i.e.,

training, procedure development, auditing, and the project QA Manager's staff).

The adequacy and implementation of this Quality Assurance program was exten-sively audited by SWEC's Engineering Assurance Division, SWEC's Quality Assur-ance Auditing Division (QAAD), TU Electric Technical Audit Program (TAP), and the NRC's Vendor Program Branch (VPB) and Office of Nuclear Reactor Regulation.

A total of 36 audits were performed by these organizations to date for both Units 1 and Common large bore piping and pipe supports Corrective Action Pro-gram (CAP) as follows:

SWEC - EA 22 SWEC - QAAD 1 t

5-28

,q TU Electric - TAP 4 12 l- NRC 1 The SWEC, NRC, and TU Electric Technical Audit Program (TAP) audits evaluated the technical adequacy of the engineering product (e.g., calculations, draw-ings, and specifications) and assessed the adequacy and implementation of the SWEC Quality Assurance Program. A summary of these audits is presented in Sections 5.3.1 and 5.3.2.

TU Electric conducted technical audits as part of the TU Electric Technical Audit Program (TAP). The details of calculations, drawings, and procedural compliance and technical interfaces were evaluated. These technical audits have resulted in eahtacements to the procedures and methods and thus contrib-uted to the overall quality of the CPSES large bore pipe and support design.

The NRC Staff performed surveillance on SWEC-PSAS validation process, includ-ing in-process reviews of SWEC-PSAS's progress and methods of resolving the generic technical issues and verification of the adequacy of SWEC-PSAS walk-downs. The NRC-VPB performed an audit of the SWEC-PSAS piping and pipe support Corrective Action Program (CAP).

A Third Party organization (Tenera, L.P.) was contracted by CPRT to overview the adequacy of SWEC-PSAS large bore piping and pipe support design methodology as discussed in Section 5.1.1. The Third Party coatluded that SWEC-PSAS's large bore pipe stress analysis and pipe support validatian program was compre-hensive and capable of resolving Comanche Peak Review Team (CPRT) and external

/ issues. This third party overview provides additional assurance that the CPSES

( large bore piping and pipe supports meet the licensing commitments.

In addition to these audits, TU Electric has initiated the independent Engi-neering Functional Evaluation (EFE) program to provide an overview of the tech-nical activities being conducted on the CPSES proj ect . The Engineering Functional Evaluation (EFE) team has audited the SWEC-PSAS performance since June 1987. The large bore piping and pipe supports design has been reviewei to assure consistency with validated input data and to assure outputs have been transferred to appropriate interfacing organizations.

l

(

Surveillance activities have been conducted by SWEC Engineering Assurance per-  !

sonnel to assure conformance to procedures and standards. Similar surveillance- l es are performed by the TU Electric Technical Audit Program (TAP).

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

1 i

O 5-29 l

l

I 1

6 These audits described above represent a very detailed and complete assessment of the following:

1. Adequacy of the Project Quality Assrrance program.

2. Implementation of the Quali <, aurance program. )

1

3. Technical adequacy of the design criteria and procedures.

4. Implementation of the design criteria and procedures.

These audits and surveillance identified instances in which some action was required to clarify or modify procedures to more clearly define some activi-ties, revice calculations to address an omission of clarifying statements or more properly address a situation, and provide additional training or project guidance to assure continued compliance with procedures. A timely and complete response was developed for every item identified throughout the audit process.

Whenever a question that suggests a need to improve any of these items was identified, the cause, extent of conditions, and any required corrective /

preventive actions were determined, properly documented, and implemented. Sub-sequent audits have verified that appropriate actions were take'n to address previously identified items and identified a trend of improved overall perfor-mance by SWEC-PSAS. No audit items which would result in questions of techni-  !

cal adequacy of SWEC-PSAS's overall validation program have been identified.

In addition to the audits and surveillance, a rigorous Quality Control (QC)

] inspection program is in place on the CPSES site. QC personnel are responsible

[V for performing inspection of attributes as delineated in the inspection pro-cedures before a particular installation is acceptable.

In summary, an appropriate level of attention has been given to the quality of activities; the Quality Assurance (QA) program is appropriate for the scope of work; project performance has been demonstrated to be in compliance with the QA program, and appropriate corrective and preventive actions were taken when-ever they were required.

5.3.1 Summary of SWEC Engineering Assurance (EA) Audits To date, SWEC EA has performed 22 audits of the SWEC-PSAS large bore piping and pipe support validation process. Each SWEC-PSAS project location has been au-dited at least three times. An average of five subjects were reviewed during each of these audits. The following list of audit subjects describes the depth of auditing that has been performed:

1. Adequacy of the SWEC-PSAS Design Procedures. l

2. Adequacy of the SWEC-PSAS Project Procedures.

l

3. ARS Data Conversion.

4. Calculations - Technical adequacy.

, 5-30 l

w _-__ i

1 l

4

5. Calculations - Documentation O

\,,/ 6. Compliance with project procedures.

7. Construction support activities. .q

8. Document Control. ,

i

9. Field walkdown activities.

10. Indoctrination and training.

11. Licensing activities.  ;

12. Records maintenance.

13. Maintenance of Project Procedure manuals.

14. Personnel qualification and experience verification.

15. System inputs to pipe stress and pipe support analyses.

A chronological tabulation of SWEC Engineering Assurance (EA) audits is pre-sented in Table 5-10. l 5.3.2 Summary of Audits by TU Electric-TAP, NRC-VBP, and SWEC-QAAD

() In addition to the SWEC Engineering Assurance (EA) Audits, the SWEC-PSAS was audited by TU Electric Quality Assurance (QA), NRC Vendor Program Branch (VPB),

and SWEC Quality Assurance Auditing Division (QAAD).

To date, TU Electric's Technical Audit Program (TAP) has performed 12 audits of the SWEC-PSAS. Each SWEC-PSAS location has been audited at least once. An average of nine (9) subjects were reviewed during each of these audits. These audits are essentially equivalent to the SWEC Engineering Assurance (EA) audits discussed in Section 5.3.1. Therefore, the list of audit subjects in Sec-tion 5.3.1 is representative for these audits. A chronological tabulation of the TU Electric Quality Assurance TAPS audits is presented in Table 5-11.

1 The NRC-Vendor Program Branch (VPB) performed one audit in mid-1986 of SWEC-PSAS validation process (Reference 31) and reviewed the following i activities:

ll

1. Design control (pipe stress and support analyses). l

2. Document Control (incoming and outgoing).

3. Procurement control.

4. Training. l l I

I

! l 5-31  ;

l l

I l

L-____---

5. Audits (SWEC-EA and TU Electric-TAP).

The SWEC Quality Assurance Auditing Division (QAAD) performed one audit of the SWEC-PSAS. This audit was performed t9 assess the Project Quality Assurance Manager's adherence to Corporate QA Program requirements, the adequacy of the Proj ect 's QA Program (CPPP-1), the Document Control Program, and the Records Management Program.

Oh U

n b 5-32 1

q 4 CORRECTIVE AND PREVENTIVE ACTION k ..IC-PSAS has developed technical and design control procedures and updated the design and installation / inspection specifications to implement the corrective actions resulting from the large bore piping and pipe supports Corrective Ac-tion Program (CAP). These procedures and specifications are identified within the Piping - Design Basis Documents (DBDs) which contain the bases for validat-ing the large bore piping and pipe supports in Unit 1 and Common. As a result of this effort, the Comanche Peak Steam Electric Station - Unit 1 and Common large bore piping systems and supports are validated as being capable of per-forming their safety-related functions.

This validation is documented in the drawings, calculations, and specifica-tions. This validated design documentation will be provided to TU Electric.

This validated design documentation can provide the basis for configuration control of CPSES large bore piping and pipe supports to facilitate operation, maintenance, and future modifications following issuance of an operating license.

At the completion of the validation, SWEC-PSAS will provide TU Electric Comanche Peak Engineering (CPE) with the complete set of drawings and calcula-tions, contained within the Large Bore Piping - Design Validation Packages (DVPs) for Unit 1 and Common. SWEC-PSAS procedures used for large bore piping and pipe supports validation will be provided to Comanche Peak Engineering (CPE). Implementation of these procedures by CPE assures that future CPSES large bore piping and pipe supports design is performed in accordance with the licensing commitments.

a Training for Comanche Peak Engineering (CPE) personnel will be provided by The training will cover background assumptions and the methodology SWEC-PSAS.

used in the validation of the piping and pipe support design. The importance of quality assurance will be stressed throughout the training program. l Practical experiente has been provided to Comanche Peak Engineering (CPE) engi-neers who have worked alongside SWEC-PSAS engineers during the ongoing valida-tion process. Experience gained by CPE engineers included changes in design documents, and familiarization with procedures followed and regulatory requirements.

TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from SWEC-PSAS to CPE. The program will provide for the identification of those tasks presently being performed by SWEC-PSAS which are to be transferred to CPE and the identification of all procedures, programs, training, and staffing j requirements. The program will be based upon three prerequisites: 1) the piping-related Corrective Action Program (CAP) effort to support plant com-pletion is finished for the particular task; 2) the Piping - Design Validation i Packages (DVPs) are complete; and 3) any required preventive action taken, as '

discussed in Appendix C, is complete.

i O 5-33 j

1

,1

This program will assure the transfer of complete design document and pro-cedures to Comanche Peak Engineering (CPE).

l l

l

\ l l

1

(

l I

O 5-34

FIGURE 5-1 i

O CORRECTIVE ACTION PROGRAM (CAP)

d FLOW CHART AND GOVERNING PROCEDURES LARGE BORE PIPING AND PIPE SUPPORTS l DESIGN VALIDATION CPPP.1 (REF 6) CPPP-28 (REF. 67)

CPPP.5 (R E F.14) CPPP 29 (REF. 77)

CPPP 6 (REF. 9) CPPP-30 (REF. 56)

CPPP.7 (REF. 8) CPPP-31 (REF. 30)

CPPP 18 (REF.17) CPPP-35 (REF. 59)

CPPP 19 (REF. 71) DBD CS 065 (REF.1)

CPPP.20 (REF. 65) DBD.CS 066 (REF.2)

CPPP 24 (REF. 66) DBD.CS 067 (REF. 3)

CPPP 25 (REF. 57) DBD.CS 069 (REF. 61)

SPEC. 2323 MS46A (REF. 44) DBD CS 070 (REF.62)

SPEC. 2323.MS200 A (REF. 41) t ISSUE MODIFICATIONS CPPP.6 (R EF. 9) CPSP 10 (REF. 73)

CPSP 14 (REF. 72) tO

\.J I f BUILD AND INSPECT l f POST CONSTRUCTION HARDWARE VALIDATION AS. BUILT INSPECTION (ECE 9.04 .04/ECE 9.04 .05) OF PlPING & PIPE (REF. 47/ 55) SUPPORTS FVM PS 080 (REF. 50) CP CPM 9.10 (REF 43) CP OAP 12.1 (REF. 34)

FVM PS 081 (REF. 51) CP. CPM 9.10 A (REF. 40) ECE.DC 7 (REF. 75)

FVM.PS 082 (REF. 52) AOP 11.2 (REF. 60) CPSP.12 (REF 37)

FVM St.040 (REF. 76) Ol OAP 11.1.28 (REF. 45)

CPPP 22 (REF.32) CP O AP 12.1 (REF. 34)

SPEC. 2323 MS-100 (REF. 38) CP AOP 12.1 (REF.12)

CPSP 12 (REF. 37)

I f FINAL RECONCILIATION J 7

CPPP.23 (REF. 29) CPPP 33 (REF. 68)

I f FINAL DESIGN L PIPING AND PIPE SUPPORTS DOCUMENTATION F COMPLETE CPPP 4 (REF. 69) C PS P.11 (R EF. 74)

CPPP.11 (REF. 70) cH47 544

1 J

1 O

O i l

FIGURE 5-2

, CORRECTIVE ACTION PROGRAM (CAP) TECHNICAL INTERFACES l LARGE BORE PIPING AND PIPE SUPPORTS f u ELECT AiC COMANCHE PE AN ENGINEERING C AP MANAGEMENT e M b e WELO LOC ATIONS poA PRE SE AVICE ANO HaSERVtCE WSPECf TONS tasPELL COAPORAT10N ESASCO I EQulPMENT QU AUFICAf TON GAOUP SYSTEM tNTER ACflON GAOUP e ALLOW ABLE V ALVE ACCELERAfroMS e V ALVE NOllts Att0W ARLE LOADS e &E ALEO STEEVE Au 0 WASTE MOVE ME N T S JE f IMPINGEMENT e e Pe"E SAE AR POStuLatt0N LOADS e PIPE MOVEMENTS Af PtPE AuPTual VALVE NOZ2LE LOADS e AESI# AaNT LOCA140NS V ALVE ACCELEAAfl0NS ANO e VALVE OPERATOR SUPPOAf AEOveAEMENTS PIPE MOVEMENT Af SE ALED SLEEVES e p

k e AEvid W AE SOLuf t0N OF e DESIGN REOueAEMENTS FOR WESTtN0nouSE SUPPLIED EsfEnseAL TECNeeC AL tSSUES 3 f V AL VE S/ E OutPME N T

• AEvtEW PROCE0uRE Asso e SPECiAL RE0ue#EMENTS PCA AESULTS OF V ALs0Af t0N CL ASS f SWFPo#fS P ROGR A M SWEC PSAS e A I PIPE M f OADS g j

" *0"O I DI F W ALIDAflON OF '

OVEgyggy PIPING AND CLASS 1 PiriNG e Atletuf ,0F ,ECN. CAL ,StutS P =rA',';,P , ca ' a~~'

e RE Sutf 9 07 ANALYSal e LOA 08 IMPOSED SV CLASS I ANO 3

• I' "O M k PtPekG One CLASS 1 PIPING e V ALVE ACCELERAflose9 AND E0ulPMENT le0DLE LOAOS FOR WE STIN0NOUSE -

SuPPUE0 V ALVES, E0utPMENT e SuPPORf AE ACTION LOA 05 ON WESIDNONOUSE DES 10NED E0uePMENT SUPPOAf 8 SYSTEM OPEAAftNG e CNA AACTE ntSitCS SvlTEM OES40N e MOOsFICaflOleS AAS DAT A fehCLU0easo THE e A UE e DESiON CHANCE RECOMMENDAftO8e8 C ASE N eHI e E APANSION JO8NT MOVEMFNTS CON T AMEN AflO8e PENE f A Af TON e e ADOT V ALVE MOVEMENTS FOft CONFtGuR A fiON eNSf tuMggf Sv$ REMS GE OLOctC AL INPuf DAT A e e St Auc tuA AL INTE AF ACE RE ACTA 0N A L CLOUD ASSOCIATES Sust0Neo AND Sf eswC e L O ADS St AflC DeSPLACEMEN TS e CONT AeNMElef PElef f A AftON LOADS ASSIST Tu ELECTRIC AND e REFLE C FfWE INSul Af TON RE MOV AL STRuCfuRAL INTEAF ACE e Af SLnVES PENE tAAfeNS SWEC . PS AS IN REbOLuflON RE 0ut AE ME NT U"' " ' ""'8 OF TECNNiC AL ISSUCS PePE AuPfuRE LOA 06 ON e MOMENT RESTRAINTS f

SWEC e MECMAmC At GA0up e CIVIL / StauCTun AL OROUP G ELECT AIC AL OA0up e INSTRUMENT ATION a CONTROL OAOUP caer 61

n r

V FIGURE 5-3 SWEC-PSAS PIPE STRESS DESIGN VALIDATION FLOW CHART SWEC e PlPiNG OR AWINGS e SYSTEM PARAMETERS e ARS CURVES e SYSTEM OPER ATING CONDITIONS e ESSENTIAL SYSTEMS e BREAK EXCLUSION BOU ND ARIE S

+

SWEC . PSAS e SYSTEM REVIEW AND HANGER OPTIMIZATION REVIEW E8ASCO e INPUTS AND MODELING J SINO NUPIPE W 7 e JETIMPINGEMENT e FLulD TR ANSIENT ANALYSIS LOADS ON PIPING I

l f RESULTS e MAXIMUM CALCULATED STRESSES e PIPE SUPPORT / CONTAINMENT PENE1 RATION LOADS e EQUIPMENT /V ALVE/NOZ2LE FLANGE LOADS e VALVE ACCELER AYlONS AND V ALVE OPERATOR SUPPORT REQUIREMENT

[% i p

e EXPANSION JOINT MOVEMENTS e PIPE MOVEMENTS AT SLEEVES

\*d )

i e ROOT VALVE MOVEMENTS FOR INSTRUMENT SYSTEMS I e STREJS LEVEL FOR PIPE l BRE AK POSTULATION e PIPE MOVEMENTS AT PIPE RUPTURE RESTRAINT AND PIPE SUPPORTS LOC A YBONS EBASCO e FUNCYlONAL CAPABILITY EVALUATION OF ESSENTIAL PIPING 4 POSTULATED BRE AK LOC AflONS e LAT N Lg E, T,1V,E y q IN g vE LOCAT NS e PIPE MOVEMENTS AT PIPE KUPTURE RESTRAlhi LOCATIONS e STRESS LEVEL AT CLASS 2 PRESSURE RETAINING WELOS IN PIPING IMPELL CORPOR ATION WESTINGHOUSE e PIPE MOVEMENT AT SE ALED SLEEVES O C SS PP e VALVE ACCELEP AYlON e EQUIPMENT / VALVE LOADS e VALVE AND EQUIPMENT NOZ2LE f FOR WESTINGHOUSE SUPPLIED E QUIPME N T S LiEYEOUt MENT STRESS CALCULATION e V ALVE ACCELERAYlONS FOR e VALVE OPERATOR SUPPORT WITN *'$t oNOuSE SumiED DOCUMENTATION / TRANSMITTAL'i V4ty RE ACTION LOADS FOR DESIGN ACCEPTANCE

+

SWEC PSAg TU ELECTRIC SWEC e PIPE SUPPORY VALIDAflON e WELD LOCATIONS FOR e CONTAINMENT PENETR ATION i (SEE FIGURE S 4) PRE SERVICE AND LOADS i

IN SERVICE INSPECTIONS e EXPANSION JOINT MOVEMENTS e ROOT VALVE MOVEMENTS FOR INSTRUMENT SYSTEMS e REFLECTIVE INSULAYlON REMOVAL AT SLEEVES OR PENETRATION LOCAflONS l

w CNs7 843 2

FIGURE 5-4 SWEC-PSAS PIPE SUPPORT DESIGN VALIDATION FLOW CHART SWEC PSAS PIPE STRESS RESULTS (FROM FIGURE S 3)

+ ^

WESTINGHOUSE SWEC PSAS AS BUILT INFORMATION AND CLASS 1 PIPE SUPPORT LOADS NON ASME ATTACHMENT LOADS PIPE SUPPORT GROUP FORMATION OF LOADING COMBINATIONS FOR PIPE SUPPORT VALIDATION O , r l

VALIDATION l e COMPONENT STANDARD SUPPORTS

• STRUCTURAL FRAMES e lNTEGRAL WELDED ATTACHMENTS e STIFFNESS FOR P!PE SUPPORTS WITHIN CLASS 1 PIPE STRESS ANALYSIS PACKAGE e ASME SECTION lil CODE CHECK e WELD / BOLT JOINT DESIGN e LOCAL STRESS e BASEPLATES, RICHMOND INSERTS, AND ANCHOR BOLTS SWEC-MECHANICAL WESTINGHOUSE SWEC -CIVIL / STRUCTU R AL

• CLASS 1 PIPE SUPPORT UPPORT CALCULATION RESULTS, INCLUDING PIPE e SUPPORT (INCLUDING MOMENT {

RESTRAINTS)/ STRUCTURAL DOCUMENTATION / SUPPORT STIFFNESSES l lNTERFACE REACTION LOADS TR ANSMITTALS FOR e SWING ANGLE EXCEEDANCE e REFLECTIVE INSULATION DESIGN ACCEPTANCE e SUPPORT REACTION LOADS REMOVAL AT BOX FRAME ON WESTINGHOUSE DESIGNED .

PIPE SUPPORT LOCATIONS EQUIPMENT SUPPORTS 1

l l 1 P t )

TU ELECTRIC CONSTRUCTION /OUALITY CONTROL O INSTALL AND INSPECT MODIFICATIONS CMsF 846

FIGURE 5-5 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)

)

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. I ossioN vauoarioN I I E l 5 I soaNnri riNat I g nevia merauano.i g accemNes arva..un g s,scricanoNs g g , ,

hmmmmmmmmmE E E g l comPLE f t artartuf t Ig gg uafnis lg Ememe m e au m 8 CPRr

. VEs AECouMENDs

, nt.msPECrioM No o,,,aN vauDarioN F g " '" " " " " " " " ""E NQWE E RINo"(V atu a hon""""""=""="="=""3 g REsUtr IN CHANoto

, 8 a of stGN 04 accurraNca E I artniaute g g on cent toENrlH g g AND oio Not msprer I Q couens I t I cara E E I No I h I E esanoau - E E reCnNicat E 5 oisposmoN g

, easioN ,

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nesut t m New I

-"8 p upoare g wonu mctuoiNo uAME

, g

' uoolaiCarloN or g existmo g g MaAowaat g i nasutts No g E

g acctPra8tt No I E is I g "O a arraisure a 6 atr$ANatt g

ACCE SSl8tE E i PtaN . auntME A E ves tecnNicat E

, r I oisposmoN res g E countere g I upoaremarn s evacuation esas,iste vas , , ,

g PaCMaoE g

cavatoe rvu g No g

. oC marscrioN I e ENGiNff alNG watNoowN E e uana accessista E E

' ' . attenNare rvu I

' upoare marnix l 5 E E E I E

' ' E ces No E I E y u an im mig coNcu,nneNce E

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ma i rieto I i

g I E vauoatioN I g ,,, g bem med ammmmmmmmmmmma ammmmmmmmma enammmmes s w 0

MaADwant ygg & VaLfo oN 2 PaCMaol DE s, ion (DVP)

Wo uoWicaMN CH4 7,ggg

,,s TABLE 5-1  !

/ A U PIPING SYSTEM INPUT DATA

1. Final Safety Analysis Report (FSAR)

I

2. ASME III Code Class 1, 2, and 3 piping drawings and Seismic Category II piping drawings within the same piping stress analysis package ,

1

3. Pipeline designation list l

4. Piping design specifications

5. Flow diagrams, system description and operating conditions l

6. Seismic response spectra (including the application of ASME Code Case N-411)

7. Seismic structural displacements data

8. General arrangement and civil / structural drawings

9. As-built piping support location drawings

10. Pipe support drawings

( 11. Thermal structural displacements data

12. Containment pressure test displacement data

13. Wall and floor sleeve sealant design data

14. Jet impingement loads

15. Pipe whip impact loads

16. Structural and equipment layout drawings

17. Valve and valve operator weights (including extended attachments), center of gravity, yoke natural frequency and acceptable valve acceleration limit

18. Equipment movement data and allowable nozzle loads

19. As-built location of pipe with respect to wall and floor sleeves

20. Existing pipe break locations, pipe rupture restraint locations and de-tailed drawings

21. Valve nozzle allowables ln I C/ 1 l

22. As-built pipe thickness

23. Westinghouse Class 1 pipe stress reports

24. ADLPIPE computer listing-for each pipe stress analysis package

25. Cont'ainment displacements.due to loss of coolant accident (LOCA)

26. Component drawings (equipment, penetration, valve, etc)

27. Calculations

a. Pipe stress analysis (if applicable)

b. Pipe support analysis and stress report (if applicable)

c. Fluid transient analysis (if applicable)

28. Loads from non-ASME attachments on pipe supports

29. Geotechnical data for buried pipe analysis

30. Flexible hose design criteria and vendor's design report

31. As-built information for tie-back support

32. As-built pipe weld shrinkage and locations

{

l l

1 l

l 1 0 2 ll l

l l

L____.-_.__________.--____

- p TABLE 5-2 V FLUID TRANSIENT LOADINGS Containment Spray System  !

• Containment spray pump startup  !

i Safety Injection System

• Check valve closure following pump trip i Service Water System

• Pump trip and pump start Residual Heat Removal System

• Relief valve discharge  ;

Chemical and Volume Control System l

• Relief valve discharge Main Steam System

/ .

b

• Main steam turbine trip

• Auxiliary feedpump turbine trip-

• Feedpump turbine trip

• Safety and relief valve discharge I

Feedwater System

• Check valve closure following pump trip  ;

• Rapid closure of isolation or control valve

• Check valve closure analysis following postulated pipe rupture

'1 Auxiliary Feedwater System i

• Check valve closure following trip of one auxiliary feedwater pump Boron Recycle System .

l

• Relief valve discharge l Component Cooling Water System i

• Relief valve discharge ,

1 O l

L TABLE 5-3 i PCHVP REINSPECTION ATTRIBUTES AND RESOLUTIONS IN RESPONSE TO'CPRT QUALITY OF CONSTRUCTION ISAP-VII.C RESULTS REPORT

l. LARGE BORE PIPING AND PIPE SUPPORTS Construction ISAP-VII.c Results PCHVP Attributes Work Category Report Recommendations FVM/ Procedures Large Bore Reinspect flow elements to CPE-SWEC-FVM-PS-081 Piping Configur- verify that they are orien- (Reference 51) ation ted in the proper direction CP-QAP-12.1 1 (Reference 34)

Figure F.23 Verify existing piping CPE-SWEC-FVM-PS-080 clearance criteria and (Reference 50)  ;

walkdown all insulated CPPP-22, Clearance large bore piping Walkdown Procedure (Reference 32)

Reinspect safety-related CPE-SWEC-FVM-PS-081 piping expansion joints CP-QAP-12.1 Figure F.23 O Pipe Welds CPE-SWEC-FVM-PS-081 ig Reinspect butt welds in and Materials Schedule 80 or thinner _CP-QAP-12.1 stainless steel piping made Figure F,23 )

prior to 1982 that are replacement welds and/or have received extensive repairs

'Large Bore Walkdown of pipe supports.

^

CPE-SWEC-FVM-PS-081 Pipe Supports - containing vendor-supplied CP-QAP-12.1 Rigid components and replacement Figure F.16 of nonconforming parts sub-ject to appropriate engineer-ing disposition i i

Inspect for proper gaps CPE-SWEC-FVM-PS-080 j between pipe and pipe sup- CPPP-22, Clearance j ports and verify adequate Walkdown Procedure l clearance between pipe CP-QAP-12.1 l welds and pipe supports Figure F.9 i 1 i 1

l

TABLE 5-3 (Cont) l Construction ISAP-VII.c Results PCHVP Attributes Work Category ' Report Recommendations FVM/ Procedures Inspect and install suitable CPE-SWEC-FVM-PS-081 locking devices on all CP-QAP-12.1 vendor-supplied components Figures F.13, F.15, l that do not have high- F.16, F.18, and F.20 strength bolting; install locking devices on all high-strength bolting that is not torqued to an acceptable pre-load Walkdown reinspection of CPE-SWEC-FVM-PS-081 pipe clamps and replace CP-QAP-12.1 nonconforming spacers or Figure F.13 confirm they fall within the limits of bounding calcu-lation Verify that jam nuts on all CPE-SWEC-FVM-PS-081 vendor-supplied components CP-QAP-12.1 (sway struts, snubbers, and Figures F.15, F.16, and spring cans) are snug tight F.17 i Walkdown of all pipe sup- CPE-SWEC-FVM-PS-081 ports having pipe clamps to CP-QAP-12.1 verify security of attach- Figure F.13 ment to the pipe Large Bore Reverify component adjust- CPE-SWEC-FVM-PS-081 Pipe Supports - ment during the startup CP-QAP-12.1 Nonrigid and preoperational phases Figure F.20 of the plant Inspect and install suitable CPE-SWEC-FVM-PS-081 locking devices on all CP-QAP-12.1 vendor-supplied components Figures F.13, F.15, that do not have high F.16, and F.20 strength bolting, install  ;

locking devices on all high-strength bolting that is not torqued to an acceptable pre- '

load

1 i

l TABLE 5-3 (Cont)- l O Construction ISAP-VII.c Results PCHVP Attributes l

I Work Category Report Reconsnendations FVM/ Procedures l Walkdown of all vendor- CPE-SWEC-FVM-PS-081 1 :' supplied components to en- CP-QAP-12.1

. sure that proper angularity Figures F.15 and F.17 exists l

Walkdown of all supports CPE-SWEC-FVM-PS-081 .,

containing vendor-supplied CP-QAP-12.1 l components and inspect Figures F.13 and F.20 l cotter keys and associated bolting 1

1 l

l O ,

l l

l 4

4 l

1 1

1 3

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1 1

i TABLE 5-4 0

V UNIT 1 AND COMMON LARGE BORE PIPE SUPPORTS MODIFICATION

SUMMARY

Category Number of Modifications ,

Prudent 1293 Recent Industry Practice 1883 Adj ustment 393 Cumulative Effects 2052 TOTAL 5621 Modification Description Category Richmond Insert Single Tubes Prudent Allowable Stress Exceeded for Structural Member Cumulative Effects Support Deleted Recent Industry Practice Support Added Cumulative Effects Rigid Trapeze. Prudent Trapeze Snubber Prudent Allowable Stress Exceeded for Welds Cumulative Effects Allowable Load Exceeded for Standard Component Cumulative Effects Allowable Load Exceeded for Concrete Anchor Cumulative Effects O. *~

Cinched U-Bolt Modification Prudent Component Exceeds 5 Degree Offset Adj ustment Revise Clearances Adj ustment To be Modified Into a Clamp Anchor Prudent Box Frame on Pin Connection Prudent Modify to Increase Stiffness Prudent  !

Preliminary Study Revises this into a Clamp Anchor Prudent Change from Rigid to Anchor or from Anchor to Rigid Prudent Change from Snubber to Rigid Recent Industry Practice Change from Rigid to Snubber Cumulative Effects Two Way Rigid Restraint Changed to a One Way Restraint or One Way Changed to Two Way Restraint Cumulative Effects Three Way Changed to One or Two Way Restraint Cumulative Effects U-Bolt on a Rigid Frame (One or Two Way ,

Restraint) Cumulative Effects i Change from Rigid Hanger to Spring or Spring to Rigid Cumulative Effects i Relocate Hanger Cumulative Effects Pipe Bearing Stress Failure Cumulative Effects Reset Spring or Snubber Settings Adj ustment Exceeds Lateral Movement for Spring Adj ustment  !

t

r~N TABLE 5-5 t \

V

SUMMARY

- CINCHED U-BOLT TRAPEZE SUPPORT H0 DEIFICATIONS Description of Modification Large Bore Piping Single strut or snubber with a standard 223 pipe clamp Box frame 82 Trapeze with strap and lugs 59 Trapeze with welded attachment now con- 43 stituting a rotation restraint Single strut or snubber with a welded I attachment Single strut or snubber with a stiff 19 clamp Deleted 266 i

TOTAL 693

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TABLE 5-th kSEISMIC' CATEGORY IliLARGE BOFE PIPING OVER SEISMIC CATEGORY 1 EQUIPMENT PIPING CHECKLIST U '

h)

The field. ' verification' of Scismic' Category II piping located over Seismic .

Category I . systems , struer.ures , or components is documented using a checklist addressing these attributes:

n; . ,

1.' ; Establish, seismic; to nonseismic boundaries in piping systems and de-

'termine unet.Ler the boundary requires further evaluation to ensure +

the. integrity of the seismic portion during a seismic event.

- 2 .t Determine if pipe supports ' restrain thermal expansion of a long straight piping run.

3. Determine if supports have exi$ ting design . loads that are less than calculated'. threshold loads. '

4 1 ,,

43 .. Determine if supports are next to a heavy, concentrated weight (valves or components).

~

5. Determine if long straight runs or risers are not adequately support-i ed for seismic in axial direction of pipe.

6. Determine if piping extends to different buildings.

7. Determine if the system design temperature exceeds 150*F.

s 8. Verify . that hot piping configuration and component alignment are in

~ s\ (accordancewiththe.designdrawingo 1 '

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TABLE 5-7

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S T I I PR D SWEC-PSAS Field Verification Methods (FVMs) for large bore piping and pipe sup-ports Post Construction Hardware Validation Program (PCHVP) are in compliance with the folleving procedures:

1. Comanche Peak Piping Erection Specification No. 2323-MS-100 (Reference 38)

2. Comanche Peak ASME Section III Code Class 2 and 3 Piping Design Spec-ification No. 2323-MS-200 (Reference 41)

3. Comanche Peak Nuclear Safety Class Pipe Hangers and Supports Specifi-cation No. 2323-MS-46A (Reference 44)

4. Comanche Peak Structural Embedments Specification No. 2323-SS-30 1 (Reference 39)

5. Comanche Peak Construction Procedure CP-CPM-9.10, Component Support Installation (Reference 43)

6. Comanche Peak Construction Procedure CP-CPM-9.10A, Installation of

'N

[d 7.

Vendor-Supplied Component Supports Catalog Items (Refer-ence 40)

CPSES Quality Assurance Procedure CP-QAP-12.1, Mechanical Component Installation Verification (Reference 34)

8. CPSES Quality Assurance Procedure QI-QAP-11.1-28, Fabrication and Installation Inspection of Safety Component Supports (Reference 45)

9. CPSES Quality Assurance Procedure QI-QAP-11.1-26, Piping and Equip-ment Installation Inspection (Reference 42) 4 l

s_- .

i i

TABLE 5-8 SEISMIC CATEGORY II LARGE BORE PIPING OVER .

I SEISMIC CATEGORY I EQUIPMENT

-PIPE SUPPORT CHECKLIST  !

The field verification of Seismic Category II piping located over Seismic I Category I systems, structures, or components-is documented using a checklist i addressing these attributes:

1. General Support Requirements l

< 1

a. Location

b. Function i

c. Orientation ~

d. Dimensions / configuration / material per control drawing /

document .

e. . Physical damage / completeness .

f. Hole. edge. distance in structural members '

g. Gap clearances h- Minimum 1 in, clearance

1. Voided. supports removed 2

2. Welding

a. Weld type O b. Welds properly wrapped

3. Base Plates / Anchor Bolts

a. Bolt size

b. Edge distance of holes

c. Size and hole spacing

d. Attachment location

e. Nut tightness / thread engagement

f. Locking devices

g. Washers

h. Clearance with adjacent Hilti bolt

4. Bolted Connections (Including Clamps)

a. Bolt / pin size

.b. Thread engagement

c. Nut tightness

d. Locking devices / cotter pins

e. Clamp size / proper spacer

f. Tightness of bolt and clamp O 1

i l

TABLE 5-8 (Cont)

I^^ 5. Snubber / Strut / Spring Components

a. Size / type / load pin size I

b. Spherical bearing adequacy / free to swivel

c. Angularity with tolerance  !

d. Setting adequate per drawing

e. Eye rod thread engagement /nt t tightness <

f. Ends not binding 1

g. Locking devices '

h. Extension weld adequacy

i. Lubrite plate

6. Design Considerations

a. Support instability (e.g., uncinched U-bolts)

b. Threshold loads exceed previous design load

c. Nonseismic interface loads

d. Seismic loading inclusion in original support load

e. Adequacy of gang support

f. Integral attachment adequacy

7. Aircraft Cables

a. Cable diameter

b. Ceiling / wall connection jm c. Clamp type / rod type

d. End loop configuration

e. Eye nut tightness / lock washers

f. Cable clamp tightness

g. Cable slack / configuration

h. Tie spacing / bundled cables tied together

1. Support location / span ji Cable restraint modifications for 12 in, and 10 in.

diameter pipe

k. End of cables wrapped to prevent fraying

TABLE 5-9 f}

1 !

V TYPICAL SWEC-PSAS TECHNICAL AND DESIGN CONTROL PRACTICES

1. Add terminal anchors in the pipe stress problem boundary to bound the stress problem.

2. Establish a seismic-to-nonseismic piping interface anchor design requirement.

3. Revise pipe stress analysis package boundary decoupling requirement.

4. Establish branch line mass effect on main piping requirement.

5. Establish functional capability evaluation requirement.

6. Document the validation of thermal stress cycles and stress range reduc-tion factor requirement.

7. Establish stiffness modeling of sleeve sealant.

8. Revise clearance requirement between pipe and structural frame.

9. Establish a clamp anchor design for 6 in. and smaller nominal size pipe.

10. Revise the seismic design loads for nonsafety-related piping attached to

{p J safety-related ganged pipe supports.

11. Revise the tube steel wraparound welding length evaluation requirement.

12. Document the strut, snubber, and spring hanger swing angle evaluation re-quirement, including thermal, seismic, and fluid transient movements.

13. Establish an integrated clearance validation program (engineering walkdown to validate clearance).

14. Establish the requirement to validate the valve weight list and the valve stem extension in the as-built drawing.

15. Establish the pipe stress and pipe support system review documentation requirement.

16. Establish the review and validation of CPSES plant destv and operating conditions.

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6.0 REFERENCES

1. CPSES Design Basis Document DBD-CS-065, ASME Class 1 Piping Analysis, Revision 0, October 1, 1987

2. CPSES Design Basis Document DBD-CS-066 ~ ASME Class 2 and 3 Piping Analysis, Revision 0, July 31, 1987

3. CPSES Design Basis Document DBD-CS-067 ASME Class 1, 2, and 3 Pipe Support Design, Revision 0, July 31,1987

4. TU Electric Comanche Peak Response Tean Action Plan, DSAP IX, Piping and Supports Discipline Specific Action Plan, Revision 2, June 18, 1987

5. SWEC-PSAS CPSES Generic Technical Issue Report, Revision 0, June 27, 1986

6. SWEC-PSAS Comanche Peak Project Procedure CPPP-1, Management Plan for Project Quality (Piping System Qualification /Requalification)

Revision 7, March 25, 1987

7. U.S. Nuclear Regulatory Commission, Standard Review Plan, NUREG-0800, Section 3.6, Revision 1, July 1981, Section 3.7, Revision 1, July 1981, Sections 3.9.1, 3.9.2, Revision 2, July 1981, and Sec-tion 3.9.3, Revision 1, July 1981, Appendix A, Revision 1, April 1984

8. SWEC-PSAS Comanche Peak Project Procedure CPPP-7, Design Criteria for Pipe Stress and Pipe Supports, Revision 3, February 23, 1987

9. SWEC-PSAS Comanche Peak Project Procedure CPPP-6, Pipe Stress / Support Requalification Procedure - Unit 1, Revision 4, April 8, 1987

10. SWEC-PSAS Comanche Peak Project Procedure CPPP-8, Piping and Support System Engineering Walkdown Procedure, Revision 1, April 25, 1986

11. SWEC-PSAS Piping and Support System Engineering Walkdown Final Re-port, CPSES Unit 1, June 4, 1986

12. CPSES ASME Quality Procedure AQP-12.1, Pressure Testing Inspec-tion, Revision 0, July 10, 1987

13. Welding Research Council (WRC) Bulletin 300, Technical Positions on Criteria Establishment, Damping Values for Piping, Response Spectra Broadening, and Industry Practice by Technical Committee on Piping Systems, December 1984

14. SWEC-PSAS Comanche Peak Project Procedure CPPP-5, Field Walkdown Procedure - Unit 1, Revision 2, March 12, 1986 6-1

l

15. SWEC-PSAS Comanche Peak Unit 1, Large Bore Field Walkdown Report, October 10, 1985

16. Pipe Support Review Issues List, Revision 4, September 17, 1987, l transmitted from N. H. Williams (CYGNA) to W. G. Counsil (TU Electric) on September 18, 1987, CYGNA Letter No. 84056.120

17. SWEC-PSAS Comanche Peak Project Procedure, CPPP-18, Procedure for )

Evaluation of ERC Deviation Reports, Revision 2, June 17, 1987 j i

18. SWEC-PSAS Report No. 15454-N(C)-010, ' Impact of Construction Devia- I tions on Stress Requalification Program, Revision 1, October 1, 1987

19. Civil-Structural Review Issues List, Revision 0, July 21, 1987; transmitted from N. H. Williams (CYGNA) to W. G. Counsil (TU Electric) on July 22, 1987

20. SWEC-PSAS Topical Report SWSQAP-1-74A, Stone & Webster Engineering Corporation Standard Quality Assurance Program, Revision E, February 21, 1986

21. SWEC-PSAS Comanche Peak Project Procedure CPPP-10, Procedure for Re-view of Plant Operating Mode Conditions, Revision 1, April 1, 1986

22. ASME Boiler and Pressure Vessel Code,Section III, Division 1 Nuclear Power Plant Components, 1974 Edition, including the 1975 Summer Ad-denda of Subsections NC and ND and 1975 Winter Addenda of g Subsection NF

23. NUREG-0582, Waterhammer in Nuclear Power Plants, U.S. Nuclear Regula-Lory Commission, July 1979

24. NUPIPE-SW, Stone & Webster Engineering Corporation Computer Program ME-110U, Stress Analysis of Nuclear Piping, Version 4, Level 2 (Proprietary)

25. NUREG/CR-1161, Recommended Revisions to Nuclear Regulatory Commission Seismic Design Criteria, Prepared by Lawrence Livermore Laboratory for USNRC, May 1980

26. Comanche Peak Steam Electric Station - Units 1 and 2, Final Safety Analysis Report, current as amended

27. ANSI /ASME OM-3-1982, Requirements for Preoperational and Initial Startup Vibration Testing of Nuclear Power Plant Systems, Revision 1 (Proposed), May 1985

28. NUREG-0797, Safety Evaluation Report (SER) and Supplement (SSER)

Nos. I through 4 and 6 through 13, Comanche Peak Steam Electric Sta-tion, Units 1 and 2, U.S. Nuclear Regulatory Commission, July 1981, Supplements dated through May 1986 6-2

, 29. SWEC-PSAS Comanche Peak Proj ect Procedure CPPP-23, Pipe Stress /

/ Support Final Reconciliation Procedure, Revision 1, July 31, 1987

\

30. SWEC-PSAS Comanche Peak Project Procedure CPPP-31, CPSES Safety-Related Piping and Pipe Supports Design Basis Consolidation Program, Revision 1, May 15, 1987

31. NBC Letter, R. F. Heishman, Vendor Program Branch Chief, to R. B. Kelly, Docket No. 99900509/86-01 dated January 2, 1987

32. SWEC-PSAS Comanche Peak Project Procedure CPPP-22, Clearance Walkdown Procedure, Revision 0, November 21, 1986

33. Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Appendix D, CPRT Sampling Policy, Applications and Guidelines, Revision 1, January 31, 1986, and Appendix E, Resolution of Discrep-ancies Identified by the CPRT, Revision 3, June 18, 1987

34. CPSES Quality Control Procedure CP-QAP-12.1, Mechanical Component Installation Verification, Revision 20, July 10, 1987

35. SWEC-PSAS CPSES Large Bore Pipe Stress and Pipe Support Generic Is-sues Report, Revision 1, July 24, 1987

36. CPRT-QOC Issue-Specific Action Plan, ISAP-VII.c Results Report, Con-struction Reinspection / Documentation Review Plan, Revision 0, May 19, 1987

37. SWEC-PSAS Site Procedure CPSP-12 Piping, As-Built Verification, Revision 4, September 3, 1987

38. CPSES Piping Erection Specification No. 2323-MS-100, Revision 9, August 17, 1987

39. CPSES Structural Embedments Specification No. 2323-SS-30, Revision 2, June 13, 1986

40. CPSES Construction Procedure CP-CPM-9.10A, Installation of Vendor-Supplied Component Supports Catalog Items, Revision 1, August 15, 1985

41. CPSES Piping Engineering and Design ASME Section III, Code Classes 1, 2, and 3, ANSI B31.1, Classes 5 and G, Specification No. 2323-MS-200, Revision 5, August 6, 1987

42. CPSES Quality Assurance Procedure Q1-QAP-11.1-26, Piping and Equip-ment Installation Inspection, Revision 0

43. CPSES Construction Procedure CP-CPM-9.10, Component Support Installa-tion, Revision 16, December 29, 1986 6-3

44. CPSES Nuclear Safety Class Pipe llangers and Supports Specification No. 2323-MS-46A, Revision 7, May 12, 1987

45. CPSES Quality Assurance Procedure QI-QAP-11.1-28, Fabrication and Installation Inspection of Safety Class Component Supports, Revision 36, April 22, 1987

46. Tenera, L.P., Discipline Specific Results Report, Piping and Sup-ports, DAP-RR-P-001, Revision 1, August 27, 1987

47. TU Electric Engineering and Construction Engineering Procedure ECE-9.04-04, Post Construction Hardware Validation Program - Imple-mentation Plan - SWEC-PSE, Revision 0, July 28, 1987

48. TU Electric Engineering and Construction Procedure EC-9.04, Post Con-struction liardware Validation Program, July 29, 1987

49. TU Electric Engineering and Construction Policy No. 1, CPSES Correc-tive Action Program, Revision 1, August 30, 1987

50. SWEC-PSAS CPSES Field Verification Method, Clearance Walkdown, CPE-SWEC-FVM-PS-080, Revision 0, July 29, 1987

51. SWEC-PSAS CPSES Field Verification Method, lia rdwa re Validation and Supplemental Inspection Programs, CPE-SWEC-FVM-PS-081, Revision 0, July 29, 1987

\ 52. SWEC-PSAS CPSES Field Verification Method, Validation of Seismic

\

Category II Large Bore Pipe Support Designs, CPE-SWEC-FVM-PS-082, Revision 0, July 29, 1987

53. ANSI /ASME N45.2.6 - 1978, Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants, January 15, 1979

54. SWEC-PSAS Comanche Peak Project Memorandum PM-39, Administrative Pro-cedure for Qualifying Wall-to-Wall, Floor-to-Floor, and Corner Pipe Supports, Revision 3, June 2, 1987

55. TU Electric Engineering and Construction Procedure ECE 9.04-05, Post-Construction Hardware Validation Program - Engineering Evalua-tions, Revision 0, September 1, 1987

56. SWEC-PSAS Comanche Peak Project Procedure CPPP-30, Validation of Seismic Category II Large Bore Piping and Pipe Support Designs, Revision 1, August 5, 1987

57. SWEC-PSAS Comanche Peak Project Procedure CPPP-25, Piping Vibration Test Procedure - Unit 1, Revision 0, December 8, 1986

58. Code of Federal Regulations, Title 10, Part 50, Paragraph 50.55(e) 1 6-4

1 l

I

59. SWEC-PSAS Comanche Peak Project Procedure CPPP-35, Piping and Pipe O Support Qualification Procedure for Secondary Wall Displacements, Revision 0, June 8, 1987

60. CPSES ASME Quality Procedure, AQP-11.2,' Fabrication and Installation Inspection of Pipe'and Equipment, Revision 0, July 10, 1987

61. CPSES Design Basis Document DBD-CS-069, Thermal Expansion Testing and Piping Vibration Monitoring, Revision 0, July 31, 1987

62. CPSES Design Basis Document DBD-CS-070, Reactor Coolant Loop Piping and Support Design, Revision 0, October 1, 1987

63. TU Electric CPSES Unit 1 and Common, SWEC Civil / Structural Project Status Report, Revision 0 l

64. TU Electric CPSES Unit 1 and Common, SWEC Mechanical Project Status Report, Revision 0

65. SWEC-PSAS Comanche Peak Project Procedure CPPP-20, Pipe Break / Crack l Postulation Analysis Procedure, Revision 1, April 30, 1987

66. SWEC-PSAS Comanche Peak Project Procedure CPPP-24, Thermal Expansion Test Procedure - Unit 1, Revision 0, December 1, 1986

67. SWEC-PSAS Comanche Peak Project Procedure CPPP-28, Procedure for Identification and Evaluation of Interfaces between Seismic and Non- j O seismic Piping, Revision 0, February 20, 1987 l

68. SWEC-PSAS Comanche Peak Project Procedure CPPP-33, Engineering Activ-ities to Support SWEC Certification of ASME III, Class 2 and 3 System N-5 Data Reports as Piping System Designer, Revision 0, May 21,1987

69. SWEC-PSAS Comanche Peak Proj ect Procedure CPPP-4, Project Records Management Procedure, Revision 2, February 27, 1987

70. SWEC-PSAS Comanche Peak Project Procedure CPPP-11, Administrative Control of Calculations, Revision 1, February 13, 1987

71. SWEC-PSAS Comanche Peak Site Procedure CPSP-19, Preparation, Review, and Approval of Specifications and Specification Revisions, Revision 0, May 27, 1987

72. SWEC-PSAS Comanche Peak Site Procedure CPSP-14, Processing Design Changes Utilizing DCAs, Revision 4, July 27, 1987

73. SWEC-PSAS Comanche Peak Site Procedure CPSP-10, New Pipe Support De-signs, Revision 0, October 15, 1987

74. SWEC-PSAS Comanche Peak Site Procedure CPSP-11, TSMD Drawing Prepara-tion, Revision 4, June 22, 1987 6-5

75. TU Electric CPSES Engineering Procedure ECE-DC-7, Preparation and Review of Design Drawings, Revision 19, October 31, 1986

76. TU Electric Field Verification Method CPE-EB-FVM-SI-40, Seismic /

Nonseismic Walkdowns, System Interaction Program, Revision 0, June 15, 1987

77. SWEC-PSAS Comanche Peak Project Procedure CPPP-29, Moment Restraint Support Qualification Procedure and Design Criteria, Revision 0, September 25, 1987

78. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.29, Seismic Design Classification, Revision 2, February 1976

79. TU Electric Letter No. TXX 6631, W. G. Counsil to U.S. Nuclear Regu-latory Commission, Comanche Peak Programs, August 20, 1987

80. TU Electric Letter No. TXX 6500, W. G. Counsil to U. S. Nuclear Regu-latory Commission, Comanche Peak Programs, June 25, 1987

81. Pipe Stress Review Issues List, Revision 4, September 16, 1987, transmitted from N. H. Williams (CYGNA) to W. G. Council (TU Electric) on September 16, 1987, CYGNA Letter No. 84056.119

82. U. S. Nuclear Regulatory Commission, Regulatory Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants, Revision 2,

("} August 1978.

V t

b 6-6

. _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - . - _ _ k

l

=

7-- APPENDIX A l .\

l b COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL ISSUES INTRODUCTION This appendix describes the details of the resolutions of issues resulting from the Comanche Peak Response Team (CPRT) and from external issues. Each of thir-ty-nine issues listed below is described in an individual subappendix which includes discussions of resolution methodology and corrective and preventive actions.

SWEC-PSAS has reviewed the CPSES Supplemental Safety Evaluation Reports (SSERs)

(NUREG-0797), and determined that the procedures and design criteria for the piping and pipe supports Corrective Action Program (CAP) are consistent with the actions required of TU Electric by the NRC Staff as stated in the SSERs.

Issue No. Issue Title Al Richmond Inserts A2 Local Stress - Piping A3 Wall-to-Wall and Floor-to-Ceiling Supports A4 Pipe Support / System Stability ,

A5 Pipe Support Generic Stiffness A6 Uncinched U-Bolt Acting as a Two-Way Restraint A7 Friction Forces

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A9 A500, Grade B Tube Steel A10 Tube Steel Section Properties All U-Bolt Cinching A12 Axial / Rotational Restraints A13 Bolt Hole Gap A14 OBE/SSE Damping A15 Support Mass in Piping Analysis A16 Programmatic Aspects and QA Including Iterative Design A17 Mass Point Spacing A18 High-Frequency Mass Participation A19 Fluid Transients A20 Seismic Excitation of Pipe Support Mass A21 Local Stress in Pipe Support Members A22 Safety Factors A23 SA-36 and A307 Steel A24 U-Bolt Twisting

.A25 Fischer/ Crosby Valve Modeling/ Qualification A26 Piping Modeling l A27 Welding A28 Anchor Bolts /Embedment Plates O

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e Issue No. Issue Title V A29 Strut / Snubber Angularity A30 Component Qualification A31 Structural Modeling for Frame Analysis ,

A32 Computer Program Verification and Use I A33 Hydrotest  !

A34 Seismic /Nonseismic Interface A35 Other Issues A36 SSER-8 Review A37 SSER-10 Review A38 SSER-11 Review A39 CPRT Quality of Construction Review on Piping and Pipe Supports j i

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SUBAPPENDIX Al RICHMOND INSERTS 1.0 Definition of the Issue There were several interrelated issues regarding the use of Richmond in- '

serts (see Figure Al-1). The issues were related to design allowables, methods for calculating bolt loads in tube steel connections, and modeling of: insert / tube steel connections. The specific issues are as follows (see References 4.1 through 4.9): l 1.1 Safety' Factors / Testing The issue was that-a safety factor of two was used for Richmond insert L designs instead of the manufacturer's recommended safety factor of three.

Related questions were raised regarding the tests performed by TU Electric on Richmond inserts to determine the load-carrying capacity of the insert and to examine the behavior of the. connection for combined loading. In specific, the representativeness of the tests to actual plant conditions and the interpretation of the test results was questioned.

1.2 Concrete Strength

. The issue was that Richmond inserts may have been installed in concrete weaker than the 4000 psi design strength used in the analyses.

1.3 Fatigue Life The issue was that the reduction in fatigue life of the threaded rod in j Richmond insert tube steel connections caused by cyclic loading was not .

considered.

1.4 Simplified Evaluation Method The isene was that justification of the simplified method of Richmond in-sert design was based on improperly interpreted finite element analysis results.

1.5 Richmond Insert / Tube Steel Finite Element Modeling The issue was that a simplified method was used in evaluating connections made with tube steel without considering bolt angularity or bending in the bolt due to the torsion in the tube steel member.

Tube steel / insert connections were inconsistently modeled as pin or fixed connections. This affects the support stiffness, support frame stresses, and the evaluations of the loads on bolts / rods and inserts. ,

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1.6 Allowable Spacing The issue was that the lack of a structural attachment interface program i

may have resulted in a failure to consider spacing effects of nearby j anchors / sleeves in the structural evaluation of inserts. l 1.7 Allowable Shear Loads The' issue was that allowable shear loads for 1 1/2 in. Richmond inserts, which were extrapolated from test data for 1 in. and 1 1/4 in. size in-l- serts, may not be conservative.

1.8 Thermal. Expansion of Long Tube Steel Members l

The issue was that thermal expansion of long tube steel members, under LOCA conditions, anchored by two or more inserts was not considered.

1.9 Tube Steel Local-' Stress 4 1 The issue was that the local stress in tube steel walls, which may cause i punching-type failure, was not evaluated.

1.10 Oversized Holes The issue was that the holes made in the connections are oversized, and therefore the sharing of shear loads cannot be assumed to be equal for all g

of the bolts.

1.11 Misuse of Allowable Loads The issue was that tension and shear allowables for inserts were occasion-ally used to evaluate threaded rods / bolts in the analyses.

2.0 Issue Resolution 2.1 Safety factors / Testing SWEC-PSAS has specified a safety factor of 3 for Richmond inserts under normal, upset, and emergency loading conditions, as recommended by the Richmond Screw Company. For faulted conditions, a safety factor of 2 has been specified based on ACI 318-71 (Reference 4.10). The allowables are based on averaging TU Electric insert capacity failure loads based on test results as described in References 4.11 and 4.12. SWEC-Civil / Structural Group has verified (Reference 4.13) that the tests were representative of CPSES Richmond insert installation and that the tests were performed in accordance with the industry-wide accepted ASTM Standard E488-76 (Reference 4.14).

The allowable loads for Richmond inserts and threaded rods, based on the appropriate safety factors, are provided in Attachment 4-5 of CPPP-7.

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\ This issue is addressed in Subappendix A36. I l

2.3 Fatigue Lift j CPPP-7, Section 4.3.1, specifies that threaded rods used in Richmond inserts / tube steel connections are designed in accordance with AISC re-quirements. SWEC-PSAS has demonstrated by analysis that the number of ]

i equivalent stress cycles on pipe supports at CPSES is less than 7,000, and therefore in accordance with AISC 7th Edition (Reference 4.15), Sec-tions 1.7.1 and 1.7.2 and Appendix B, fatigue is not a concern for thread- ,

ed rods used in these connections. j 2.4 Simplified Evaluation Method ,

j The procedure developed and implemented by SWEC-PSAS for the qualification l of Richmond inserts and bolts (Attachment 4-5 of CPPP-7) is independent of I previously completed finite element analyses.

2.5 Richmond Insert / Tube Steel Finite Element Modeling ,

I SWEC-PSAS established the tube steel to bolt load transfer mechanism for shear and torsion loads (with respect to the tube steel) and developed a conservative design methodology for evaluating these connections.

R. L. Cloud and Associates (RLCA) performed an independent analysis of the

, tube steel to bolt load transfer mechanism and confirmed that the SWEC-( PSAS methodology is appropriate (Refe.rence 4.16).

The SWEC-PSAS model simulated a member with bolt properties (in the STRUDL computer program) to connect the center of tube steel to the face of con- j crete. Support joints were modeled as fixed except for the bolt's tor-l sional moment. The force and moment reactions were first used directly in j the interaction equation for qualifying the bolts and were later converted ]

to tension for evaluating the inserts. This interaction equation was doc-umented by both RLCA (Reference 4.17) and SWEC-PSAS (Reference 4.18).  !

This method of analysis represents a conservative means of transferring shear and torsion loads from the tube steel to the bolts. Single tube steel members , subject to torsion, were modified by outriggers installed at the connections to eliminate the moment on the bolt.

Attachment 4-5 of CPPP-7 provides the modeling procedure for qualifying the Richmond insert when used in conjunction with tube steel for all sup-port configuration types, including the proper interaction equation for qualifying the bolts / rods.

2.6 Allowable Spacing Atticbment 4-5 of CPPP-7 specified spacing requirements and the effects of reduceo spacitig on Richmond insert allowables. A project-wide program on Richmond insert spacing, conducted by the SWEC Civil / Structural Group as A

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fs discussed in the Civil / Structural PSR (Reference 4.13), is being imple-mented (also see Subappendix A28, Sections 1.1 and 2.1).

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2.7 Allowable Shear Loads TU Electric performed additional tests (see Section 2.1 above and Refer-ences 4.11 and 4.12) to establish shear allowables for all discrete sizes of Richmond inserts used at CPSES including the 1 1/2 in. Richmond insert.

Design allowable values were based on these tests.

2.8 Thermal Expansion of Long Tube Steel Members  !

The effects of thermal expansion on long tube steel members anchored by two or more inserts was evaluated by RLCA in Reference 4.19, and limits on i tube steel length were established.

Attachment 4-5 of CPPP-7 provides limits on tube steel length of long tube steel members anchored by two or more inserts due to the effects of '

LOCA-induced thermal expansion.

2.9 Tube Steel Local Stress SWEC-PSAS developed and implemented a procedure for the evaluation of lo-cal stresses due to nuts bearing on tube steel walls. This was incorpo-rated into Attachment 4-13 of CPPP-7. For additional discussion of this issue, refer to Subappendix A21, Section 2.0.

n k,) 2.10 Oversized Holes SWEC-PSAS procedures assume equal distribution of shear loads resulting from rod and hole fit-up tolerances, where tubing is anchored by two or more Richmond inserts. However, for Richmond inserts and threaded rods with high shear interaction ratios (greater than 0.25), potential unequal shear loading is addressed by checking that these Richmond inserts and rods are capable of resisting twice the calculated shear (Reference 4.20).

2.11 Misuse of Allowable Loads The SWEC-PSAS procedure for the validation of Richmond inserts and bolts (Attachment 4-5 of CPPP-7) requires separate evaluations for the inserts and for the threaded rods / bolts using specified allowables and interaction equations.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue, l l

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

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• The corrective .ction to resolve the issues regarding the analysis (Q and design of Richmond inserts used in conjunction with tube steel was accomplished through the ic'plementation of the criteria provided in CPPP-7, Attachment 4-5 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References  !

4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), Sections VII and VIII, August 22, 1983 4.2 Reply to NRC Staf f questions from W. A. Horin to G. Mizuno, June 11, 1984 l

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4.3 Reply to NRC Staff questions, September 1984 4.4 Affidavit of CASE witness M. Walsh before the ASLB, September 11, 1984 4.5 Structural Embedments Specification No. 2323-SS-30, Revision 1, Gibbs &

Hill, Inc., February 10, 1984 4.6 Richmond Inserts / Anchorages for Concrete Constructions, Bulletin No. 6, Richmond Screw Anchor Co., 1971 4.7 Testimony of N. H. Williams in response to CASE questions of Febru-

,3 ary 22, 1984, to CYGNA Energy Services, April 12, 1984 f

V) 4.8 June 20, 1984, and August 9, 1984, meeting with NRC Staff discussing Rich-mond Inserts' affidavit 4.9 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987 4.10 ACI Code 1971, Building Code Requirements for Reinforced Concrete, American Concrete Institute, Detroit 4.11 TU Electric Test Report, Shear Tests on Richmond 1 1/2 in. Type EC-6W In-serts, March 30, 1983 4.12 TU Electric Test Report, Shear and Tension Loading on Richmond Inserts, 1 1/2 in. Type EC-6W and 1 in. Type EC-2W, April 19, 1984 4.13 TU Electric Units 1 and Common, Civil Structural Project Status Report, '

Revision 0, October 1987 4.14 ASTM Standard 488-76, Standard Test Methods for Strength of Anchors in )

Concrete and Masonary Elements )

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4.15 AISC Specification for the Design, Fabrication, and Erection of Structural  !

Steel for Buildings, 7th Edition, 1969 )

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( 4.16 RLCA Report No. RLCA/P142/01-85/003, Richmond Insert / Structural Tube Steel Connection, Revision 0, September 10, 1986 4.17 RLCA Report No. RLCA/P142/01-86/008, Richmond Insert / Structural Tube Steel Connection, Design Interaction Equation for Bolt / Threaded Rod, Revision 0, September 10, 1986 4.18 SWEC-PSAS Report No. 15454.05-N(C)-002, Interaction Relation for a Struc-tural Member of Circular Cross Section, May 1986 4.19 RLCA Report, Richmond Insert / Structural Tube Steel Connection Effect of Thermal Expansion of Tube Steel on Richmond Inserts and Bolts 4.20 SWEC-PSAS Project Memorandum 141, Unequal Shear Loading Effect on Richmond Insert and Threaded Rods Used in Conjunction with Tube Steel C\ i t

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\~ / LOCAL STRESS - PIPING 1.0 Definition of the Issue i The issue was (References 4.1 through 4.4) that local stresses in piping, due to the relative displacements between the pipe and supports, were not properly addressed at CPSES in the items listed below:

1.1 Zero Gap Restraints Zero gap restrainto are box frame pipe supports with the specified gap on the pipe support drawing less than the predicted radial ther-mal expansion of the pipe. Therefore, these support types restrain the radial thermal expansion of the pipe. The loads due to the re- ,

strained pipe expansion, combined with the mechanical loads, have the potential to overstress the frame, welds, and pipe. In addition, zero gap restraints used in conjunction with struts or snubbers are potentially unstable.

1.2 Integral Welded Attachments (IWAs)

Integral welded pipe support attachments (IWAs), such as trunnions  ;

and lugs, induce local stresses in the pipe wall. Anchor supports I

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with opposing trunnions attached to different support structures may l

( ) restrain the radial thermal pipe expansion and induce additional load I in the pipe, trunnions, and support structures. l l

The load from r9 strained radial thermal pipe expansion, when combined with the mechanical loads, has the potential to overstress the pipe, trunnion, welds, support structure, and support structure anchorage.

2.0 Issue Resolution The issue of local stress on piping was resolved as follows:

2.1 Zero Gap Restraints Frame-type pipe supports, designed to restrain the lateral movement  ;

of the pipe through point, line, or surface contact, induce local l stresses in the pipe wall due to the bearing contact force. The is-sue of local pipe stress due to bearing contact was resolved as follows:

2.1.1 Zero clearance box frames are eliminated or modified to provide sufficient gaps to allow for the thermal expansion of the pipe in accordance with CPPP-7, Attachment 4-11.

The modification of zero gap restraints on struts or snub-bers, to provide stability, is discussed in Subappendix A4.

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l 2.1.2 Guidelines were provided in CPPP-7, Attachments 4-6B and

(\/,j 4-6C, to assess the local longitudinal line/ point contact and circumferential bearing stresses in piping restrained by pipe support frames.

2.2 Integral Welded Attachments CPPP-7, Attachment 4-6A provided simplified analysis methods for the evaluation of pipe local stress at trunnions and lugs, with and with-out pipe reinforcing pads. The local pipe stress for trunnions on elbows is evaluated in accordance with PM-162. Local pipe stresses at IWAs that did not meet the geometric limitations of the simplified methods (such as multiple trunnions attached at the same location, or pipe-through trunnions) were qualified based on finite element analy-sis techniques.

In accordance with CPPP-7, Section 4.6.4.1, supports with opposing trunnions attached to different support structures were specially analyzed to predict the additional load induced on the pipe, trun-nion, support structure, welds, and support structure anchorage due to the restrained thermal expansion of the pipe. This load was added to the thermal load due to the longitudinal thermal expansion of the pipe to determine the thermal design load for the pipe local stress evaluation and the design of the trunnion, support structure, welds, and support structure anchorage. The trunnion was then analyzed in accordance with CPPP-7, Attachment 4-6A as discussed above, p)

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3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

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• Pipe support modifications resulting from resolution of issues in )

Subappendixes Al through A35 were determined to be reportable under j provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the local pipe stress issues with zero clearance box frames was to eliminate the support or modify the support to provide proper gaps between the pipe and support during l the design validation. The corrective action to resolve the stabili-ty issue for zero gap restraints is discussed in Subappendix A4. The corrective action to resolve the local pipe stress issue with frames and IWAs was to provide analysis methodologies and acceptance crite-ria consistent with licensing commitments in CPPP-7, Attach-ments 4-6A, B, and C during the design validation. All local pipe stress design validation analyses were performed in accordance with these attachments.

• The preventive action for this issue is identified in Appendix C.

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4.0 References 4.1 CASE's Proposed Finding of Fact and Conclusions of Law -(Walsh/Doyle Allegations),Section IV, August 22, 1983.

4.2 CASE's Answer to Applicant's Statement of Material Facts as to which there is no Genuine Issue Regarding Consideration of Local Displace-ments and Stresses, August 24, 1984.  ;

4.3 CASE's Answer to Applicant's Reply to CASE's Answer to Applicant's l Motion for Summary Disposition Regarding Local Displacements and Stresses, October 4, 1984.

4.4 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987.

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I SUBAPPENDIX A3 WALL-TO-WALL AND FLOOR-TO-CEILING SUPPORTS 1.0 Definition of the Issue The issue (References 4.1 and 4.2) was that when a pipe support is at- 1 tached from floor-to-ceiling or wall-to-wall, the support members effec-tively act as building structural members. Loadings due to the thermal expansion of the frame, relative displacements between building attachment points from seismic building movements, time-dependent displacements such as concrete, creep, and the cumulative effects of these could be signifi-cant. Since these loads and displacements were not considered in the de-sign, the potential existed for support members to become overstressed.

2.0 Issue Resolution 2.1 Floor-to-Ceiling and Wall-to-Wall (F-C/W-W) Supports The large F-C/W-W frames were qualified for loading combinations that i incluie frame thermal expansion, differential building displacements  !

due to seismic movements, long-term concrete creep, and live loads.  ;

Relative building displacements, long-term creep, and live load ef-fects were demonstrated to be insignificant for corner supports. The ,

loading combinations and the allowable stresses are delineated in Attachment 4-19 of CPPP-7. j

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( )s 2.1.1 Large Frames Outside the Service Water Tunnel All large F-C/W-W frames, except those in the service water l tunnel, are being modified by adding slip joints.

2.1.2 Large Frames in the Service Water Tunnel The large F-C/W-W frames in the service water tunnel were assessed for stresses caused by floor live load, differen-tial floor / wall displacements due to long-term concrete creep, thermal expansion, and seismic excitation as speci-fled in Section 2.1. Supports assessed as being inadequate are being modified (Reference 4.3).

2.2 Corner Supports A generic study of these supports was performed utilizing the assess- i ment methods in Section 2.1. The supports were then reviewed based on the study results, and the designs were validated. I 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

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• All the pipe support modifications resulting from resolution of is-sues in Subappendixes Al through A35 were determined to be reportable O> under. provisions. 'of- 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective-action to resolve the issue with the proper evaluation of -floor-to-ceiling and wall-to-wall . and corner supports was accom-plished through the implementation,of the criteria of CPPP-7, Attach-ment-4-19 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section VI, August 22, 1983 4.2 CASE's Partial Answer to Applicant's . Statement of Material Facts, in the Fo rm of Affidavit of CASE Witness, Mark Walsh, August 27, 1984 ,

4.3 SWEC-PSAS Report No. 15454.05-N(C)-013 1 Qur.lification of Wall-to- l Wall / Floor-to-Floor Supports, April 1987 4.4 SWEC-PSAS Report No. 15454.05-N(C)-012, Revision,1, Qualification of Corner Supports, June 2, 1987-O A3-2

SUBAPPENDIX A4 k PIPE SUPPORT / SYSTEM STABILITY

'1.0 Definition of the Issue The issue (References 4.1 through 4.5) was that certain pipe support con-figurations installed at CPSES were potentially unstable or their buckling capacity was not properly evaluated. An unstable support is defined as a support that can shift or cove to an unqualified position. An unqualified position is a position other than that assumed in the piping stress analy-sis. A related issue was that the stability of the overall piping systems must be assured.

1.1 Potentially Unstable Support Configurations i

The following are configurations whose buckling capacity was not l properly assessed, or which were potentially unstable because they had the potential to move axially along the pipe and/or rotate around the pipe, creating a three-pin linkage system.

1.1.1 Zero-Clearance Box Frames Supported by Single and/or Multiple Struts or Snubbers Dr Q

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1.2 System Stability The stauility of the overall piping system is dependent upon the sta-bility of each individual support. The issue was that if there were unstable supports in a piping system, then the overall system would be unstable.

2.0 Issue Resolution j

2.1 Potentially Unstable Support Configurations l

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A stable support is a support that cannot shift or move to an unqual-

/ ified position. Unqualified position means a position that exceeds Q] the specified tolerances from the position assumed in the pipe stress analysis.

The stability of supports was assured by qualifying column-strut sup-ports and by modifying potentially unstable configurations in accor-dance with CPPP-7, Section 4.2.4 and Attachment 4.9, as follows:

2.1.1 Zero-Clearance Box Frame Supported by Single or Multiple Struts or Snubbers These support types were either eliminated or modified, such as by removing the existing box frame and replacing it with a standard pipe clamp or rigid frame.

2.1.2 Uncinched U-Bolts on Single Strut or Snubber All supports of this nature were eliminated or are being modified by replacing the U-bolt assembly with a design consistent with the required support function.

2.1.3 Multi-Strutted Gang Support Frames These supports were redesigned as rigid frames.

2.1.4 Trapeze Supports With U-Bolts t

N All supports of this nature were eliminated or are being modified as described in Subappendix A12, Axial, Rotation-al, and Trapeze-Type Restraints.

2.1.5 Column-Strut Stability A procedure to evaluate the critical buckling load of a column-supported strut was developed and is included in CPPP-7, Attachment 4-9.  !

l 2.2 System Stability I The stability of the overall piping system was assured by the following:

1) Each installed support was individually qualified to be stable (in accordance with the definition in Section 2.1).

2) The system integrity was analyzed and qualified to the ASME Section III, Division 1 Code allowables for deadweight, thermal, and applicable occasional loads (fluid transients) and seismic excitations in three orthogonal directions.

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3.0 Corrective and Preventive Action

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• No additional issues were discovered during the review and resolution l of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of pipe support and system stability was accomplished through the analysis methods and support modifications specified in CPPP-7, Section 4.2.4 and Attachment 4-9 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section III, August 22, 1983 4.2 CASE's Motions and Answer to TU Electric's Motions for Summary Dispo-sition Regarding Stability of Pipe Supports, October 15, 1984 4.3 Testimony of N. H. Williams in Response to CASE Question of February 22, 1984, to CYGNA Energy Services f~h

.') 4.4 Letter to Mr. J. B. George of TU Electric from N. H. Williams of CYGNA in reference to stability of pipe supports, April 30, 1985 4.5 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987.

A4-5

SUBAPPENDIX A5 A

k, s PIPE SUPPORT GENERIC STIFFNESS 1.0 Definition of the Issue 1.1 Generic Stiffness Methodology The issue (References 4.1 through 4.6) was that there is no assurance that the assumed set of generic stiffness values used in the piping stress analyses were sufficiently representative of the stiffnesses of the installed supports. Therefore, the results of the pipe stress analyses may not be valid.

Supports were designed to allowable stresses and to a deflection lim-it of 1/16 in. for Level B (upset condition) loads. No check was performed on the support stiffness, since it was assumed that the 1/16-in. deflection limit would ensure that the actual support stiff-ness was acceptably close to the assumed values used in the piping stress analyses.

1.2 Pipe Support Stiffness Evaluation It was also noted that the flexibilities of all pipe support compo-nents, such as U-bolts and base plates, should have been included in the support stiffness calculation.

() 1.3 Effect of Oversize Holes on Pipe Support Stiffness Evaluation The bolt hole sizes for 1 in. diameter bolts were 1/16 in. larger than allowed by the ASME Section III Code of record. The issue was that these oversized holes were ignored in the pipe support deflec-l tion check and therefore could have an unconservative impact on the seismic analysis of the piping system.

2.0 Issue Resolution 2.1 Generic Stiffness Methodology Pipe support stiffnesses were represented in the pipe stress analysis in accordance with CPPP-7, Section 3.10.8.

The following approach was followed to develop a generic stiffness methodology for CPSES.

2.1.1 Determination of Generic Values The following three types of supports were selected from the CPSES pipe supports installed in the plant:

1) Rigid supports, including frames and struts b A5-1 I

2) Anchors 3)- Snubbers i

For rigid supports, generic values were analytically devel- l oped . (Reference 4.7) for groups of pipe sizes. For snub- j bers, generic values were based on snubber sizes. i The - generic values for anchors were developed in terms of nondimensional values, which are independent of pipe sizes. )

The nondimensional stiffness values of all sample anchors for all pipe sizes can thus be used together in developing i histograms. 1 2.1.2 Pipe Support Stiffness Histograms )

For all the supports evaluated, stiffness values were calculated. .l i

Histograms of the calculated stiffnesses (Reference 4.8) were developed and representative - values (median values) determined. j 2.1.3 Minimum Acceptable Stiffness for Use of the General Value To assure that the use of generic values produce valid pipe ,

stress analyses, a minimum stiffness value was established. I O The minimum stiffness was determined with consideration of its effect on thermal, static, and dynamic responses i (Reference 4.7). This approach utilized simplified piping i models and fundamental engineering principles. 1 2.1.4 Screening Procedure ]

Before the beginning of pipe stress analyses, each pipe ,

support was assessed to determine if its stiffness falls l above the minimum stiffness; if so, it was assigned the generic stiffness. When a pipe support's stiffness had been determined to fall below the minimum value, the calcu-lated stiffness value was used in the pipe stress analysis in lieu of the generic value. A set of CPSES generic stiffness values and acceptable minimum values have been incorporated in the design criteria, CPPP-7, j Section 3.10.8.  !

l 2.2 Pipe Support Stiffness Evaluation ]

l In accordance with CPPP-7, Section 4.3.2.2, the stiffness of each j component in the support assembly, such as vendor-supplied compo-nents, structural members, and base plates was assessed in the evalu-ation of the support stiffness.

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To facilitate the support stiffness evaluation, the stiffnesses of p)

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commonly used supports and subassemblies have been provided in graph-ic and tabular forms and incorporated in Attachment 4-18 of CPPP-7.

2.3 Effect of Oversize Bolt Holes on Pipe Support Stiffness Evaluation As discussed in Subappendix A13, Bolt Hole Gaps, CPSES anchor-bolt hole sizes were in compliance with ASME 1985 Summer Addenda NF-4721(a) and are not oversized. Therefore, consistent with industry practice, the effects of bolt hole gaps were not included in the support stiffness assessments.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution 4 of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issuet regarding pipe support generic stiffness was accomplished by implementing the procedures provided in CPPP-7, Sections 3.10.8 and 4.3.2 and Attachment 4-18 during the design validation.

A

• The preventive action for this issue i t, identified in Appendix C.

b 4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations)Section IX, August 22, 1983 4.2 Affidavit of CASE Witnesses J. Doyle and M. Walsh, CASE's Partial Answer to Applicants' Statement of Material Facts as to which there is no Genuine Issue Regarding Applicants' Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis, August 24, 1984, and August 27, 1984 l 4.3 CYGNA Phase 3 Final Report, TR-84042-01, Revision 1, Appendix J, i Note 8, November 20, 1984 );

4.4 N. H. Williams (CYGNA) letter to V. Noonan (USNRC), Open Items Asso-ciated with Walsh/Doyle Allegations, CYGNA Letter No. 84042.022 dated January 18, 1985 4.5 Testimony of N. H. Williams in response to CASE questions of i Februa ry 22, 1984, to CYGNA Energy Services I 4

4.6 CYGNA Pipe Support Review Issues List Revision 4, CYGNA Letter No. 84056.120 dated September 18, 1987

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4.7 SWEC-PSAS Report No. 15454-N(C)-003, Generic Pipe Support Stiffness Values for Piping Analysis, September 1986 4.8 Pipe Support Generic Stiffness Study, CPPA-48,974, TU Electric, February 13, 1986 O

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L I SURAPPENDIX A6 O

l V UNCINCHED U-BOLT ACTING AS A TWO-WAY RESTRAINT l

1.0 Definition of the Issue The issue (References 4.1 and 4.2) was that certain uncinched U-bolts at-tached to rigid frames were modeled and analyzed as one-way restraints i I (i.e., as providing restraint in the direction parallel to the axis of the threaded portion of the U-bolt) but will actually behave as two-way re-straints (i.e., as stated above and laterally). This was viewed as having a two-fold effect:

1.1 Modeling Failure to include the two-way restraining action of the U-bolts may invalidate the results of pipe stress analyses that utilized U-bolts modeled as one-way restraints.

1.2 Uncinched U-Bolt Qualification Guideline Such U-bolts may not meet the manufacturer's recommended interaction limits when the lateral loads are applied.

2.0 Issue Resolution 2.1 Modeling 2.1.1 For pipe sizes equal to or greater than 8 in. NPS, uncinched U-bolts were replaced in the model with a compo-nent commensurate with the support function.

2.1.2 In the piping analysis, uncinched U-bolt supports for pipe .

sizes 6 in. and smaller that are attached to rigid frames i were modeled as two-way restraints.

2.2 Uncinched U-Bolt Qualification Guideline 2.2.1 STRUDL models of U-bolts were developed to derive the stiffness value and resultant loading (moment, shear, and tension) at the attachment to the frame. For static (i.e.,

signed) loads, a friction coefficient of 0.3 was considered to act in the axial direction of the pipe. Resolution of the friction issue is discussed in Subappendix A7.

2.2.2 Based on the above STRUDL analyses, allowable U-bolt load ratings were developed, j 2.2.3 The uncinched U-bolt qualification procedure was incorpo-rated in Section 4.2.5.2 and Attachment 4-3 of CPPP-7.

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f 2.2.4 Stiffness values for uncinched U-bolts, modeled as.two-way i restraints were developed and issued in CPPP-7, Sec-tion 4.3.2.2 and Attachment 4-18, 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting ' from resolution of issues in l- Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the concern of U-bolts acting as two-way restraints was accomplished by. implementing the criteria of CPPP-7, Sections 4.2.5.2 and 4.3.2.2, and Attachments 4-3 and 4-18 during the design validation. .;

! *- The preventive action for this issue is identified in Appendix C. ,

4.0 References i

'l 4.1 CASE's Proposed Findings of Fact and Conclusions of Law, (Walsh/Doyle i Allegations)Section II, August 22, 1983 ,

4.2 CASE's Answer to Applicant's Motion for Summary Disposition of CASE's Allegations Regarding U-Bolts Acting as Two-Way Restraints, August 20, 1984 l I

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SUBAPPENDIX A7 (j FRICTION FORCES 1.0 Definition of the Issue The issue (References 4.1 through 4.4) was that friction loads were not considered in the original pipe support designs when the predicted pipe movement was less than 1/16 in.

2.0 Issue Resolution Friction loads were considered in the validation of pipe supports at CPSES. Section 4.7.3 and Attachment 4-7 of CPPP-7 required that friction be considered in all load cases for noneyclic loads (i.e., static and/or steady state loads) regardless of the magnitude of pipe movement.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

n i,

The corrective action to resolve the issue of friction forces was accomplished through the implementation of the criteria provided in CPPP-7, Attachment 4-7 during the design valiation.  !

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section XVI, August 22, 1983.

4.2 CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces in the Design of Pipe Supports with Small Thermal Movements, August 6, 1984.

4.3 CASE's Answer to Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces, October 1, 1984.

4.4 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal i Letter No. 84056.120 dated September 18, 1987 i l

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SUBAPPENDIX A8 l-l'Vh AWS VERSUS ASME CODE PROVISIONS i

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l N 1.0 Definition of the Issue l l

The issue - (References 4.1 through 4.4) was that certain aspects of weld

(- design, welding practices, and the effects of punching shear (local stress) on structural members were not adequately addressed. The items ,

discussed are grouped into the following four. groups:  !

1.1 Skewed T-Joint Welds The issue was that the effective throats of skewed T-joint welds were incorrectly calculated in the original design. The AWS angle limita-tion between the joined parts was violated in the evaluations of 4

skewed T-joint welds at CPSES.

1.2 Effective Throat of Flare Bevel Welds j The issue was that since the ASME Code does not adequately address-the determination of the effective throat for flare bevel welds, f there is no assurance that the evaluations of these welds were prop-erly performed.

1.3 Welding Practices j The issue was that since the ASME Code does not adequately address various welding practice related items such as preheat requirements, i cap welding, weave welding, downhill welding, drag and work angles (which limit the space allowed for welders to function), and lap joint requirements, that these welding processes may not have been properly addressed in the existing welding procedures.

1.4 Punching Shear (Local Stress) )

1 I

The issue was that punching shear has not been considered in the de-  !

signs at CPSES since the ASME Code does not adequately address this  !

subject. Local stresses, which can be significant, develop in the  !

immediate vicinity of the joint between two members. Based on the l it lative sizes of items joined, one member tends to punch through the wall of the other.

2.0 Issue Resolution 2.1 Skewed T-Joint Welds Pipe support welds at CPSES were installed in accordance with Weld Procedure BR-WPS-11032. Weld configurations contained in this procc-dure were qualified by testing in accordance with ASME Section III, A8-1 l

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, , . Subsection NF requirements; therefore, the limitations of prequalified welds did not apply.

lO) Guidelines for the design validation of the effective throat of skewed T-joint welds were incorporated in CPPP-7, Attachment 4-2.

These requirements were consistent with AWS D1.1.

2.2 Effective Throat of Flare Bevel Welds Resolution of the issue regarding the determination of the ef fective throat for flare bevel welds is addressed in Subappendix A10.

2.3 Welding Practices Resolution of the issues regarding inadequate weld procedure-related items is addressed in Subappendix A27.

2.4 Punching Shear (Local Stress)

Resolution of the issue regarding the evaluation of local stresses in the walls of structural pipe support members is addressed in Subappendix A21, 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution 7"N of this issue.

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• Pipe support modifications resulting from the resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of AWS versus ASME Code provisions was accomplished through the implementation of the crite-ria provided in Section 4.4 and Attachment 4-2 of CPPP-7 during the design validation.

• The preventive action for this issue is identified in Appendix C.

j 4.0 References l

4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle I allegations),Section V, August 22, 1983.

4.2 CASE's Answer to Applicant's Statement of Material Facts as to which there is no Genuine Issue Regarding Certain Case Allegations Regard-ing AWS and ASME Code Provisions Related to Design Issues, August 4, 1984.

I 4.3 NRC Staff Response to Applicant's Motion for Summary Disposition on AWS and ASME Code Provisions on Weld Design, November 2, 1984.

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4.4 Affidavit of David Terao on AWS and ASME Code Provisions on Weld De-O sign, November 2, 1984.

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l SUBAPPENDIX A9 i

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I d A500, GRADE B TUBE STEEL 1.0 Definition of the Issue The original design of CPSES pipe supports used a design yield strength Sy of 42 ksi for A500, Grade B, tube steel (cold formed) in accordance with ASME Code Case N-71-9. Later versions of ASME Code Cases N-71-10 through N71-14 revised the yield strength from 42 ksi to 36 ksi. Therefore, the issue (References 4.1 through 4.4) was that all designs for tube steel supports'at CPSES should be revised to incorporate the lower design yield strength.

2.0 _I_ssue Resolution 2.1 Basis of ASME Code Case Revision The basis of the ASME Section III NF Code Committee revision of ASME Code Case N-71-9 (42 ksi) to N-71-10 (36 ksi) is the concern that the yield strength in the heat-affected zone at weldments could be '

slightly reduced. Since test data were not available at the time to quantify the reduction, the ASME Section III Code allowable for A500 Grade B (cold-formed tube steel) was reduced to that of A501 (hot-formed). The Code Committee's action was considered a conservative measure.

h(3 The Code Committee has evaluated test data on this issue. The test data demonstrate that the yield strength in the heat-affected zone of A500 Grade B tube steel is not reduced below 46 ksi.

ASME Code Case N-71-15, which specifies Sy = 46 ksi for A500 Grade B7 tube steel in rectangular shapes, was issued in December 1986.

2.2 SWEC-PSAS Validation The design of pipe supports using A500, Grade B tube steel at CPSES were validated using a yield strength of 36 ksi in accordance with CPPP-7, Section 4.7.2.1.

Pipe supports where the calculated stress exceeded 36 ksi but did not exceed 42 ksi were not modificd. The yield stress of 42 ksi is based on ASME Section III Code Case N-71-9 which is consistent with CPSES licensing commitments and is acceptable and conservative in light of ASME Section III Code Case N-71-15 which specifies the allowable yield strength of A500 Grade B tube steel as 46 ksi.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution ,

of this issue. l l

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• Pipe support modifications resulting from resolution of issues in Subappendix Al through A35 were determined to be reportable under j lV) provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36),

l

• The corrective action to resolve the A500, Grade B tube steel issue was accomplished through the implementation of criteria provided in CPPP-7, Section 4.7.2.1, during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 Affidavit of W. P. Chen on Revised A500 Steel Yield Values, May 29, 1984 4.2 Testimony of N. H. Williams in Response to CASE Questions of f February 22, 1984, to CYGNA Energy Services  ;

4.3 Meeting Between CASE and TU Electric with SWEC in Attendance, Large Bore Pipe Supports, March 12, 13, and 14, 1987 i

4.4 CYGNA Pipe Support Review Issues List, Revision 4, Transmittal Letter No. 84056.120 dated September 18, 1987 l

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rN. SUBAPPENDIX A10 TUBE STEEL SECTION PROPERTIES 1.0 Definition of the Issue 1.1 Section Properties The section properties for A500 Grade B cold-formed tube steel used in the pipe support design at CPSES had been obtained from three au-thoritative source documents. Each source document listed small dif-ferences in section properties based on different nominal corner tangent radii (RT) as follows:

a. AISC Manual of Steel Construction, 7th Edition, RT E 3t.

(t = thickness of tube steel wall)

b. 1974 Welded Structural Tube Institute (WSTI) Manual of Cold-Formed Welded Structural Steel Tubing, RT E lt.

c. AISC Manual of Steel Construction, 8th Edition, RT E 2t.

These small differences in nominal section properties led to the con-tention that tube steel milled prior to 1980 had different corner radii and that tube steel had been procured for use at CPSES both l

.'_} prior to and af ter 1980. Therefore, the issue was that the vintage V of the tube steel must be established and the proper section proper- ,

ties used (References 4.1 and 4.2). l i

1.2 Effective Throat of Flare Bevel Welds The 8th Edition of AISC states that the effective throat of flare bevel groove welds is t = 5/16 R unless it can be established that a i larger effective throat

• can be obtained. The design of flare bevel l

welds at CPSES used two different effective throats of t* = 0.645t l

and t = t.

e Because of the differences in assumed corner radii of tube steel, the effective throat evaluation of flare bevel welds was questioned.

i 1.3 Bolt llole Ef fects The issue was that the effect of bolt holes on section properties had not been considered in the design.  :

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2.0 Issue Resolution 2.1 Section Properties SWEC reviewed the material manuf acturer's dimensional standards for A500, Grade B tube steel supplied to CPSES.

The review was performed for ASTM A500 (standard specification for cold-formed welded and seamless structural tubing in rounds and shapes), which included a 12 year span starting from issue date 1974 through 1986. Since the standard mill tolerances did not change dur-ing this period of time, it was concluded that the fabrication toler-ances and section properties of tube steel members in CPSES have been maintained to a consistent standard.

SWEC-PSAS also confirmed that Welded Steel Tube Institute (WSTI) amended its 1974 issue to agree with the 8th Edition of the AISC.

This amendment is the latest revision to date. These section proper-ties are based on a nominal corner tangent radius of 2t and are con-sidered representative of cold-formed tube steel.

SWEC-PSAS resolutions are summarized as follows:

• The use of section properties in AISC Manual of Steel Construc-tion, 8th Edition is appropriate, since it represents the actual cold-formed tube steel used at CPSES.

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• The 8th Edition of AISC is used by SWEC-PSAS in the selection of section properties for structural tube steel.

• SWEC-PSAS surveyed tube steel corner dimensions on installed supports at CPSES (Reference 4.3) and confirmed that the in-stalled supports have a nominal 2t corner radius.

• Section 4.3.2.1 of CPPP-7 specifies that structural tube steel section properties are selected from the 8th Edition of the AISC steel manual.

2.2 Effective Throat of Flare Bevel Welds SWEC-PSAS performed a survey of tube steel dimensions on installed ASME Section III, Subsection NF pipe supports at CFSES and weld tests of worst-case configurations to determine the appropriate effective throat to be used for flare bevel welds (Reference 4.3). Based on the results of this survey, it was concluded that an effective throat of t =t- 1/16 in. is justified for all tube sizes except TS 2 x 2.

For #TS 2x2 sections, an effective throat t *

= t- 1/8 in. is appropriate.

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1 q Existing welds on TS ' 2 x 2 sections ' are qualified to - the t = i t - 1/8 in, criteria, unless ' it is verified that the weld haI a larger effective throat by performing a field inspection of the weld in accordance with the methods described in SWEC-PSAS Project Memo-randum No. 140.(PM-140).

Specification No. 2323-MS-100 was revised on March 2, 1987 to' assure that an effective throat'of t = t - 1/16 in. is achieved for welds

~

on TS 2 x 2 tube steel for any* subsequent work.

Section 4.4 and Attachment 4-2 of CPPP-7, as amended by SWEC-PSAS PM-140, specify the effective throats of flare bevel welds. l i

2.3 Bolt Hole Effects The section properties. for tube steel are reduced for the effects of bolt holes as required by CPPP-7, Section 4.3.2.1 which is in accor-dance with the requirements of ASME Section III, Appendix XVII requirements.  !

3.0 Corrective and Preventive Action 1

• No additional issues were discovered during the review and resolution of this issue,  !

• Pipe support modifications resulting from resolution of issues . in Subappendix Al through A35 were determined to be . reportable under j

\ provisions- of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action for tube steel section properties and bolt hole j effects was provided in Section 4.3.2.1 of CPPP-7. The corrective  !

action for the - effective throats of flare bevel welds was accom-plished.through the implementation of the criteria provided in Attach-ment 4-2 of CPPP-7 and SWEC-PSAS PM-140 during the design validation. j

• The preventive action for this issue is ider.tified in Appendix C.  !

i 4.0 References  !

4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle I Allegations),Section XVIII, August 22, 1983 4.2 CASE's Answer to Applicants' Statements of Material Facts as to Which There Is No Genuine Issue Regarding CASE's Allegations Regarding Sec-tion Property Values, August 12, 1984 4.3 SWEC-PSAS Report No. 15454-N(C)-004, Survey of Structural Tube Steel Dimensions to Verify the Effective Throat of Flare Bevel Welds, March 1987 i

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SUBAPPENDIX All

/N E-s U-BOLT CINCHING

-1.0 Definitio'n of the Issue.

The following issues - (References 4.1 L through 4.6) ' were raised regarding the use of cinched U-bolt supports with single struts or snubbers.

1.1 Evaluation of the Cinched U-Bolt Assembly-The stresses in the run pipe, the U-bolt, and the support. cross-piece due to the combined effect of preload (i.e. , cinching), pipe thermal and pressure expansion, and external _ loadings were not considered in the design of the cinched U-bolt supports.

1 1.2 Use of SA-36 and A307 Material for Cinched U-Bolts.  ;

i 1.2.1 Preload Maintenance SA-36 material is .similar to A307 material, which is prohibited  !

in the AISC Code, 7th Edition, Table 1.5.2.1, as bolting materi-al in friction connections. Maintenance of joint preload is the underlying issue.

p 1.2.2 Fatigue U ASME Section III, Appendix XVII, Table XVII-3230-1, Footnote '4, and' AISC 7th Edition, Appendix B, Table B2, Footnote 4, recom-mend that A307 bolts not be used in connections subject to j stress reversal. Fatigue of the A307 material is the issue.  !

Both these issues regarding the ' use of A307 material were ex- 'i

. tended to the SA-36 U-bolt used in cinched U-bolt supports.

1.3 Preload-Torque Relationship {

The established preload-torque relationship was questioned, especial- l

'ly. in light of the potential ~ for galling under U-bolt nuts while l tightening. l l

1.4 Stability of Cinched U-Bolt Supports j The stability of the cinched U-bolt pipe support assembly is depen-  !

dent on attaining and maintaining the required preload. In light of the uncertainty in the preload-torque relationship, as discussed in ,

Section 1.3, and the issue regarding the fatigue life and preload l maintenance ability of A307 material, as discussed in Section 1.2, [

the stability of cinched U-bolt supports with struts and snubbers was l questioned.

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2.0 Issue Resolution v] Due to the extensive engineering effort required to validate cinched U-bolt type supports with struts or snubbers, and the uncertainty in the ability to attain and ma d ntain required preload levels, all cinched U-bolt supports .with struts or snubbers are deleted or modified to other stable support designs consistent with the required support functions.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issues of 1) the proper evalua-tion of the pipe and cinched U-bolt assembly, 2) the use of SA-36 material in cinched U-bolts, 3) the preload-torque relationship, and 4) stability, is 'oeing accomplished through the elimination or modification of cinched U-bolt supports with struts or snubbers in accordance with the criteria provided in CPPP-7, Section 4.2.5.1 used during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Finding of Fact and Conclusions of Law, (Walsh/Doyle Allegations)Section IV, August 22, 1983 4.2 ASLB Memorandum and Order at 27, 28, 33-41, December 28, 1983, and reconsidered in Memorandum and Order at 25-6A, 20-4C, February 8, 1984 4.3 Westinghouse Report No. WCAP-10620, U-bolt Support / Pipe Test, July 1984 4.4 Westinghouse Report No. WCAP-10627, U-bolt Support Assembly Finite Element Analysis, July 26, 1984 4.5 CASE Answer to Applicant's Statement of Material Facts as to Which There is No Genuine Issue Regarding to Consideration of Cinched U-bolts, Affidavit of CASE Witness J. Doyle, October 8, 1984 4.6 CYGNA Pipe Support Review Issues List (RIL), Revision 4, Transmittal Letter No. 84056.120 dated September 18, 1987 l

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SUBAPPENDIX A12

! 1

\s / AXIAL / ROTATIONAL RESTRAINTS 1.0 Definition of the Issue Three groups of axial and/or trapeze-type supports listed below use welded lug or trunnion attachments to transfer loads to frames or component hardware.

a. Single or dual trunnions with component supports

b. Non-trunnion component supports

• Trapeze supports with U-bolts

• Riser clamps with dual components

• Riser clamps with single components

c. Frame supports with lugs The issues (References 4.1 and 4.2) regarding these specific types of sup-ports are summarized as follows:

1.1 Rotational Load g'~g The issue was that rotational restraint effects must be treated as a

() primary load for the support design.

1.2 Eccentric Loading The issue was that eccentric loading, which can result from effects such as differential snubber lockup and support steel stiffness vari-ations, must be considered in the design process.

1.3 Snubber Lockup The issue was that snubber end clearance effects may cause signifi-cant increase in loads or invalidate linear analysis results.

1.4 Lug / Frame Design Load i j

The issue was that multiple lug configurations must consider a con-servative loading distribution for lug and frame design.

1.5 Clearances l The issue was that insufficient clearances or eccentricities may ex-I ert rotational restraint on the pipe.

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j 2.0 Issue Resolution q

2.1 Rotational Load The eccentric line of action of single component riser clamps and single axial trunnion, and the rotational resistance to the pipe of dual trunnion-type supports, were modeled in the pipe stress analy-sis. The pipe supports were design validated considering the result-ing load as a primary load.

2.2 Eccentric Loading The'effect of differential snubber lockup in the dual trunnion sup-port was addressed by increasing the design load on each trunnion snubber and its supporting structure by 20 percent. The variation in support steel stiffnesses for dual component riser clamps was ad-dressed by limiting the acceptable variation in stiffness between the supporting structures for each component and increasing the component design load from 50 percent to 75 percent of the total support design load.

Four lugs are typically used for nonintegral axial clamp supports.

Each lug was validated to 50 percent of the total load for dual com-  ;

ponent supports modeled as a single component.

Dual component riser clamps with variations in support stiffnesses exceeding the acceptable value were modeled in the stress analysis as (q

• eccentric (one-sided) transnational restraints, and the support is being modified by the removal of the component on the softer side.

For such eccentrically modeled supports, the load for each lug is j based on statics with the assumption that all of the moment is react- i ed at the lugs, i.e., the clamp-to-pipe connection does not resist the moment. ]

Trapeze supports with cinched U-bolts are being eliminated or modi-fied to provide a stable support configuration consistent with sup-port function as discussed in CPPP-7, Attachment 4-8.

2.3 Snubber Lockup To assure valid stress analysis results, snubber pairs used in dual component applications (dual trunnions and riser clamps) are matched as defined in Reference 4.3.

2.4 Lug / Frame Design Load Lugs for rigid frame-type axial restraints were each validated for the total load if only two lugs are used, or 50 percent of the total load if four lugs are used.

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-s Analysis of load distribution at lug / frame interfaces was based on

[ CPPP-7, Attachment 4-8, which maximized the critical stress in the

\ frame.

2.5 Clearances The clearances between the pipe and the frame and the lugs and riser clamps and frame are controlled in accordance with CPPP-7, Attach-ment 4-11 to assure proper function of the pipe support. Pipe support eccentricities are discussed in Section 2.2 above.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of axial / rotational re-straints was accomplished through the implementation of the criteria in CPPP-7, Section 3.10.6.2 and Attachment 4-8 of CPPP-7.

• The preventive action for this issue is identified in Appendix C.

p 4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Alle-gations),Section XII, August 22, 1983 4.2 Affidavit of Case Witness Mark Walsh - CASE's Partial Answer to Appli-cant's Statement of Material Facts as to Which There was No Genuine Issue Regarding Allegations Concerning Consideration of Force Distribution in Axial Restraints, August 27, 1984 4.3 Nuclear Standard, Mechanical and Hydraulic Snubbers for Nuclear Applica-tion, NE-E7-9T, September 1984, U.S. Department of Energy, Nuclear Energy Program f

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.SUBAPPENDIX A13

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%. BOLT H0LE GAP 1.0> Definition of the Issue-Bolt hole gap, as used herein, refers to the radial clearance between an anchor bolt and the bolt hole edge in pipe support member / base plates.

Issues regarding the effect of bolt hole gaps are as follows (Refer-ences 4.1 to 4.4):

1.1 Oversized Holes <

The issue was that bolt holes in support base plates are oversized.  !

Bearing connections are not allowed if the bolt hole is greater than l the standard size hole specified by the AISC Code.

1.2 Shear Distribution The ' issue was that it is impossible to predict how many bolts are involved in the transfer of shear. Inelastic action that distributes I the shear load to all anchor bolts is appropriate for static loads only.

1.3 Effect on Support Stiffness The issue was that the presence of gaps in joints under dynamic con- j

- ditions adversely affects the stiffness of the pipe support and its seismic response. . The usual procedure is to assume that two bolts react to the load regardless of the number of bolts in the pattern. i i

2.0 Issue Resolution l 2.1 Oversized Holes ,

Hole sizes allowed by the ASME Section III Code, paragraph NF-4721, were compared to existing hole sizes at CPSES as shown below.

ASME Code Table NF-4721(a)-1 specifies the allowable bolt hole sizes for bearing-type connections as follows:

l Bolt Size Hole Size Equal to or-less than 1 in. Bolt diameter +1/16 in, j Between 1 and 2 in. Bolt diameter +1/8 in. I The allowable bolt hole sizes of the installed CPSES base plates were as follows: l l

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,_ Bolt Si_ze Hole Size I )

\s / Equal to or less than 3/4 in. Bolt diameter +1/16 in.

1-in, to 1 1/2 in. Bolt diameter +1/8 in.

Therefore, it was concluded that only the bolt holes for 1-in. diame-ter bolts at CPSES have an allowable size larger than the code allow-able (by 1/16 in.). The 1985 Summer addenda of the ASME Section III Code, paragraph NF-4721(a) clarified that for anchor bolts, the hole size may be increased by 1/16 in. over the values specified in Table NF-4721(a)-1.

ASME Section III, 1985 Summer Addenda NF-4721(a) was added to the  :

CPSES Code of Record in CPPP-7, Section 2.2, and Specification No. MS-46A (Reference 4.5).

2.2 Shear Distribution

(

Design of base plate connections at CPSES is based on standard steel design practices where equal shear load sharing among bolts is used.

This practice is described in References 4.6 and 4.7, which compare the ultimate shear load sharing in plate connections to the equal distribution assumed at design levels.

Support designs at CPSES were examined and it was concluded that the d Richmond insert to tube steel connection may not be covered by these

(j

(_,

g normal practices. Therefore, Richmond insert to tube steel connec-tion designs are reviewed in accordance with SWEC-PSAS Project Memo-

)

randum No. 141 (PM-141) to confirm that unequal shear load sharing is not an issue.

2.3 Effect on Support Stiffness .

1 l

The effect of bolt hole gap on support stiffness is discussed in Appendix AS.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution i of the issue. )

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36),

• The corrective action to resolve the bolt hole gap issue was accom-plished through the implementation of the criteria provided in CPPP-7, Attachments 4-4 and 4-5, SWEC-PSAS PM-141, and Specification No. MS-46A during the design validation.

• The preventive action for this issue is identified in Appendix C.

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i 4.0 References -

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(,) 4.1 ' CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle  :

Allegations),Section XXI, August 22, 1983 4.2 CASE's Answer to the Applicants' Statement of Material Facts in the Form of Affidavit of CASE Witness M. Walsh, August 12, 1984 4.3 CYGNA's response to CASE Question No. Doyle 16 4.4 CASE's 4th Round Answer to Applicants' Reply to CASE's Answer to Ap-plicants' Motion for Summary Disposition Regarding the Effects of Gaps, December 19, 1984 4.5 Comanche Peak Nuclear Safety Class Pipe Hangers and Supports Specifi-cation No. 2323-MS-46A, Revision 7, July 6, 1987 4.6 B. Kuzmanovic and N. Williams, Steel Design for Structural Engineer, 2nd Edition, 1983, Prentice Hall, Inc., page 321 4.7 C. Salmon and J. Johnson, Steel Structures Design and Behavior, 1971, Intext Educational Publishers i

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SUBAPPENDIX A14 I

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'( OBE/SSE DAMPING 1.0 Definition of the Issues i The issue (References 4.1 to 4.4) was that the improper damping values were used in the stress analysis at CPSES.

1.1 NRC Regulatory Guide 1.61 Damping  ;

The issue was that piping systems containing active components (e.g.,

valves) used the damping for piping which was higher than the damping prescribed by NRC Regulatory Guide 1.61 (Reference 4.5) for active '

valves.

Damping values higher than the allowables in NRC Regulatory Guide 1.61 were used in the pipe stress analysis at CPSES.

1.2 Damping for Mixed Size Piping The issue was that in certain pipe stress analysis packages which are comprised of piping of different sizes, the damping values for the l

12-in. or greater piping were used even though the pipe stress analy-sis package contained piping smaller than 12 in.

/7 i 2.0 Issue Resolution 2.1 NRC Regulatory Guide 1.61 Damping CPPP-7 Section 3.4.5.4.1 specified the use of NRC-recommended damping values for piping addressed in NRC Regulatory Guide 1.61. In fact, the NRC has recently approved the higher damping values for piping systems contained in ASME Code Case N-411 (Reference 4.6). There-fore, the lower damping for active components in NRC Regulatory ,

Guide 1.61 is not applicable to the CPSES piping system analysis, j 2.2 Damping for Mixed Size Piping CPPP-7 specified that mixed-size piping systems (containing pipes above and below 12-in. NPS) are conservatively evaluated with the lower damping values of NRC Regulatory Guide 1.61. i Use of the damping values specified in ASME Code Case N-411 that are applicable to all pipe sizes was approved for implementation at CPSES by the NRC Staff. CPPP-7 authorized the use of Code Case N-411 for all systems, including mixed-size CPSES piping systems, except where stress analysis is performed using the Independent Support Motion Method.

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3.0 Corrective and Preventive Action

• No additional issues were discovered'during.the review and resolution of this issue.

• All the pipe support modifications resulting from resolution of is-i sues in Subappendix Al through A35 were determined to be reportable under provisions of 10CFBT,0.55 (e) _

(see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve OBE/SSE damping issue was accom-plished through the implementation of the criteria provided in

~CPPP-7, Section 3.4.5.4.1 during the design validation.

• The ' preventive . action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Dcyle Allegations),Section XXII, August 22, 1983 4.2 C/iSE's Answer to Applicant's Motion for Summary Disposition Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE-Loading Conditions, August 6, 1984 4.3 CASE's Answer to Applicant's Reply to CASE's Answer to Applicant's

.O b/

Motion Re.ghrdir.g Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions, October 2, 1984 4.4 CYGNA Pipe Stress Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987

-4.5 USNRC Regulatory Guide 1.61, Damping Values for Seismic Design of '

Nuclear Power Plants, October 1973 4.6 NRC Letter from V. S. Noonan to W. G. Counsil dated March 13, 1986, Evaluatlon of Request for Use of ASME Code Cases N-397 and N-411 A14-2' L_i____ _ _ _

SUBAPPENDIX A15 SUPPORT MASS IN PIPING ANALYSIS 1.0 Definition of the Issue The issue was that the mass contribution of the support to the piping sys- I tem is significant and it cannot be omitted from the analysis (Reference 4.1).

The support mass contribution to the piping model was not always consid-cred in the CPSES pipe stress analysis, because it was considered small relative to the total mass of the piping system.

2.0 Issue Resolution The support mass, eccentric and nonec entric, was accounted for in pipe stress analyses in accordance with CPPP-7, Section 3.10.4. A detailed procedure for pipe support mass determination and inclusion in the piping system analysis was included in Attachment 3-4 of CPPP-7, with additional guidance on the modeling of eccentric mass included in Attachment 3-11.  !

I 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution m of this issue.

I \

V

• All the pipe support modifications resulting from resolution of is-sues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the support mass in piping analysis issue was accomplished through the implementation of the criteria provided in CPPP-7, Attachments 3-4 and 3-11 during the design validation.

• The preventive action for this issue is specified in Appendix C.

4.0 References 4.1 CASE'S Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section XIV, August 22, 1983 1

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l SUBAPPENDIX A16 Li k PROGRAMMATIC ASPECTS AND QA INCLUDING ITERATIVE DESIGN 1.0 Definition of the Issue The following miscellaneous. issues with programmatic aspects and QA were

. identified (References 4.1 and 4.2).

1.1 Fragmented Responsibility and Interface Control The issue was that inadequate interface control and fragmented re-sponsibilities - between analysis, design, and construction phases of piping and support design phases resulted in numerous inadequacies and inconsistencies.

l'. 2 Iterative Design The issue was'that the identification and correction of design errors was delayed until the end of the iterative design process.

1.3 Quality Assurance and Personnel The issue was that calculations did not follow project guidelines for quality assurance. No standards were specified for the qualification of personnel at different levels.

1.4 Timeliness The issue was that problems which were generic in nature were not resolved promptly, resulting in numerous deficiencies of a similar nature.

1.5 Construction and Field Changes The . issue was that procedures for construction and installation were inadequate and were not kept up to date. Field changes were not ap-proved, and resulted in calculations justifyint as-built conditions.

1.6 Procedures The issue was that frequent changes and lack of adequate control of procedures resulted in many violations of the procedures.

1.7 Calculation Errors The issue was that in random checks of calculations, numerous errors were found.

I A16-1

1.8 Miscellaneous V The issue was that various other issues were raised regarding the updating of criteria and the adequacy of various practices used in design / qualification activities.

2.0 Issue Resolution i SWEC-PSAS's Management Plan for Project Quality, CPPP-1 (Reference 4.3), i outlines SWEC-PSAS's approach to resolving the various programmatic issues through issuance of Proj ect Procedures, which implement SWEC corporate procedures (Engineering Assurance Procedures, and Quality Standards).

CPPP-1 addresses each of the 18 criteria of 10CFR50, Appendix B. The in-dividual issues listed in Section 1.0 are resolved as follows: ,

2.1 Fragmented Responsibility and Interface Control The issue of fragmented responsibility between piping analysis and support design was resolved by the integrated design process in the SWEC-PSAS validation program.

All ASME Section III Code Class 2 and 3 piping systems and all ASME Section III Code Class 1, 2, and 3 supports were validated by SWEC-PSAS'in accordance with CPPP-7 which provides consistent crite-ria for both pipe stress analysis and pipe support design. Each pipe stress analysis package was reviewed in accordance with Section 7.3

% of CPPP-6, as a system, by pipe stress and pipe support engineers to assure that the interactions between the pipe stress and the pipe support efforts are properly accounted for in the SWEC-PSAS portion of the Corrective Action Program (CAP).

)

As part of the integrated design process, interfaces between analy-sis, design, and construction are controlled in accordance with CPPP-6. Personnel performing the validation effort are trained by project management in the use of the applicable project procedures.

2.2 Iterative Design Design criteria changes were issued during the pipe stress and pipe i support validation by means of controlled documents (project memoran-da) and revisions to CPPP-7. Prompt review was required for any de-sign criteria changes containing the potential for support modification.

As-built verification of piping and pipe supports is being performed as part of the PCHVP. All modifications are provided to TU Construction via procedurally controlled design change documenta-tion prepared by SWEC-PSAS.

A16-2 i

2.3 Quality Assurance and Personnel'

-SWEC-PSAS's Management Plan for- Project Quality (CPPP-1) identifies j the procedures to be followed during the generation and review of .

l project calculations. -These ' procedures appropriately emphasize re-view of calculations for technical adequacy of the resulting designs L!

(calculation conclusions). The emphasis on review for technical ade-  ;

quacy assures that any inconsistencies / documentation discrepancies will not affect the overall . conclusion of the calculations. All l identified occurrences of inconsistencies and documentation discre- i pancies are promptly resolved. I Engineering personnel are assigned to tasks after an etaluation of their ability to perform that task. This evaluation is initiated by )

verification of the employee's academic and professic.nal credentials and employment history in conjunction with the normal employmeri in-terviews. Personnel are then assigned to work at an appropriate lev-el under a supervisor. The supervisor is responsible for evaluating and training the employee. This process assures that appropriately qualified personnel are assigned to all engineering tasks.

Personnel involved'in the validation effort were trained in the use of the applicable project procedures.

2.4 Timeliness Early in the validation process, all. CPRT and external issues were

-( .

identified and SWEC-PSAS resolutions to these issues were developed.

During the design validation, any additional issues identified were addressed in a timely manner and appropriate corrective and preven-tive ections identified and implemented.

2.5 Construction and Field Changes .q Field changes were controlled by SWEC-PSAS project procedures which required that new designs, modifications, or reconciliations with as-built conditions be documented and approved by qualified respon-sible -engineers. Walkdowns in accordance with SWEC-PSAS procedures, as well as inspection under the PCHVP, assured that the as-built con- 1 dition of piping and pipe supports was properly reflected in the de-sign validation.

2.6 Procedures Controlled copies of CPPP-6 and CPPP-7 (and revisions / changes there-to) were issued to the pipe stress and pipe support supervisory per-sonnel assigned to the SWEC-PSAS CPSES effort.

The issuance and modification of these procedures are controlled in accordance with CPPP-14 (Reference 4.4).

O A16-3

l Revisions to these procedures were followed by detailed training of

[)

V pipe stress and support personnel.

2.7 Calculation Errors As addressed under paragraph 2.3 above, the SWEC QA Program assures the technical adequacy of the engineering product. SWEC-PSAS re-quires all employees to develop technically correct and precise cal-culations. Whenever documentation discrepanices are observed, they are promptly corrected.

2.8 Miscellaneous The various project procedures used in the validation effort along with the corporate engineering and qualltf assurance procedures were sufficient to address any issues related to the validation of pipe i stress and pipe supports at CPSES. This conclusion was also reached  ;

by the third party reviewers (see Section 5.1.1). l 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under t)

provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

N.J

• The corrective action to control discipline interfaces and to provide consistent design criteria between pipe stress analysis and pipe sup-port design was accomplished through the issue and control of CPPP-1, CPPP-6, CPPP-7, and other project procedures during the design vali-dation. Many audits were conducted to assure that SWEC-PSAS person-nel followed the procedures (see Section 5.3).

• The preventive action for this issue is specified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), August 22, 1983 4.2 Comanche Peak Response Team, Design Adequacy Program, Discipline Spe-cific Results Report, Piping and Supports, DAP-RR-P-001, Revision 1, August 27, 1987 4.3 SWEC-PSAS Project Procedure CPPP-1, Revision 7, Management Plan for Project Quality (Piping System Qualification /Requalification),

March 25, 1987 4.4 SWEC-PSAS Proj ect Procedure CPPP-14, Revision 3, Procedure for the Preparation and Control of Project Procedures, September 19, 1986 7_3 k A16-4 l

f., SUBAPPENDIX A17

\sl MASS POINT SPACING 1.0 Definition of the Issue The issue (Reference 4.1) was that the project procedures which estab-lished requirements for minimum mass point spacing were not followed and that the computer program used improperly lumped concentrated masses.

2.0 Issue Resolution Modeling guidelines for locating the mass points in the computerized pipe stress analysis were included in Section 3.10.6.1 and Attachment 3-7 of CPPP-7. To assure adherence to these requirements, mass point spacing was included as a review item in the pipe stress analysis checklist in CPPP-6, Attachment 9-9.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• All the pipe support modifications resulting from resolution of is-sues in Subappendix Al through A35 were determined to be reportable

s under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of mass point spacing was accomplished through the implementation of the criteria provided in CPPP-7, Section 3.10.6.1 and Attachment 3-7 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Pipe Stress Review Issues List, Revisico 4, and Transmittal Letter No. 84056 119, dated September 16, 1987 I

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SUBAPPENDIX A18 i \

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HIGH FREQUENCY MASS PARTICIPATION 1

1.0 Definition of the Issue The issue (References 4.1 and 4.2) was that the 33-Hz cutoff frequency criteria used in the CPSES pipe stress seismic analysis may not be ade-quate. The pipe stress analysis did not comply with the CPSES FSAR re-quirement that the inclusion of high frequency modes beyond the cutoff frequency in the response spectrum analysis do not result in more than a 10-percent increase in the system response.

2.0 Issue Resolution Two analysis options were developed and utilized to address the high-frequency mass participation issue.

II

• Perform seismic amplified response spectrum (ARS) modal analysis with 50-Hz cutoff frequency, including a high-frequency missing mass cor- ,

rection option, by using NUPIPE-SW (V04/L02) or later issue.

• Perform an equivalent static analysis by using the zero-period accel-eration (ZPA) values in all three directions. Combine these results by the square root of the sum of the squares (SRSS) method with the i results of the seismic analysis with a 50-Hz cutof f frequency that O did not include the high-f requency missing mass correction. Addi-V tional studies (Reference 4.3) verified the adequacy of this method-ology for CPSES piping systems whose ZPA is less than 50 Hz.

The high-frequency mass participation criteria was specified in Section j 3.10.6.8 of CPPP-7. l l

3.0 ['orrective and Preventive Action l

• No additional issues were discovered during the review and resolution of the issue.

• All the pipe support modifications resulting from resolution of is-sues in Subappendix Al through A35 were determined to be reportable i under provisions of 10CFR50.55(e) (see Subappendix B2, l SDAR-CP-86-36). l l

• The corrective action to resolve the high frequency mass participa- l tion issue was accomplished through the implementation of the crite-ria provided in CPPP-7, Section 3.10.6.8 and the use of NUPIPE-SW(V04/LO2) during design validation.

• The preventive action for this issue is identified in Appendix C.

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,I. 4.0 References j l dated

\- 4.1 Question 2, CYGNA Communications Reports, J.O.No. 83090 October 5, 1983 4.2 CYGNA Pipe Stress Review Issues List, Revision 4, CYGNA Letter No. 84056.119 dated September 16, 1987 4.3 SWEC-PSAS Letter No. CH-1CPO-1456 dated February 6, 1987, from l A..Chan to L. Nace, Attachment A, Justification for Te rminating Comanche Peak Piping Response Spectrum Analysis at 50 Hz Instead of at the Frequency Corresponding to the Zero Period Acceleration i

is c

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I SUBAPPENDIX A19 (3

() s. FLUID TRANSIENTS 1.0 Definition of the Issue Fluid transients are occasional mechanical loads that should be considered in stress evaluation of ASME Section III Code Class 2 and 3 piping. The previous analysis pr;epared for CPSES considered fluid transients on sever-al piping systems. The issue was that the adequacy of the analysis and the completeness of the identification of these fluid transients was ques-tioned (Reference 4.1).

2.0 Issue Resolution The following process was followed to assure that fluid transients were properly addressed in the SWEC-PSAS validation of the pipe stress analysis.

• Specific fluid transients were identified and summarized in Attach-ment 1 of CPPP-10. These transients were identified by following the guidelines given in NUREG-0582, past experience with other PWRs, and by assessing an overall review of the CPSES system flow diagrams.

Additionally, system engineers reviewed the piping system operating components which could produce significant fluid transients, such as p rapid valve opening or closing actions of control valves, relief

i valve discharge, pump startup or trip, and turbine trip.

V

• The piping systems identified in Attachment 1-1 of CPPP-10 were ana-lyzed for the effects of fluid transients in accordance with the re-quirements of CPPP-7, Section 3.4.5.5 and Attachment 3-1. These analysis methods resolve CPRT and external fluid transient issues. ]

3.0 Corrective and Preventive Action t

\

• No additional issues were discovered during the review and resolution I of the issue. l I

• Pipe support modifications resulting from resolution of issues in I Subappendixes Al through A35 were determined to be reportable under I provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the fluid transient issue was accom-plished through the implementation of the criteria provided in CPPP-7, Attachment 3-1 during the design validation.

• The preventive action for this issue is identified in Appendix C. l l

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4.0 References

,, g 8

(j) 4.1 TES draft Letter No. 6216-7 dated February 21, 1985, from D. F. Landers to V. S. Noonan, Director, Comanche Peak Project, U.S.

Nuclear Regulatory Commission, which transmitted Technical Report No. TR-6216B, Preliminary Consulting Report on Comanche Peak Steam Electric Station - Piping and Support Design

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SUBAPPENDIX A20 SEISMIC EXCITATION OF PIPE SUPPORT MASS 1.0 Definition of the Issue The issue was that the effect of seismic acceleration of the support mass (i.e., self-weight excitation) was not included in the design of the CPSES pipe support structures (References 4.1 and 4.2).

2.0 Issue Resolution SWEC-PSAS resolved these issues by the following methodology:

• Seismic acceleration of pipe support mass was evaluated for all pipe supports with frames on seismic systems.

• The procedure to include the ef fects of pipe support self-weight ex-citation in the pipe support evaluation was incorporated in CPPP-7 as Attachment 4-21.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

m

• Pipe support modifications resulting from resolution of issues in

! Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the seismic excitation of pipe sup- l port mass issue was accomplished through the implementation of the f criteria provided in CPPP-7, Attachment 4-21 during the design i validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), August 22, 1983,Section X 4.2 NRC Inspection Report 50-445/82-26 and 50-446/82-14, Febru- ,

ary 14,1983 (NRC Staff Exhibit 207, pages 34, 35, and 36) {

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SUBAPPENDIX A21 m

(x_ ,/I LOCAL STRESS IN PIPE SUPPORT HEMBERS 1.0 Definition of the Issue The issues (References 4.1 through 4.6) regarding the evaluation of local stress in pipe support members are as follows:

1.1 Local Stress in Tube Steel Members The issue was that local stress in tube steel members, induced by attached support components, such as beam brackets, lugs, or other tube steel members, was not considered in the design.

1.2 Other Support Configurations Requiring Local Stress Evaluations The issue was that several other support types and support details were identified as requiring evaluations for local st'resses:

• Cinched U-bolt supports with struts and snubbers

• Piping anchors

• Zero gap box frames

• Wide flange webs at connections f-~ 1.3 Short Beam Stresses

( /

The issue was that short structural members were incorrectly analyzed in full flexurc. It was noted that more localized stress distribu-tion due to plate behavior would result.

2.0 Issue Resolution Attachment 4-13 of CPPP-7 specified the requirements to evaluate local stresses in pipe support members.

2.1 Local Stress in Tube Steel Members ,

A procedure to evaluate local stress in tube steel members based on the methods of AWS Code D1.1 Section 10.5, including yield line anal-ysis, was developed and incorporated in Attachment 4-13 of CPPP-7.

2.2 Other Support Configurations Requiring Local Stress Evaluations Resolutions for the issue regarding the need for local stress evalua-tions on other support configurations is as listed below:

• Cinched U-bolt supports on struts and snubbers are being elimi-nated or modified as discussed in Subappendix A11.

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• Resolution of the issue regarding the local stress evaluation (g) for piping anchors is addressed in Subappendix A2 v

• Zero gap box frames are being eliminated or modified as dis-cussed in Subappendix A2

• Requirements for the evaluation of local stresses in wide flange member webs at connections, consistent with the AISC Code re-quirements, were developed and incorporated into Attachment 4-13 of CPPP-7 2.3 Short Beam Stresses Attactunent 4-13 of CPPP-7 requires that short beam support raembers be analyzed for local stress effect.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendix Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of local stress in pipe (T support members was accomplished through the implementation of the V criteria provided in CPPP-7, validation.

Attachment 4-13 during the design j i

l

• The preventive action for this issue is identified in Appendix C. l 4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle I Allegations),Section IX, August 22, 1983 I 4.2 CASE's Answer to Applicants' Statement of Material Facts as to Which There is No Geniune Issue Regarding Consideration of Local Displace-ments and Stresses, August 27, 1984.

4.3 CASE's Answer to Applicant's Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses, October 9, 1984.

4.4 NRC Staff Response to Applicant's Motion for Summary Disposition on l AWS and ASME Code Provisions on Weld Design, November 2, 1984 4.5 CASE's Answer to Applicant's Motion for Summary Disposition of Cer-tain CASE Allegations Regarding AWS and ASKE Code Provisions Related to Design Issues, August 6, 1984 Ch A21-2

f -- 4,6 Transcript of Proceedings Before the United States Nuclear Regulatory

( Commission, Washington, DC, in the Matter of Meeting to Conduct Feed-back Discussions with Messrs. Walsh and Doyle Re Concerns About the Comanche Peak Plant Held March 23, 1986 O

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l SUBAPPENDIX A22 V SAFETY FACTORS 1.0 Definition of the Issue The issue (References 4.1 and 4.2) was that the industry practice of ne-glecting to factor small potential loads into design calculations is not supported by adequate CPSES factors of safety. The issue also was that CPSES safety factors had already been eroded by poor and insufficient de-sign practices.

2.0 Issue Resolution CPRT and (.ternal issues have been resolved and incorporated into the technical and design control procedures. Therefore, the inherent design margin (safety factor) accumulated from the built-in conservatism in codes, inputs, and regulatory positions is applicable.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

p) i D

• The corrective action to resolve the issue of safety factors has been implemented in the SWEC-PSAS Corrective Action Program (CAP) through the resolution of all applicable CPRT and external issues which have been incorporated into the technical and design control procedures.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section I, August 22, 1983 4.2 CASE's Partial Answer to TU Electric's Statement of Material Facts as to Which There is No Genuine Issue Regarding Safety Factors, August 27, 1984 {

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SUBAPPENDIX A23 l l

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V SA-36 AND A307 STEEL

[.

1.0 Definition of the Issue The following issues were identified (References 4.1 through 4.3) regarding the use of SA-36 and A307 material in pipe supports at CPSES, 1.1 Design Allowables Derived from Tests The issue was that the material allowables used in the design of cinched U-bolts, U-bolts as two-way restraints, and SA-36 threaded rod used with Richmond inserts for pipe supports at CPSES were derived from tests and not from the ASME Section III Code minimum yield stress, since questions arose as to whether the material tested in the following tests represented the actual material used onsite.

1.1.1 Cinched U-Bolt Tests Conducted by Westinghouse l 1.1.2 U-Bolts as Two-Way Restraints Tests Conducted by ITT Grinnell 1.1.3 Richmond Insert Tests Conducted by TU Electric 1.2 Friction Connections

.I V The issue was that AISC Code 7th Edition Table 1.5.2.1 prohibits the use of A307 as bolting material in friction connections. Attainment and main-tenance of joint preload is the underlying issue. SA-36 and A307 materi-als are similar. ASME Section III Code Inquiry NI86-030 (Reference 4.4)

However, clarifies that cinched U-bolts are not friction connections.

since the U-bolt design relies on friction and preload to provide stabili-ty, the AISC prohibition needs to be addressed.

1.3 Fatigue The issue was that SA-36 material used in cinched U-bolts, U-bolts as two-way restraints , and as rod, threaded into Richmond inserts, are sub-ject to load cycling, which must be considered in the qualification. ASME Section III, Appendix XVII, Table XVII-3230-1, footnote 4; and AISC 7th edition, Appendix B, Table B2, footnote 4, state "Where stress reversal is involved, use of A307 bolts is not recommended." Fatigue of the A307 ma-terial is the issue. Since SA-36 material is similar to A307, this issue was extended to SA-36 U-bolts and threaded rods used with Richmond inserts.

A23-1

1.4 Allowable Stresses in Bolting Material The issue was that the allowable stresses used in the design of bolting material exceed the material yield strength under the faulted condition (Level D) service limit. This does not conform to the guidance of NRC Regulatory Guide 1.124, Reference 4.5, which limits the load increases to 1.5 times the normal operating (Level A) service limit, because of the potential for nonductile behavior.

1.5 Use of Low-Strength Nuts with High-Strength Bolts The issue was that low-strength nuts, A563 Grade A, were used with high-strength bolting, instead of the code compatible A194 Grade B nut. The issue was that the resultant connection capacity should have been reduced in the analysis.

2.0 Issue Resolution 2.1 Design Allowables Derived from Tests In accordance with CPPP-7, Section 4.2.5.1, cinched U-bolts with struts or 1 snubbers are being eliminated or modified.

Design allowables for linear components, such as SA-36 U-bolts and SA-36 threaded rod used with Richmond inserts, were derived by SWEC-PSAS f rom the ASME Section III Code minimum yield strength specified in Section 2.2 of CPPP-7 O and not from tests.

2.2 Friction Connections In accordance with CPPP-7, Section 4.2.5.1, cinched U-bolts with struts or snubbers are being eliminated or modified.

l U-bolts used as two-way restraints do not rely on preload for load transfer.

Richmond insert connections were designed as bearing connections and do not rely on friction (preload) for load transfer capability. {

2.3 Fatigue U-bolts used as two-way restraints and SA-36 threaded rod used with Richmond inserts were subject to reversing stress fields due to seismic and fluid tran-sient loads.

The SA-36 U-bolts used as two-way restraints as well as the threaded rod used with Richmond insert tube steel joints were designed as ASME Section III, lin-car NF support components in accordance with ASME Section III, Appendix XVII, and AISC, respectively. ASME Section III Code Appendix XVII Table XVII-3230-1 j j and AISC Code 7th Edition, Appendix B, Table B2, footnote 4 define the lower bound value for consideration of stress cycles as 20,000. SWEC-PSAS demon-O l O A23-2 i

I strated that the number of equivalent stress cycles for these components was ,

(n) less than 7,000.

Codes.

Therefore, fatigue was not relevant as defined in these j 2.4 Allowable Stresses in Bolting Material Bolting material was designed in accordance with ASME Section III, Para- ,

graph NF-3225 Summer 1983 addenda, which limited the stresses at temperature at j the faulted condition (Level D) to yield. The use of this later code paragraph l assures ductile behavior and thus conforms to the guidance of NRC Regulatory f Guide 1.124. I 2.5 Use of Low-Strength Nuts with High-Strength Bolting l

In accordance with CPPP-7, Attachment 4-5, the tensile allowable load for j high-strength bolts using low-strength nuts was reduced to 60 percent of the j normal high-strength bolt allowable, to account for the reduced proof load i stress of the A563 Grade A nut.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendix Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

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• The corrective action to resolve the SA-36 and A307 steel issue was accomplished through the implementation of the criteria provided in CPPP-7, Sections 2.2 and 4.2.5.1, and Attachment 4-5 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Alle-gations,Section III), August 22, 1983.

4.2 CASE's Fourth Motion for Summary Disposition to Disqualify the Use of A307 and SA-36 Threaded Parts, January 14, 1985.

4.3 CASE's Partial Answer to Applicants' Statement of Material Facts Relating to Richmond Inserts as to Which There are No Material Facts, September 10, 1984 4.4 ASME III Code Inquiry NI86-030 "Section III, Division 1, NF-3324.6 (a)(3)(b) Friction Type Joints, NF-3324.6(a)(4) Slip Resistance, Friction Type Joints, NF-3225.4, Friction Type Joints, 1983 Edition with the Winter 1985 Addenda," June 25, 1986 m

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l 4.5 NRC Regulatory Guide 1.124, Service Limits and Loading Combinations for Class 1 Linear Type Component Supports, Revision 1, January 1978 O

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e SUBAPPENDIX A24 l (w

• U-BOLT TWISTING l

1.0 Definition of the Issue This issue (References 4.1 through 4.3) was that out-of-plane rotation of the crosspiece of a trapeze cinched U-bolt support may result when the struts are  ;

in compression. This rotation would induce twisting on the U-bolt, for which it was not designed. 1 2.0 Issue Resolution i

Due to the extensive engineering effort required to demonstrate the acceptabil- i ity of this type of support, cinched U-bolt trapeze supports with struts or snubbers are being eliminated or modified. Modification options are discussed in Subappendix A12, Axial / Rotational and Trapeze Restraints.

3.0 Corrective and Preventive Action l

• No additional issues were discovered during the review and resolution of the issue.

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• Pipe support modifications resulting from resolution of issues in 4 Subappendixes Al through A35 were determined to be reportable under j provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36). (

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• The corrective action for the twisting of U-bolts on trapeze supports with struts or snubbers is being accomplished through the elimination or modification of this support type in accordance with CPPP-7, Sec-tion 4.2.5.1 during the design validation.

• The preventive action for this issue is identified in Appendix C. )

4.0 References l l

4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle l Allegations),Section III, August 22, 1983 l 4.2 CASE's Motions and Answer to Applicants' Motions for Summary Disposi-tion Regarding Stability of Pipe Supports, October 15, 1984 4.3 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987 O A24-1

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l SUBAPPENDIX A25

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,b FISHER / CROSBY VA'.VE MODELING/ QUALIFICATION 1.0 Definition of the Issue The issues (References 4.1 through 4.4) related to Fisher and Crosby valve modeling and qualification were as follows:

1.1 Crosby Valves The issue was that the main steam (MS) safety relief valves (SRV) which have a double ported outlet configuration used an unconserv-ative assumption of a 55/45 split in the flow distribution in lieu of the 60/40 split flow distribution, as suggested by Crosby Valve.

There are five such valves located along the MS line that discharges into vent stacks.

1.2 Fisher Valves The issue was that the Fisher valve operators may not be qualified to withstand the loads imposed on them by the snubbers that support the valve operator.

The Fisher valve is a control valve that is used to control main steam (MS) flow by relieving steam to the atmosphere.

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( ) 1.3 Flexible Valves The issue was that the modeling of " flexible" valves (frequency less than 33 cycles per second) was inadequate. It was found that valves noted in Reference 4.4 (excluding Fisher valves) were the only " flex-ible" valves within the original scope of work. It was determined q that the valve accelerations for those valves were acceptable; howev-er, the modeling of the Fisher valve yoke, which is laterally sup-ported at the end, was not addressed. If the yoke is modeled much stiffer than it actually is, it may have an effect on the analysis  !

results.

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1.4 Valve Accelerations and Loads l

The issue was that the validity of a sampling process to assure the acceptability of valve accelerations and valve flange loads has not ,

been demonstrated, l 2.0 Issue Resolution 2.1 Crosby Valves i

• SWEC-PSAS discussed the flow distribution of doubled-ported SRV with Crosby (Reference 4.5), and Crosby verified that the SRV has an equal f

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-s (50/50) flow distribution ratio (instead of 60/40, as was thought).

i (d for conservatism, a 55/45 SRV flow distribution ra tio was used to calculate the blowdown force.

• SWEC-PSAS evaluated the multiple SR'/ loading combination issue and concurred that all five valves opening simultaneously must be consid-ered for piping and pipe support design. Since valves may open in a set or random sequence, those cases were also considered. The vali-dation process identified the design basis for multiple SRV openings, including five simultaneous valves opening, for stress analyais eval-uation. The cases evaluated covered all possible circumstances based 4 on the system design, including the worst load condition.

l 2.2 Fisher Valves The SWEC-PSAS validation of the Fisher relief valve branch connection {

piping model included the effects of the snubber supports at the l valve. In accordance with Section 7.4.3 of CPPP-6 both valve accel-erations and support loads on the valves were transmitted to the equipment qualification organization (Impell Corporation) for valida- j tion, except for Westinghouse-supplied valves, which were transmitted i to Westinghouse for validation.

2.3 Flexible Valves The yokes of flexible valves were modeled to properly predict the I fG yoke frequency. CPPP-7, Section 3.10.6.5 specified the proper valve l d yoke modeling of flexible valves. I 2.4 Valve Accelerations and Loads All valves were validated for applicable accelerations and valve noz-zle loadings in accordance with CPPP-7, Section 3.10.5.2. Also, since all valves were validated, the concern regarding sampling has been satisfied.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in Subappendix Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of valve modeling and ,

qualification was accomplished through the implementation of the cri-teria provided in CPPP-6, Section 7.4.3 and CPPP-7, Sections 3.10.5.2 and 3.10.6.5 during the design validation.

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• The preventive action for this issue is identified in Appendix C.

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4.0 References

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'V 4.1 Tel-con dated October 21, 1976, between Crosby Valve and Gibbs &

11111, J. R. Zahorsky and M. H. Giden, regarding Contract No. 2323A, Double-Ported Safety Valves 4.2 Telex from Crosby Valve to Gibbs & Hill regarding Contract No. 2323A, Main Steam Safety Valves, J. R. Zahorsky to Dr. Kim, October 12, 1976 4.3 CYGNA Pipe Stress Review Issues List, Revision 4, and Transmittal Letter No. 84056.119 dated September 16, 1987.

4.4 Communications Report between Krishnan/ Ray (Gibbs & Hill) and Minichiello (CYGNA), June 18, 1984.

4.5 Tel-con dated February 21, 1986, between R. Martin and J. R. Zahorsky I of Crosby Valve and W. Wang, A. J. Cokonis, and W. H. Green of SWEC, regarding Crosby double ported relief valve discharge loads.

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SUBAPPENDIX A26 O

U PIPING MODELING 1.0 Definition of the Issue The issue was that incorrect inputs were used in the pipe stress analysis as follows (Reference 4.1):

• Incorrect pipe wall thickness was used to calculate an allowable noz-zie load (Reference 4.1, Issue 2).

• Improper stress intensification factors were used (Reference 4.1, Issue 10).

• Fluid content and insulation weights were not included for valves and flanges'(Reference 4.1, Issue 4).

• Valve acceleration and flange loads were not always checked in the piping analysis-(Reference 4.1, Issue 21).

• Two piping segments were input into the stress analysis with the in-correct wall thickness (Reference 4.1, Issue 12).

2.0 Issue Resolution ge'% All pipe stress analysis packages were validated in accordance with Pro-ty ject Procedures CPPP-6 and CPPP-7, which provided direction for the proper modeling of piping systems. SWEC Engineering Assurance Procedure EAP 5.3 provided guidance on the preparation and review of calculations, including the need to assure that proper input is used. Checklists were included in proj ect procedures to provide additional assurance that correct piping models were created and that proper review of the input and output was performed.

In addition, personnel were trained in the implementation of the proce-dures. This training was further enhanced by daily contact with the expe-rienced on-project technical supervision. The SWEC Engineering Assurance Division performed audits of project activities to verify that procedural requirements were met and that calculations were technically acceptable.

The combination of the procedures, the procedural control, and the audit program provided assurance that the inputs were correct and the calcula-tions were complete and technically acceptable.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

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• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under (V) provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issues related to piping model-ing was accomplished through the implementation of the criteria pro-vided in Section 3.0 of CPPP-7 during the -design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Pipe Stress Review Issues List, Revision 4, and Transmittal Letter No. 84056.119 dated September 16, 1987. q i"\

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SUBAPPENDIX A27 l (D

() WELDING 1.0 Definition of the Issue The following welding-related issues were identified (Reference 4.1):

1.1 Undersized Fillet Welds The issue was that the sizes of two fillet welds were found to be less than the minimum requirements of Table XVII-2452.1-1 in Appen-dix XVII of the ASME Code Section III.

1.2 Penetration Weld Subsurface Cracking The issue was that there is a potential for subsurface cracking on welds with deep penetrations. The. shrinkage due to weld cooling may be resisted where the joined surfaces approach being parallel. Under these conditions, subsurface cracking can occur without the crack propagating to the surface. Upon loading, this<nubsurface crack may propagate through the weld causing joint failure.

1.3 Eccentricity of Three-Sided Welds (Unsymmetrical Welds) l f-m' The issue was that analyses of three-sided welds have not consistent-ly considered the eccentricity between the center of gravity of the (O member and the weld.

1.4 Linear Versus Plate and Shell Weld Design for Base Plates The issue was that the practice of qualifytag base plate welds using j linear analyses (as opposed to plate and shell analyses) was  !

questioned.

1.5 Combination Welded / Bolted Connections ,

I The issue was that no evidence was found to support the fact that )

combination welded / bolted connections are designed in accordance with i Appendix XVII, subparagraph XVII-2442,Section III of the ASME Code.

1.6 Crosspiece Cover Plate Welds The issue was that it was observed that shear flow has not always l been considered in the analysis of welds attaching cover plates to crosspiece members.

1.7 One-Third Increase of Weld Allowable Stress for Emergency and Faulted Conditions A27-1

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The issue was that the practice of increasing weld allowable stresses J

(3 v) by one-third for emergency and faulted conditions was questioned.

l 1.8 Welding Practices ,

The issue was whether welding procedures qualified by test in accor-dance with the ASME Code are adequate in light of AWS requirements for prequalified welds. This issue involves the following inadequate welding practices: cap welding, weave welding, lap joint require-ments, downhill welding, and preheat requirements.

2.0 Issue Resolution 2.1 Undersized Fillet Welds ASME Code Case N-413 eliminated the minimum weld size requirements of Table XVII-2452.1-1 in the ASME Section III Code. Attachment 4-2 of CPPP-7 incorporates ASME Code Case N-413.

2.2 Penetration Weld Subsurface Cracking As part of the resolution of this issue, SWEC-PSAS reviewed Refer-ence 4.3, which states that the tendency to develop subsurface weld cracks stems from the "... misuse of a welding process that can achieve deep penetration or poor joint design. A few preventive mea-sures can ensure elimination of both of these factors. Limiting the

/^\ penetration and the volume of weld metal deposited per pass, through

\d speed and amperage control, and using reasonable depth of fusion are both steps in the right direction."

All CPSES pipe support welds are fabricated in accordance with CPSES Weld Procedure WPS-11032.

SWEC-PSAS reviewed WPS-11032 and concluded that it is a qualified procedure in accordance with ASME Section IX which adequately con-trols the joint design, travel speed, electrode size, and amperage and that the SMAW process is not a deep penetration process.

Therefore, all pipe support welds fabricated in accordance with CPSES Weld Procedure WPS-11032 are in compliance with the ASME Code.

2.3 Eccentricity of Three-Sided Welds (Unsymmetrical Welds)

In accordance with CPPP-7, Attachment 4-2, paragraph 3, the eccen-tricity between the center of gravity of the member and the weld has been considered.

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A27-2

l p 2.4 Linear Versus Plate and Shell Weld Design for Base Plates v I O ASME Section III, Subsection NF-1230 allows the use of either plate-and-shell or linear-type support analysis for the design of welds connecting linear and plate and shell elements. In accordance with CPPF-7, Attachment 4-2, these welds were validated using the linear-type support analysis.

2.5 Combination Weided/ Bolted Conr.ections Welds used in combination welded / bolted connections vdrei designed in accordance with CPPP-7, Attachment 4-2, paragraph 3.ii3 for the en-tire shear force, which complien with ASME Section III, paragraph XVII-2442.

2.6 Crosspiece Cover Plate Welds In accordanct with CPPP-7, Attachment 4-2, paragraph 3.1.5, members I which use cover plates for strength purposes had the plate-to-member attachment weld validated for shear flow.

2.7 One Third Increase in Allowable Weld Stress for Emergency and Fault 3d Conditions 2.7.1 A one-third incre se in allowable weld stress for emergency and faulted ccn'itions is acceptable. ASME Code, Sec-(] tion 711 Subser .on NF, paragraph NF 3231.1(b), Design of V Linear-Type Su forts by Analysis for Class 1 Component Sup-ports, and Appendix XVII-2110(.s), Linear Elastic Analysis, specify an allowable stress increase for emergency and faulted conditions. The emergency condition is stated as having a one-third allovable increase. Both para-graph NF 3231.1(b) and Appendix XVII-21100 refer to ASME Section III, Subsection NF for the faulted condition, where the factor is always greater than one-third.

2.7.2 AISC has allowed the one-third increase since the 7th edition.

2.7.3 Correspondence from K. Ennis, Assistant Secretary of ASME, to W. M. Eifert of SWEC, dated September 25, 1985, confirms this position (

Reference:

4.2).

2.8 Welding Practices SWEC-PSAS reviewed WPS-11032 and concluded that it is a qualified procedure in accordance with ASME Section IX, and thus, the limita-tions of AWS for prequalified weld configurations do not apply.

Therefore, all pipe support welds fabricated in accordance with weld procedure WPS-11032 are in compliance with the ASME Code.

,O A27-3

l -~3 Furthermore, the Atomic Safety and Licensing Board (ASLB), using an

. NRC staff comparison of ASME versus AWS and their own review of ex-s

'J isting welding procedures, concluded (on June 29, 1984, Refer- ,

ence 4.4) that compliance with the ASME code has been adequate to assure the acceptability of the CPSES welding procedures.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• All the pipe support modifications resulting from resolution of is-sues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve pipe support welding concerns was I accomplished through the implementation of the criteria provided in Attachment 4-2 of CPPP-7 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Pipe Support Review Issues List Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987.

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(_,) 4.2 Letter from K. Ennis, Assistant Secretary of ASME, to W. M. Eifert of SWEC dated September 25, 1985.

4.3 Design of Welded Structures, Omer W. Blodgett, 1966.

4.4 ASLB Memorandum and Order LBP-84-25 (Written - Filing Decisions, No. 1: Some AWS/ASME Issues), June 29, 1984.

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SUBAPPENDIX A28 7-_

-- ANCHOR BOLTS /EMBEDMENT PLATES 1.0 Definition of the Issue Issues were raised (Reference 4.1) involving embedment plate, anchor bolt, and base plate designs at CPSES. They are as follows:

1.1 Embedment Plates and Through-Bolts The issue was that there was no evidence that the spacing between attachments to embedment plates was checked at CPSES and that for existing designs, moment connections to the embedments require stiff-eners, but no procedure for the design of a stiffener was provided.

Also, there was no written evidence documenting that as-built loads from pipe supports that use through-bolts were transmitted to the Civil / Structural Group for acceptance.

In addition, several instances were observed of Hilti Kwik-bolts in-stalled close to through-bolt base plates that were not shown on the support drawing.

1.2 Base Plate Edge Distance A

) The issue was that anchor bolt edge distance tolerances could result in a 15-percent increase in base plate stresses for base plate de-signs with struts, springs, or snubbers with a 5-degree offset.

1.3 Hilti Kwik-Bolt Embedment Length The issue was that there was a discrepancy identified between the bolt embedment lengths on support drawings and the lengths used in calculations.

1.4 Concrete Edge Distance Violation The issue was that instances were observed where pipe sleeve penetra-tions exist close to support base plates but were not shown on sup-port drawings.

2.0 Issue Resolution These issues were addressed as described below:

The SWEC Civil / Structural Corrective Action Program (SWEC-C/S-CAP) devel-oped uniform design criteria for all concrete anchorages (References 4.2 and 4.3), including the evaluation of spacing between different discipline commodities. The design criteria were incorporated into CPPP-7,

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( i Attachments 4-4, 4-5, and 4-25 via SWEC-PSAS Project Memorandum PM-210.

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l Pipe support anchorage validation was performed in accordance with these attachments. Specific resolutions of these issues are as follows:

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2.1 Embedment Plates and Through-Bolts  !

SWEC Civil / Structural is responsible for structural attachment load evaluations. CPPP-6 controlled the transmittal af pipe support at- d tachment loads on embedded plates, through-bolts, and base plates to SWEC Civil / Structural discipline. SWEC Civil /Stractural will identi-fy base plates installed close to through-bolts to SWEC-PSAS for val-idation. SWEC Civil / Structural design validation of embedded plates and structures is described in the Civil / Structural PSR (Reference 4.3).

2.2 Base Plate Edge Distance An analysis was performed by SWEC-PSAS to determine the ef fects of edge distance tolerances on the bolt loads and plate stresses, and it was concluded that the edge distance tolerance was acceptable. {

Furthermore, the PCHVP will validate the as-built base plate bolt hole edge distances.

2.3 Hilti Kwik-Bolt Embedment Length p Embedment lengths shown on the drawings were used in calculations to

( validate pipe support anchorage designs in accordance with Attach-ment 4-4 of CPPP-7.

2.4 Concrete Edge Distance Violation During PCHVP, SWEC Civil / Structural will identify base plates which are installed close to pipe sleeve penetrations and transmit this information to SWEC-PSAS for validation. Base plate validation is performed in accordance with CPPP-7.

3.0 Corrective and Preventive Action I i

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• No additional issues were discovered during the review and resolution i of the issue. )

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under q provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36). q

• The corrective action to resolve the anchorage issues has been accom-plished by the incorporation of the DBD (Reference 4.2) into CPPP-7 l for the validation of embedments in concrete and the PCHVP for the identification of anchorage spacing violations.

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• The preventive action for this issue is identified in Appendix C b] 4.0 References l 4.1 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal q Letter No. 84056.120, dated September 18, 1987.

4.2 TU Electric, CPSES Units 1 and 2, Design Basis Document DBD-CS-015, Revision 4, June 10, 1987 4.3 TU Electric, CPSES Unit 1 and Common, Civil / Structural Project Status Report, Revision 0, October 1987 1

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l SUBAPPENDIX A29

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' I STRUT / SNUBBER ANGULARITY 1.0 Definition of the Issue 1.1 The issue (Reference 4.1) was that the loading component (" kick" load) resulting from the angular swing of the strut / snubber from its {

nominal position, due to construction tolerances and pipe movements, j was not assessed in designs. j i

1.2 The NRC Inspection and Enforcement Bulletin IEB-79-14 program re-quires all as-built angular tolerances over i 2 deg to be measured and assessed (Reference 4.2). The issue was that the construction angular tolerance for the installed CPSES struts / snubbers was 1 5 degrees.

2.0 Issue Resolution 2.1 The angular swing of struts / snubbers due to construction tolerances and pipe movements from applicable the rmal, seismic, and/or fluid transients were assessed. The effect of the swing angle load compo-nent (maximum swing angle of 5 deg) was censidered in the support design. If the i 5-deg tolerance was exceeded, the proper function and load rating of strut / snubber assemblies were ensured in addition to the component load consideration. These requirements were includ-(,,

f)T ed in Sections 4.2 and 4.2.6 of CPPP-7.

2.2 All installed struts / snubbers were measured and those that exceeded i 2-deg tolerance were assessed in the validation program. j 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue. ,

• Pipe support modifications resulting from resolution of issues in Sub3ppendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the issue of strut / snubber angulari-ty was accomplished through the implementation of the criteria pro-vided in Sections 4.2 and 4.2.6 of CPPP-7 during the design validation and is physically validated in the Post Construction Hard-ware Validation Program (PCHVP) through the implementation of Field Verification Method CPE-SWEC-FVM-PS-081 (Reference 4.3).

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• The preventive action for this issue is identified in Appendix C. l l PN 4 I

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4.0 References 4.1 Transcript of Proceedings of Feedback Discussion Between USNRC and Walsh and Doyle on the Concerns About the CPSES, March 23, 1985 4.2 NUREG-0797, Supplementary No. 11, Safety Evaluation Report Related to the Operation of CPSES Units 1 and 2, USNRC, Docket Nos. 50-445 and 50-446, May 1985 4.3 SWEC-PSAS Comanche Peak Field Verification Method, Hardware Vali-dation and Supplemental Inspection Programs CPE-SWEC-FVM-PS-081, Revision 0, July 29, 1987 9

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SUBAPPENDIX A30 COMPONENT QUALIFICATION 1.0 Definition of the Issue i Issues related to the qualification of member components in CPSES pipe supports were identified as follows (Reference 4.1):

1.1 Dynamic' Pipe Movements in Support Design i

The issue was that all dynamic piping movements were not included in' t the support design when checking frame gaps, swing angles, or spring travel. Existing designs addressed only the seismic effects. This is applicable to frame gaps in the unrestrained direction, strut /

snubber swing angles, and both spring and snubber travel. .

1.2 Incorrect Standard Component Allowables ,

The issue was that incorrect U-bolt allowables were used in the de--

sign of support RH-1-064-011-S22R.

1.3 Untightened Locknut On Struts The issue was that the upper locknut on one strut was not tightened, 'I which could lead to rotation of the strut and a subsequent load k redistribution.

1.4 Inverted Snubbers The issue'was that four supports were identified in which the snub-bers were installed 180 degrees from the configuration shown on the support drawings.

2.0 Issue Resolution  !

2.1 Dynamic Pipe Movements in Support Design Predicted pipe movements for all design conditions for pipe supports were evaluated in the design validation in accordance with CPPP-7, Section 4.2.

2.2 Incorrect Standard Component Allowables RH-1-064-011-S22R was a cinched U-bolt support with a strut. This support is being modified in accordance with CPPP-7, Section 4.2.5.1.

Component standard-type pipe supports were validated in accordance with CPPP-7, Section 4.1, by comparison to vendor-supplied load ca-pacity data sheets (LCD) or certified design report summaries (CDRS).

A30-1

n 2.3 Untightened Locknuts on Struts i 1

\Y The Post-Construction Hardware Validation Program (PCHVP) is being performed to validate the proper hardware installation including locknuts through inspections performed in accordance with Field Veri-fication Method CPE-SWEC-FVM-PS-081 (Reference 4.2).

2.4 Inverted Snubbers q The Post-Construction Hardware Validation Program (PCHVP) is being performed to validate the proper hardware installation including snubbers through inspections performed in accordance with Field Veri-fication Method CPE-SWEC-FVM-PS-081.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of the issue.

• Pipe support modifications resulting from resolution of issues in )

Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

i

• The corrective action to resolve the locknut and snubber installation issues is being accomplished through the implementation of pipe sup-port hardware inspections and rework. The corrective action to re-p solve the component allowable and dynamic pipe movement issue was (si accomplished through the implementation of the criteria provided in Sections 4.1 and 4.2 of CPPP-7 during the design validation. The corrective action to resolve the design of Support RH-1-064-011-S22R was accomplished through the implementation of the criteria provided in CPPP-7, Section 4.2.5.1.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987 4.2 SWEC-PSAS Comanche Peak Field Verification Method, Hardware Vali-dation and Supplemental Inspection Program CPE-SWEC-FVM-PS-081, q Revision 0, July 29, 1987 3 1

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SUBAPPENDIX-A31

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V STRUCTURAL MODELING FOR FRAME ANALYSIS l

11.0 Definition of the Issue Issues were raised (Reference 4.1) relating to the structural modeling for frame supports:  ;

1 1.1 Torsion Evaluation The issue was that for wide flange members, the torsional deflections were underestimated and members were not checked for local stresses at points of torsional loading.  !

l '. 2 Boundary Conditions for Richmond Insert / Tube' Steel Connections The issue was that modeling of member end restraints at Richmond insert / tube steel connections was inconsistent. Three different mem-ber end' conditions varying from fully fixed to fully free were as-sumed. Each assumption may be conservative for one member and uncon-servative for another.

.1. 3 -Support Boundary Conditions  !

The issue was that supports were identified in which the assumed 3

boundary conditions were questionable.

)

2.0 Issue Resolution 2.1- Torsion Evaluation In accordance with Section 4.3.2.1 of CPPP-7 member properties used l in the pipe support validation, including values for torsional resis- j tance, were taken from AISC Manual of Steel Construction, 8th Edi- l tion. Tables 4.7.2-3 through 4.7.2-7 of CPPP-7 provided equations i for evaluating member stresses, including local effects due to tor- l sional loading.

I 2.2 Boundary Conditions for Richmond Insert Tube Steel Connections i Consistent modeling techniques were used for Richmond insert tube  ;

steel connection validation as specified in CPPP-7, Attachment 4-5 to I assure that member end restraints were properly modeled. 1 I

2.3 Support Boundary Conditions Attachment of the pipe support to the building structure was reflect- )

ed in the frame analysis by the proper modeling of the connection stiffness in accordance with CPPP-7, Attachment 4-18.

\ A31-1

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3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al .through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

(

• :The-corrective action to resolve this issue was accomplished through the implementation of the criteria provided in CPPP-7, Sec- L tion 4.3.2.1, Tables 4.7.2-3 and 4.7.2-7, and Attachments 4-5 and 4-18 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References

' 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), Sections VII and XII, August 22, 1983.

1 A31-2 l

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.- SUBAPPENDIX A32 COMPUTER PROGRAM VERIFICATION AND USE 1.0 Definition of the Issue l l

The issue - (References 4.1 and 4.2) was whether there was adequate ' quality ]

assurance for the verification and use of appropriate versions of the fol- j lowing computer programs: l J

• ADLPIPE Version 2C (dated April 1977) - Piping Analysis  !

• 'FUB-II - Base Plate Qualification - ITT Grinnell

' ' Corner and Lada Base Plate Qualification Program q a

2.0 Issue Resolution The computer programs for which sp cific issues were raised were not used in the pipe stress and pipe support validation effort.

The computer programs that were used for piping and pipe support valida-tion were identified in CPPP-7, Section 5.0.

The computer programs used in the validation effort were verified in ac-cordance with ' SWEC QA program . requirements for verification, technical adequacy,'and. appropriate version. The computer program verification was documented, and identified the various project applications.

3.0 Corrective ~and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under the provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36) .

• The corrective action to resolve the concern regarding computer pro-gram verification was accomplished through the implementation of the ,

SWEC Quality Assurance Program.  !

I

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Design Control Review Issues List, Revision 1, June 21, 1985 l

4.2 NRC Inspection Report No. 50-445/83-12:50-446/83-07 Inspection Con- l ducted by J., I. Tapia and W. Paul Chen, May 13, 1983 I'

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y p SUBAPPENDIX A33 HYDROTEST 1.0 Definition of the Issue The issues (References 4.1 and 4.2) was that hydrostatic test loading con-ditions were not properly considered for ASME Section III Code Class 2 and j 3 piping analysis and pipe support designs. '

2.0 Issue Resolution l The hydrotest loads for piping and supports were evaluated for 1.5 times tl'e design pressure, in accordance with the ASME Section III Code of Record, except- for the ASME Section III Class 2 and 3 piping, which was evaluated for 1.25 times the design pressure consistent with the actual hydrostatic test conditions. The lower design pressure for Classes 2 and 3 piping is in accordance with a later code version which is accept- l able, since the project - met the requirements of ASME Section III Code paragraph NA-1140, which allows the use of later Code provisions where appropriate. Evaluation of piping and supports for hydrotest loading was performed as specified in CPPP-7, Sections 3.6.2.4 and 4.7.2.

3.0 Corrective and Preventive Action

'[

'No additional issues were discovered durin8 the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve the hydrotest issue was accomplished through the implementation of the criteria provided in CPPP-7, Sec-tions 3.6.2.4 and 4.7.2, during the design validation.

• The preventive action .for this issue is identified in Appendix C.

4.0 References 4.1 CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section XIII, August 22, 1983 4.2 CYGNA Pipe Support Review Issues List, Revision 4, and Transmittal Letter No. 84056.120 dated September 18, 1987 f

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SUBAPPENDIX.A34

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i SEISMIC /NONSEISMIC INTERFACE 1.0 Definition of the Issue j The following issues (Reference 4.1) were raised relating to the design of isolation anchors:

I 1.1 Seismic Category I Piping Attached to Nonseismic Piping  !

l The issue was that the seismic effects of nonseismic piping attached 1 to safety-related piping were not adequately considered.

)i 1.2 Piping Routed Between Seismic Category I and Nonseismic Buildings 'l 1.2.1 The issue was that safety-related piping was not seismi-cally isolated when it was routed between seismic Cate-gory I and nonseismic buildings.

1.2.2 The issue was that postulated failure of the turbine build-ing due to an earthquake, which is a nonseismic building,  ;

was not considered in the design of safety-related piping '

which is routed between the turbine building and seismic j Category I buildings.

p j!

2.0 Issue Resolution 1

2.1 Seismic Category I Piping Attached to Nonseismic Piping '

In accordance with CPPP-7, Attachment 4-10, Sections 1.4, 1.5, and 1.6 the following two methods were used for the design validation of safety-related piping attached to nonseismic piping:

2.1.1 A plastic hinge was assumed to occur on the nonseismic pip- j ing immediately adjoining the anchor. The anchor was ana- j lyzed for plastic moments.

2.1.2 One or more restraints and the piping supported by these restraints on the nonseismic side were seismically ana- I lyzed. In addition, the effect of the remaining portion of nonseismic piping was accounted for by the assumption of a '

plastic hinge.

2.2 Piping Routed Between Seismic Category I and Nonseismic Buildings SWEC-PSAS Project Memorandum No. PM-203 clarified the requirements of CPPP-7, Attachment 4-10, and limits the use of Option 2.1.2 to piping i in seismically analyzed buildings. Therefore, the interface between I seismic Category I piping and nonseismic piping occurring at the O A34-1 l

j l

boundary between seismic Category I and nonseismic buildings (e.g.,

p) t the main steam line) was modeled by a plastic hinge as discussed in Item 2.1.2.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under the provisions of 10CFR50.55(e) (See Subappendix B2, SDAR-CP-86-36) .

• The corrective action to resolve the seismic /nonseismic interface issue was accomplished through the implementation of criteria provid-ed in CPPP-7, Attachment 4-10 during the design validation.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CYGNA Pipe Support Review Issues List, Revision 4 and Transmittal Letter No. 84056.120, dated September 18, 1987.

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SUBAPPENDIX A35 V OTHER ISSUES 1.0 Definition of the Issue Subappendixes Al through A34 have addressed the CPRT and external issues (excluding the SSER and CPRT-QOC issues addressed in Subappendixes A36 through A39). These 34 subappendixes represent the consolidation of all but 51 of the 972 piping-related Discrepancy Issue Reports (DIRs), gener-ated by TENERA, L. P. to track closure of issues as part of their third party review. The remaining 51 DIRs (Reference 4.1, Attachment B) are unrelated to the 34 primary issue topics discussed in the previous 34 sub-appendixes. The issues raised by these 51 DIRs must be resolved by the SWEC-PSAS validation effort.

2.0 Issue Resolution SWEC-PSAS resolved the issue identified in each of the 51 DIRs described above by referencing the applicable design or administrative procedure that resolved each issue. These 51 DIRs are considered closed by SWEC-PSAS and TENERA, L. P. I 3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution e of this issue.

• Pipe support modifications resulting from resolution of issues in Subappendixes Al through A35 were determined to be reportable under  ;

provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36).

• The corrective action to resolve this issue was accomplished through the implementation of the criteria provided in CPPP-6 and CPPP-7.

• The preventive action for this issue is identified in Appendix C.

4.0 References 4.1 CPRT Design Adequacy Program Descipline Specific Results Report:

Piping and Supports, DAP-RR-P-001, Revision 1, August 27, 1987 I

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s f- s SUBAPPENDIX A36 t > \

SSER-8 REVIEW 1.0 Definition of the Issue SSER-8 describes the NRC Staff evaluation and resolution of technical is- g sues relating to the civil, structural, and miscellaneous issues of CPSES  !

(Reference 4.1). l The issue was whether the concrete design strength of CPSES safety-related concrete installed between January 1976 and February 1977 was 4,000 psi or greater.

2.0 Issue Resolution The results of the concrete strength tests, performed between January 1976 and February 1977, were reviewed by the SWEC Civil / Structural Group (Reference 4.2). As a result of the consistency between the cylinder data and the Schmidt-Hammer data, SWEC Civil / Structural concluded that there is no evidence of systematic falsification of cylinder data or improper test-ing; therefore, it was further concluded that the 4000 psi design strength of the safety-related concrete placed during that period was substantiated (Reference 4.3).

/N 3.0 Corrective and Preventive Action t

v

)

• No additional issues were discovered during the review and resolution of this issue.

• This issue has been determined to be not reportable in accordance with 10CFR50.55(e).

1

• No corrective action on the design basis is required due to this {

issue, j

• Current construction and QC concrete testing procedures are adequate.

No additional preventive action is required due to this issue. )

l 4.0 References 4.1 NUREG-0797, Supplement No. 8, Sections 3.1.3 and 4.1.2, Safety Evalu-ation Reported Related to the Operation of CPSES Units 1 and 2, Dock-et Nos. 50-445 and 50-446, USNRC, February 1985 4.2 TU Electric CPSES Unit 1 and Common, Civil / Structural, Project Status l Report, Revision 0 1

4.3 CPRT Action Plan II.h Results Report, Concrete Compression Strength, Revision 1, February 28, 1986

(%1 k- ' A36-1 L_________.

SUBAPPENDIX A37 t i D' SSER-10 REVIEW 1.0 Definition of the Issue SSER-10 describes the NRC Staf f evaluation and resolution of technical issues relating to the mechanical and piping group (Reference 4.1). The four piping design related issues are:

1.1 Uncontrolled Weld Repairs by Plug Welding The SSER indicated that a plan is required for sampling inspection of plug welds in CPSES for cable tray supports, pipe supports, and base plates. A bounding analysis is required to assess the ranging ef-fects of uncontrolled plug welds on pipe supports, cable tray sup-ports, and base plates to serve their intended functions. A report documenting the results of the assessment is required.

1.2 Installation of Main Steam Line Pipes - Unit 1, Loop 1 The SSER indicated that Tasks 4.5.1 through 4.5.8 in SSER-10, which include stress assessment and nondestructive examination of Loop 1 main steam (MS) and feedwater (FW) lines, must be performed. Results of analysis, examinations, and reviews are required to be documented n in a report.

1.3 Isolation of Seismic Category I Piping from Nonseismic Piping l

The SSER indicated that an analysis shall be performed and documen-tation shall show that piping systems such as MS, FW, and auxiliary steam lines routed from seismic Category I to nonseismic Category I  ;

buildings are in conformance with the licensing commitments. ]

1.4 As-Built Verification of Type 2 Skewed Welds on NF Supports The SSER indicated that confirmation is required that the Type 2 skewed welds on pipe supports are not undersized. This may be accom-  !

plished through the verification of previous weld inspections or through reinspection.

2.0 Issue Resolution '

2.1 Uncontrolled Weld Repairs by Plug Welding SWEC-PSAS reviewed the Comanche Peak Response Team (CPRT) Action Plan  ;

V.d Results Report (Reference 4.2) and concluded that since the unau-thorized repair of plug welde does not compr mise the structural in-tegrity of the components, there is no impact of plug weld repairs on l the validation of pipe supports at CPSES.

l l 1 V A37-1

f- s 2.2 Installation of Main Steam Lirs Pipes - Unit 1, Loop 1 The CPRT Action Plan V.e Results Report (Reference 4.3) was reviewed by SWEC-PSAS and, based on the main steam and feedwater pipe stress analysis, which incorporated brunding parameters, it was concluded that no deleterious effects resulted from the sequence of events as-sociated with Unit 1, Loop 1, main steam and feedwater (FW) lines hydrostatic tests.

2.3 Isolation of Seismic Category I Piping from Nonseismic Piping This topic is addressed in Subappendix A34.

2.4 As-Built Verification of Type 2 Skewed Welds on NF Supports Pipe support welds at CPSES are inspected in accordance with Inspec-tion Procedure QI-QAP-11.1-28 (Reference 4.4). However, since Type 2 skewed welds are typically found on the weld of the trunnion to the pipe, inspection procedures for Type 2 skewed welds were included in the piping weld inspection Procedure QI-QAP-11.1-26 (Reference 4.5).

CPRT Action Plan V.a Results Report (Reference 4.6) confirmed that inspections were performed in accordance with QI-QAP-11.1-26, and that skewed welds are not undersized. Pipe support weld inspection Procedure QI-QAP-11.1-28 has since been revised to include inspection procedures for Type 2 skewed welds.

/}

C/

3.0 Corrective and Preventive Action

• No additional issue was discovered during the review and resolu-tion of this issue.

• Pipe support modifications resulting from resolution of isola-tion of Seismic Category I piping from nonseismic piping has been determined reportable under the provisions of 10CFR50.55(e)

(see Subappendix B2, SDAR-CP-86-36). No modifications were re-quired as a result of the resolution of the issues discussed in Sections 1.1, 1.2, and 1.4.

• The corrective action to resolve the issue of the isolation of Seismic Category I piping from nonseismic piping has been accom-plished through the implementation of criteria provided in CPPP-7, Attachment 4-10, during the design validation.

The corrective action to resolve the issue of the installation of main steam line piping was accomplished through implementa-tion of CPSES Construction Procedure CP-CPM-1.2 (Reference 4.7) and SWEC-PSAS Procedure CPSP-30 (Reference 4.8), which requires engineering to evaluate the installed piping and pipe support j configuration including the proper design of temporary supports i prior to a piping system hydrostatic test to assure the integri-f ty of the installed safety-related piping and pipe supports.

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,. The corrective action for the issue of uncontrolled plug weld

.[ '

repair was accomplished through enhanced pipe support installa-tion and inspection. criteria.

The corrective action for the issue of verification of Type 2 skewed welds on NF supports was accomplished through the revi--

sion of Weld Inspection Procedure QI-QAP-11.1-28 to include in- l spection procedures for Type 2 skewed welds. l

• The preventive action for this-issue is specified in Appendix C.

I 4.0 References J I

4.1 NUREG-0797, Supplement No.10, Safety Evaluation Report related to the operation of CPSES Units 1 and 2, USNRC, Docket Nos. 50-445 and 50-446, April 1985 4.2 CPRT Action Plan V.d Results Report, Plug Welds, Revision 1, Decem-

'ber 18, 1986

.4.3 CPRT Action Plan- V.e Results Report, Installation of Main Steam Pipes, Revision 1, October 15, 1986 4.4 CPSES Quality Assurance Procedure QI-QAP-11.1-28,. Fabrication . and Installation Inspection of Safety Class Component Supports

(

4.5 CPSES - Quality Assurance. Procedure QI-QAP-11.1-26, Piping and Equip-ment Installation Inspection 4.6 CPRT -Action Plan V.a Results Report, Inspection for Certain Types of Skewed Welds in NF Supports, Revision 1, October 22, 1986 4.7 CPSES Construction Procedure CP-CPM-1.2, Construction Activities. for Systems and/or Areas Accepted and/or. Controlled by TU Electric Plant Operations, Revision 5, March 4, 1987 4.8 SWEC-PSAS Project Procedure CPSP-30, Processing TU Electric Requests for Temporary Hangers, Revision 0, October 7, 1987 A37-3 L - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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1 SUBAPPENDIX A38

.O SSER-11 REVIEW l

1.0' Definition of the Issue SSER-11 (Reference 4.1) describes the NRC Staff TRT position on the evalu- 3 ation and resolution of technical questions and allegations relating to l the QA/QC Group. i i

The issues identified by SSER-11 in the design process that are related to piping design are as follows:

1.1 As-Built Inspection Program (Allegations AQ-50, AQ-21, AQ-22, and AQ-119, Reference 4.1)

. As-built issues were classified into hardware, procedural, as-built, and ' weld-related categories.

~

Specifically, six pipe support con-struction issues in Unit I were listed as follows:

1.1.1 Excessive snubber spherical bearing clearance. ,

1.1.2 Missing strut and snubber load pin locking device.

1.1.3 Pipe clamp halves not parallel.

(O ,) 1.1. 4 - Snubber adapter plate bolts not fully engaged.

1.1.5 Hilti-Kwik bolts installed with' less than- minimum embedment.

1.1.6 Absence of locking devices for threaded fasteners on NF supports.

1.2 Isolation Anchors The issue was that isolation anchore were not always used in the de-sign of seismic-to-nonseismic piping. The isolation anchor must be designed to withstand the combined loading imposed by both seismic Category I and nonseismic piping (Allegation SRT-13, Reference 4.2).

1.3 Main Steam Loop Hydro The issue was that .the design of the main steam lines in Unit I did not take into account the stresses caused by repositioning of the line after flushing and by the settling of temporary supports (Reference 4.1).

l (T A38-1

g 1.4 Girth Welds

! ).

L' The iesue was that radial shrinkage of girth welds in thin-walled stainless steel pipe was not always adequately analyzed (Allegations AQ-50, Ref. 4.1; and AW-52, AW-59, AW-62, Ref. 4.2).

2.0 Issue Resolution 2.1 As-Built Inspection Program The issue of the as-built QC verification of supports at CPSES was also identified in Subappendixes A39 and B3. The resolution of this issue and the corrective and preventive actions associated with this issue are addressed in Subappendixes A39 and B3.

2.2 Isolation Anchors The isolation anchor issue was also identified in SSER-10 (Refer-ence 4.2) and is discussed in Subappendixes A34 and A37. The resolu-tion of this issue and the corrective and preventive actions associated with this issue are addressed in Subappendixes A34 and A37.

2.3 Main Steam Loop Hydro The Unit 1 main steam loop hydro issues were also identified in SSER-10 and are discussed in Subappendix A37. The resolution of this O)

( issue and the corrective and preventive actions associated with this issue are addressed in Subappendix A37.

2.4 Girth Welds The effects of radial shrinkage of girth welds on the pipe stress analysis were analyzed in accordance with CPPP-7, Attachment 3-15.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• Pipe support modifications resulting from resolution of the issue of ,

isolation anchors and girth weld shrinkage have been determined re-  !

portable under the provisions of 10CFR50.55(e) (see Subappendix B2, SDAR-CP-86-36). Pipe support modifications resulting from resolution of the issue of as-built verification of pipe supports have been de-termined reportable under the provisions of 10CFR50.55(e) (see j Subappendix B3, SDAR-CP-86-63). q l

• The corrective action to resolve the girth weld issue was accom-plished through the implementation of the criteria specified in Attachment 3-15 of CPPP-7 during the design validation. i A38-2 l

• The corrective actions to resolve the issues of the as-built inspec-5 tion program, the isolation anchors, and the main steam loop hydro-static test are discussed in Subappendixes A39, A34, -and A37, respectively.

• The preventive actions for these issues are specified in Attachment C.-

4'. 0 References

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l 4.1 NUREG-0797, Supplement No. 11, Safety Evaluation Report related to )

l the operation of CPSES Units 1 and 2, USNRC, Docket Nos. 50-445 and 50-446, May 1985

-4.2 NUREG-0797, Supplement No. 10, Safety Evaluation Report related to the' operation of CPSES Units 1 and 2, USNRC, Docket Nos. 50-445 and '

50-446, April 1985 i

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SUBAPPENDIX A39 r 1

\- / CPRT QUALITY OF CONSTRUCTION REVIEW ON PIPING AND PIPE SUPPORTS 1.0 Definition of the Issue Evaluation Research Corporation (ERC) was contracted by CPRT to perform the Quality of Construction (QOC) sample inspection of the safety-related components installed in CPSES, including piping and pipe supports. This task was implemented in accordance with CPRT Action Plan VII.c, and the results were discussed in Section 5.2.5 of the CPRT Action Plan VII.c Re-sults Report (Reference 4.1).

ERC inspection covered approximately 82,500 inspection points for piping and pipe supports. ERC evaluated the results and recommended corrective action on the adverse trends and construction deviations on the piping components, gaps, locking devices, pipe clamp spacers, pipe clamps, cotter keys, and angularity offsets.

The recommended corrective actions on the adverse trends and construction deviations of the pipe supports identified in the CPRT-QOC Results Report are summarized as follows:

Construction CPRT Action Plan VII.c Results

/"T Work Category Report Recommendations 1.1 Large Bore Piping Reinspect flow elements to verify Configuration that they are oriented in the proper direction 1.2 Large Bore Piping Verify existing piping clearance Configuration criteria and walkdown on all large bore piping with insulation installed 1.3 Large Bore Piping Reinspect safety-related piping Configuration expansion joints 1.4 Pipe Welds and Reinspect butt welds in Sched-Materials ule 80 or thinner stainless steel piping made prior to 1982 that are replacement welds and/or have received extensive repairs C'

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A39-1

t-l' g Construction CPRT Action Plan VII.c Results. i

) Work Category Report Recommendations l 1.5 Large Bore Walkdown of pipe supports con-

j. Pipe Supports taining vendor-supplied compo-Rigid .nents and replacement of non-conforming parts subject to l appropriate engineering disposi-tion 1.6 Large Bore Inspect for proper gaps between Pipe Supports pipe and pipe support and verify Rigid adequate clearance between pipe welds and pipe support 1.7 Large Bore Inspect and install suitable Pipe Supports locking devices on all vendor-Rigid supplied components that do not have high-strength bolting; install locking devices on all l high-strength bolting that is not 3 torqued to an-acceptable preload 1.8 .Large Bore Walkdown reinspection of pipe Pipe Supports clamps and replace nonconforming Rigid spacers or confirm they fall  !

, within the limits of bounding  !

calculation  !

1 1.9 Large Bore Verify that jam nuts on all Pipe Supports vendor-supplied components (sway Rigid struts, snubbers, and spring cans) are snug tight 1.10 Large Bore Walkdown of all pipe supports Pipe Supports having pipe clamps to verify Rigid security of attachment to the P i pe 1.11 Large Bore Reverify component adjustment ,

Pipe Supports during the startup and preopera- )

Nonrigid tional phases of the plant 1.12 Large Bore Walkdown of all vendor-supplied Pipe Supports components to ensure that proper Nonrigid angularity exists 1.13 Large Bore Walkdown of all supports contain-l Pipe Supports ing vendor-supplied components Nonrigid and inspect cotter keys and associated bolting 1 l

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,- ~s Construction CPRT Action Plan VII.c Results Work Category Report Recommendations (V) 1.14 Large Bore Inspect and install suitable Pipe Supports locking devices on all vendor-Nonrigid supplied components that do not have high-strength bolting, in-stall locking devices on all high-strength bolting that is not torqued to an acceptable preload 2.0 Issue Resolution The Post-Construction Hardware Validation Program (PCHVP) (Reference 4.2) is the portion of TU Electric's Corrective Action Program (CAP) which val-idates the final acceptance attributes for safety-related hardware.

The input to the Post-Construction Hardware Validation Program (PCHVP) is contained in the installation specifications. Final acceptance inspection requirements identified in the validated installation specifications were used to develop the Post-Construction Hardware Validation Program (PCHVP) attribute matrix. This matrix is a complete set of final acceptance at-tributes identified for installed hardware. The Post-Construction Hard-ware Validation Program (PCHVP), by either physical validations or through an engineering evaluation methodology, assures that each of the attributes

/N defined in the attribute matrix is validated, k

SWEC-PSAS developed the Field Verification Method (FVM) CPE-SWEC-FVM-PS-081 (Reference 4.3) to coordinate the Unit I and Common piping and pipe support inspection validation activities.

Piping inspections are performed and documented by Quality Control (QC) personnel to assure that applicable inspection attributes are acceptable.

The piping inspection attributes are as below:

Equipment and piping configuration Piping wall thickness at shop / field bends Radial weld shrinkage at stainless steel piping joints Equipment anchoring Remote valve operators  !

Branch connections i All pressure boundary items installation / base metal defects l Valve orientations Pipe / sleeve details Permanent pipe support installation (no temporary or voided supports)

Verify location (span) dimensions / tolerances l Applicable dielectric insulating sleeves over bolts / studs l Linear dimensions of piping segments and in-line components ,

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I g- The hardware validation of pipe supports assures that the removable items C

\' j on a pipe support are installed as : required by the design documentation.

The hardware validation is implemented by Quality Control (QC) personnel in compliance with the validated support drawing. Quality Control person-nel verify and document that all applicable hardware attributes listed on the hardware validation checklists are acceptable. The following pipe  ;

support hardware validation checklists are used, as applicable:

Adjacent Weld Checklist Bolted Connection Checklist Hilti Bolt Checklist Pipe Clamp Checklist Richmond Insert Checklist Snubber Checklist Support Checklist Sway Strut Checklist Through Bolt / Embedded Bolt Checklist U-Bolt / Bolted U-Guide Checklist Variable / Constant Spring Checklist In addition to the hardware validation pipe support inspections, Quality Control (QC) personnel also conduct inspections for pipe support configu-ration attributes as below:

Material acceptability Support configuration compliance with validated design drawing,

/) including dimensions V Support overhang length / tolerance Support projection length / tolerance Sway strut / snubber pin-to pin dimension / tolerance Alignment and circumferential deviation of shear lugs Hilti bolt size /embedment Weld length of structural member on base plate Welded connection in accordance with validated drawing Edge distance for structural members and base plates Slope of bolted part with bolt head or nut Shim' size / weld SWEC-PSAS developed the Field Verification Method (FVM) CPE-SWEC-FVM- j PS-080 (Reference 4.4) to assure that sufficient clearance exists around the validated piping. Clearance is required to permit those anticipated piping displacements that could occur under plant operating conditions without any impediment to those displacements. An impediment is defined as any structure, pipe, conduit, cable tray, or equipment that encroaches on the envelope of anticipated pipe displacement.

This field verification effort is performed by the SWEC-PSAS engineering personnel. SWEC-PSAS has established clearance criteria and is responsi-ble for training the clearance walkdown teams, evaluating clearance prob- 1 lems, and issuing design changes to correct any clearance violations.  ;

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- The physical validation of mechanical piping attributes (e.g., flow ele-ment orientation and expansion joint installation) is performed by SWEC

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'- mechanical discipline PCHVP as discussed in the SWEC Mechanical Project Status Report (Reference 4.5).

These corrective actions also envelop the resolution of issues in Sub-appendixes A29, A30, A38, and B3. The quality of construction require-ments for piping and pipe supports in the PCHVP were incorporated into the construction and QC inspection procedures to serve as the preventive action.

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• The quality of construction of pipe support installation issue was determined to be reportable under the provisions of 10CFR50.55(e)

(see Subappendix B3, SDAR-CP-86-63).

• The corrective action to resolve this issue is accomplished through the implementation of the Post-Construction Hardware Validation Program.

• The preventive action for this issue is identified in Appendix C.

ll G 4.0 References 4.1 CPRT Action Plan VII.c Results Report, Construction Reinspection /

Documentation Review Plan, Revision 0, June 11, 1987 4.2 TU Electric Engineering and Construction Procedure EC-9.04, Post Con-struction Hardware Validation Program, July 17, 1987 4.3 SWEC-PSAS Comanche Peak Field Verification Method, Hardware Valida-tion and Supplemental Inspection Programs, CPE-SWEC-FVM-PS-081, Revision 0, July 29, 1987 4.4 SWEC-PSAS Comanche Peak Field Verification Method, Clearance Walk-down, CPE-SWEC-FVM-PS-080, Revision 0, July 28, 1987 4.5 TU Electric, CPSES Unit 1 and Common, Mechanical Project Status Re-port, Revision 0 l

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APPENDIX B e' -

f INTRODUCTION This appendix describes the details of resolutions of issues identified during the performance of the piping Corrective Action Program (CAP). Included in this appendix are the piping-related Significant Deficiency Analysis Reports (SDARs) initiated by TU Electric.

Each of the five issues listed below is described in an individual sub-appendix which includes discussions of resolution methodology and corrective and pre-ventive actions.

Issue No. Issue Title l

B1 SDAR-CP-86-33, Stiffness Values for Class 1 Stress Analysis B2 SDAR-CP-86-36, Large Bore Piping and Supports B3 SDAR-CP-86-63,' Pipe Support Installations B4 SDAR-CP-86-67, Preoperational Vibration Test Criteria B5 SDAR-CP-86-73, ASME Snubber Attachment Brackets O]

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l SDAR-CP-86-33, STIFFNESS VALUES FOR CLASS 1 STRESS ANALYSIS i 1.0 Definition of Issue l TU Electric ' identified a deficiency in the stiffness values of pipe sup- j ports for ASME Section III Class 1 piping stress analysis (Reference 4.1). j The pipe support stiffness values used in the previous Westinghouse stress i analysis of ASME Section III Code Class 1 piping in Unit I were based on input from the existing design. These pipe support stiffness - values changed with implementation of the corrective actions from the pipe stress and pipe support validation program, thus rendering the previous results of ASME Section III Class 1 pipe stress analysis in Unit 1 inconsistent

.with the pipe stress and pipe support validation program.

Appropriate ASME Section III Code Class 1 pipe support stiffness values that incorporated corrective actions and modifications resulting from the pipe stress and pipe support validation program must be used in the validated ASME Section III Code Class 1 pipe stress analysis.

2.0 Issue Resolution

.The calculations of the stiffness values for the pipe supports for the ASME Section III Code Class 1 pipe stress analysis packages were completed and these results were transmitted to Westinghouse in accordance with O Section 7.5.7 of project procedure ' CPPP-6 (Reference 4.2) and SWEC-PSAS

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Project Memorandum PM-130 (Reference 4.3). Westinghouse reanalyzed these stress problems and issued revised support loads for pipe support validation.

TU Electric determined that this issue was reportable under the provisions of 10CFR50.55(e) and submitted reports (References 4.1 and 4.4) to the NRC Staff on May 28, 1986, and October 17, 1986. The large bore pipe support modifications and hardware validation status is being updated under 10CFR50.55(e) via SDAR-CP-86-36 (Subappendix B2).

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

• This issue was determined to be reportable under the provisions of 10CFR50.55(e).

• The corrective action to resolve this issue was accomplished by the validation of the ASME Section III Code Class 1 pipe stress analysis  ;

by Westinghouse and by the SWEC-PSAS validation of the pipe supports in accordance with Sections 3.10.8 and 4.3.2.2, and Attachment 4-18 of CPPP-7.

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• The preventive action for this issue is identified in Appendix C. j l 7-~)g

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l 4.0 References 4.1 TU Electric Letter No. TXX-4831, W. G. Counsil to E. H. Johnson, Di-rector, Division of Reactor Safety and Projects, U.S. Nuclear Regula-tory Commission, Stiffness Values for Class 1 Pipe Stress Analysis, May 28, 1986 (SDAR-CP-86 Interim Report).

4.2 SWEC-PSAS Project Procedure CPPP-6, Pipe Stress / Support Requalifica-tion Procedure - Unit 1, Revision 4, April 8, 1987.

4.3 SWEC-PSAS Project Memorandum PM-130, Transmittal of Requalification Results to Westinghouse, December 19, 1986.

4.4 TU Electric Letter No. TXX-6025, W. G. Counsil to E. H. Johnson, Di-rector, Division of Reactor Safety and Projects, U.S. Nuclear Regula-tory Commission, Stiffness Values for Class 1 Pipe Stress Analysis, October 17, 1986 (SDAR-CP-86 Final Report).

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\ 1 SDAR-CP-86-36, LARGE BORE PIPING AND SUPPORTS I

1.0 Definition of Issue i

Impact of CPRT and external issues tabulated in Subappendixes Al through  ;

A35 on the adequacy of the piping and pipe support design and installation 1 processes is significant. j 2.0 Issue Resolution SWEC-PSAS was contracted to validate the piping and pipe supports at i CPSES. Modification of certain pipe supports provided expedient accep-tance for the expanded requirements. Support modifications are cate-gorized as follows:

2.1 Prudent - Supports in this category may have been technically ac-ceptable; however, more time and expense would have been involved in the detailed analysis than that required to physically modify the support and qualify the modification.

2.2 Recent Industry Practice - Mc iific.:tions implemented to eliminate snubbers to enhance plant maintainability, reduce inservice inspec-tion, and minimize worker radiation exposure during operating plant conditions.

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2.3 Adjustment - Minor modifications (such as retorquing or shimming) implemented to meet installation criteria contained in the resolution of the CPRT and external issues.

2.4 Cumulative effects - Modifications that are required due to the com-bined effect of previous issues.

The implementation of the physical modifications of pipe supports is be-ing performed by TU Electric Construction and is being validated by the PCHVP.

TU Electric determined that this issue was reportable under the provisions of 10CFR50.55(e) and submitted the initial Significant Deviation Analysis Report No. SDAR-CP-86-36 (Reference 4.1) on June 9, 1986. Periodic status reports are being submitted to the NRC Staff.

3.0 Corrective and Preventive Action

• No additional issues have been discovered during the review and reso-lution of this issue.

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• This issue was determined to be reportable under the provisions of 10CFR50.55(e).

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• The corrective action to resolve this issue is accomplished through

'T the piping and pfpe supports CAP.

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• The preventive actions for this issue are described in Appendix C.

4.0 References 4.1 TU Electric Letter No. TXX-4844 dated June 9, 1986, W. G. Counsil to E. H. Johnson, Director, Division of Reactor Safety and Projects, U.S. Nuclear Regulatory Commission, Pipe Supports, SDAR-CP-86-36 (In-terim Report)

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SUBAPPENDIX B3

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A SDAR-CP-86-63, PIPE SUPPORT INSTALLATIONS 1.0 Definition of the Issu_e On September 4, 1986, a deficiency was identified involving a broken  !

cotter _ pin on a snubber (Reference 4.1).

2.0 Issue ResoJution The piping, CAP includes the PCHVP that will validate cotter pin installa- l tion in accordance with field verification method CPE-SWEC-FVM-PS-081 (Reference 4.2).

3.0 Corrective and Preventive Action See Section 3.0 of Subappendix A39.

4.0 References 4.1 TU Electric Letter No. TXX-6027, W. G. Counsil to E. H. Johnson, Di-rector, Division of Reactor Safety and Projects, U.S. Nuclear Regula-tory- Commission, Pipe Supports, SDAR-CP-86-63 (Interim Report),

November 3, 1986 4.2 SWEC-PSAS . Comanche Peak Field Verification Method, Hardware Valida- j tion and Supplemental Inspection Programs, CPE-SWEC-FVM-PS-081, Revision 0, July 29, 1987 1

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,, SUBAPPENDIX B4 U) SDAR-CP-86-67, PRE 0PERATIONAL VIBRATION TEST CRITERIA 1.0 Definition of the Issue TU Electric identified a deficiency (Reference 4.1) in the preoperational vibration test criteria. The CPSES criteria document, Preoperational Vi-bration Test Program, Issue 1, June 1980, was reviewed, and it was found that the mathematical formulas used to determine stress endurance limits, allowable deflections, and flexibility characteristics of certain piping systems may not have been accurate. Vibration calculations and test re-sults were evaluated to determine the validity of the original calculations.

The evaluation yielded the following results:

1. Two test data points (from a total of 21 syste;a tests) were found to exceed the allowable deflection limits.

2. The measured direction of deflection movement was not clearly identi-fied in all instances.

3. The test deflect.'ons were measured in only one direction in some Cases.

O) v 2.0 Issue Resolution As a result of the piping Corrective Action Program (CAP) and extensive modifications to the piping systems, TU Electric will repeat the preopera-tional vibration testing. SWEC-PSAS has established Project Procedure CPPP-25, Unit 1 Piping Vibration Test Procedure (Reference 4.2), for the management and assessment of piping system vibration as required by the CPSES FSAR Section 3.9.B.2. This preoperational vibration test procedure is based on information contained in NRC Regulatory Guide 1.68 (Refer-ence 4.3) and Section 3.9 of NUREG-0800 (Reference 4.4). SWEC-PSAS will provide technical services to the testing program.

TU Electric determined that this issue is reportable under the provisions of 10CFR50.55(e) and submitted SDAR-CP-86-67 on February 19, 1987.  !

3.0 Corrective and Preventive Action

+ No additional issues were discovered during the review and resolution  !

of this issue.

• This issue was determined to be reportable in accordance with the I provisions of 10CFR50.55(e). l I

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• The corrective actions to resolve this issue will be implemented by

.y) repeating the preoperational piping vibration testing by a new test procedure to resolve the concerns.

• Preventive action for this issue is identified in Appendix C.

4.0 References 4 4.1 TU Electric Letter No. TXX-6072 dated October 27, 1986, W. G. Counsil to U.S. Nuclear Regulatory Commission, Attention: Document Control Desk, SDAR-CP-86-67 Preoperational Vibration Test Criteria 4.2 SWEC-PSAS Project Procedure CPPP-25, Piping Vibration Test Procedure, Revision 0, December 8, 1986 4.3 USNRC Regulatory Guide 1.68, Initial Test Programs for Water-Cooled  !

Nuclear Power Plants, Revision 2, January 1978 4.4 USNRC Standard Review Plan NUREG-0800, Section 3.9.2, Revision 2, July 1981 l

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r3 SUBAPPENDIX B5 l \ )

SDAR-CP-86-73, ASME SNUBBER ATTAClefENT BRACKETS l

1.0 Definition of the Issue TU Electric identified a deficiency (Reference 4.1) involving restriction of the snubber swing angle by the snubber rear brackets. Rear brackets on safety-related snubbers have the potential to cause restricted movement and binding due to the use of the incorrect rear bracket.

2.0 Issue Resolution A drawing review of ASME Section III, Code Class 1, 2, and 3 snubbers was conducted to verify the adequacy of swing clearances, and identified 1063 snubbers as having attachment brackets. As a result of field examination, <

the number of snubbers requiring evaluation has been reduced to 165.

2.1 These 165 supports were evaluated by comparing the field verified swing angle data with the predicted movements. The results are as follows:

• 83 supports were determined to have sufficient field verified swing angle to accommodate the predicted pipe movement.

(' + 15 supports were determined to be unnecessary in a previously initiated pipe support validation effort (and are being deleted).

• 33 supports are being modified as a result of the pipe support validation effort (but not as a result of this deficiency).

• 31 supports have been identified as having less clearance than required by analysis and are being modified to correct the situation.

• 3 supports have no safety-related function and do not impair the safety-related function of other components and therefore re-quire no further evaluation for safety significance.

2.2 TU Electric determined that this issue was reportable under the pro-visions of 10CFR50.55(e) and submitted Significant Deficiency Analy-sis Report SDAR-CP-86-73 (Reference 4.1).

3.0 Corrective and Preventive Action

• No additional issues were discovered during the review and resolution of this issue.

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• This issue was - determined to be reportable under the provisions of l 10CFR50.55(e).

• The corrective action to resolve the snubber rear bracket issue is beingL accomplished through the implementation of CPSES Construction Procedure CP-CPM-9.10A, paragraph 3.6 and CPSES Quality Control Procedure Nos. CP-QAP-12.1 and QI-QAP-11.1-28, which require a check for binding on the rear bracket. Additionally, a backfit inspection was implemented in accordance with Field Verification Method THE-FVM-PS-038.

• The preventive actions are identified in Appendix C.

i 4.0 References 4.1 .TU Electric Letter No. TXX-6104, W. G. Counsil to : E. H. Johnson, 'Di-  :

rector, Division of Reactor 3nfety and Projects, U.S.' Nuclear Regula-tory ' Commission, Snubber Rear Brackets, SDAR-CP-86-73, November 19,

.1986 4

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APPENDIX C - PREVENTIVE ACTIONS

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The preventive actions are embodied in the procedures developed and used for the Corrective Action Program. These procedures resolve all CPRT and external issues as well as all issues identified during the performance of the CAP.

Implementation of the preventive actions will assure that the design and hard-ware for CPSES Unit I and Common can continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4. The particular preventive actions preclude the recurrence of the issues identified in Appendixes A and B as summarized below in Sections 1.0 and 2.0, respec-tively.

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, 1.0 APPENDIX A ISSUES - PREVENTIVE ACTION l )

U A1. Richmond Inserts Attachment 4-5 of CPPP-7 (Reference C.1) provides requirements and instructions for the inclusion of bending stress in the analysis of bolting used in Richmond inserts with tube steel, the proper modeling of Richmond insert to tube steel connections, length limits of tube steel members used with two or more Richmond inserts, and evaluations of spacing between inserts. Attachnent 4-13 of CPPP-7 provides pro-cedures for the evaluation of local stresses due to nuts bearing on tube steel walls. SWEC-PSAS Prcject Memorandum PM-141 (Refer-ence C.2) provides procedures to check the potential unequal shear loading when the tube steel connection is anchored by two or more Richmond inserts. Additionally, Quality Assurance Procedure QI-QAP-11.1-28 (Reference C.3) was revised to include inspection for proper thread engagement.

A2. Local Stress in Piping Attachments 4-6A, 4-6B, and 4-6C of CPPP-7 provide requirements and instructions for the evaluation of local run pipe stresses due to integral welded attachments (4-6A), and support bearing loads (4-6B and 4-6C).

The use of zero-gap box frames, the evaluation of pipe support stiff-

% nesses and the evaluation of local stresses in pipe support members s are discussed in the preventive actions of Subappendixes A4, AS, and A21, respectively.

A3. Wall-to-Wall and Floor-to-Ceiling Supports Attachment 4-19 of CPPP-7 provides procedures for the inclusion of the effects of differential seismic displacements and the long-term effects of concrete creep on supports which span wall-to-wall and floor-to-ceiling.

A4. Pipe Support / System Stability Section 4.2.4 and Attachment 4-9 of CPPP-7 provide requirements for the modification of potentially unstable pipe support configurations.

A5. Pipe Support Generic Stiffness Section 3.10.8 of CPPP-7 provides baseline stiffness values for rigid pipe supports, anchors, and snubbers. Section 4.3.2.2 of CPPP-7 out-lines the approach to be used in determining pipe support stiffnesses and Attachment 4-18 is a tabular / graphic compilation of support com-ponent and standard support subassembly.

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,_s A6. Uncinched U-Bolt Acting as Two-Way Restraint k- Section 4.2.5.2 and Attachment 4-3 of CPPP-7 provide requirements and instructions for the proper application and evaluation of uncinched U-bolts used as two-way restraints. Section 4.3.2.2 and Attach-ment 4-18 of CPPP-7 provide the stiffness values for uncinched U-bolts used as two-way restraints.

A7. Friction Forces Section 4.7.3 of CPPP-7 requires that the effects of friction forces  !

acting on pipe supports be included in the design for all noneyclic loads. Attachment 4-7 of CPPP-7 provides the methods of implementing this requirement.

A8. AWS Versus ASME Code Provisions Section 4.4 and Attachment 4-2 of CPPP-7 provide guidance for the design / qualification of skewed joint welds.

The angular limits of skewed, T-joint welds requires no preventive action since CPSES weld procedures are qualified by testing, which overrides the AWS angle limitations.

A9. A500, Grade B Tube Steel rs Section 4.7.2.1 of CPPP-7 specifies the design criterion of pipe sup-() ports using A500, Grade B tube steel. l A10. Tube Steel Section Properties Section 4.3.2.1 of CPPP-7 requires the use of the 8th Edition of the AISC Manual of Steel Construction (Reference C.4) in the selection of section properties for support design / qualification to preclude the use of inappropriate section properties for tube steel.

Specification No. 2323-MS-100 (Reference C.5) has been revised to assure that an effective throat of t = t-1/16 in. is achieved for welds on all tube steel sizes for any new design in the future.

Section 4.4 and Attachment 4-2 of CPPP-7, Revision 3, as amended by SWEC-PSAS Project Memorandum PM-140 (Reference C.6), specifies effec-tive throat dimensions for flare bevel welds which meet the criteria of AWS. The revised guidelines of PM-140 will be followed for any future weld evaluation to preclude the recurrence of inadequate ef-fective throat size.

All. U-Bolt Cinching Sectiou 4.2.5.1 of CPPP-7 deleted the use of cinched U-bolts /

crosspiece supports with struts / snubbers.

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l A12. Axial / Rotational Restraints d Sections 3.10.6.2 and 4.6.3, and Attachments 3-11 and 4-8 of CPPP-7 establish the procedure for the analysis of axial and rotational restraints.

A13. Bolt Hole Gap Attachments 4-4 and 4-5 of CPPP-7 and SWEC-PSAS Project Mem-orandum PM-141 provide procedures for the design and evaluation of base plate bolt holes. Specification No. MS-46A (Reference C.7) and Quality Assurance Procedure QI-QAP-11.1-28 specify the design re-quirements and QA inspection tolerance of the bolt hole diameters.

A14. OBE/SSE Damping Section 3.0 of CPPP-7 requires the use of OBE/SSE damping values that are consistent with Regulatory Guide 1.61 (Reference C.8) as modified by ASME Code Case N-411.

4 A15. Support Mass in Piping Analysis Section 3.10.4, Attachment 3-4, and Attachment 3-11 of CPPP-7 provide '

guidance for the determination of pipe support mass and require the inclusion of this mass in the piping stress analysis.

A16. Programmatic Aspects and Quality Assurance, Including Iterative g Design Project Procedures CPPP-1, (Reference C.9) CPPP-6, (Reference C.10) and CPPP-7 control the validation of the piping and pipe supports.

This is an integrated effort within one organization and assures proper interface between piping analysis and pipe support design.

Additionally, personnel involved in the validation process receive training in the proper application of the requirements.

Interface with Westinghouse for Class 1 stress analysis is discussed in Subappendix B.1.

A17. Mass Point Spacing Section 3.10.6.1 and Attachment 3-7 of CPPP-7 provides guidelines for the proper location of mass points in pipe stress analyses.

A18. High-Frequency Mass Participation Section 3.10.6.8 of CPPP-7 specifies the criteria to account for high frequency mass participation in stress analyses. Use of computer program NUPIPE-SW (V04/L02) has been revised to automatically account for high frequency mass corrections.

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A19. Fluid Transients n

Project Procedure CPPP-10 (Refe?t:nce C.11) describes the procedure by which fluid transient events are identified for applicable systems l for inclusion in the pipe stress analyses. {

Section 3.4.5.5 and Attachment 3-1 of CPPP-7 provide requirements and instructions for the inclusion of these load conditions in the stress analyses, l

A20. Seismic Excitation of Pipe Support Mass Attachment 4-21 of CPPP-7 specifies the requirements for inclusion of the effects of pipe support self-weight excitation in the support evaluation.

A21. Local Stress in Pipe Support Members Attachment 4-13 of CPPP-7 establishes the requirements to evaluate local stresses which may occur in pipe support members.

A22. Safety Factors The technical and design control procedures assure that the piping systems are designed in accordance with the CPSES design criteria, and therefore, they will perform their safety-related functioa.

h a A23. SA-36 and A307 Steel Section 2.0 of CPPP-7 lists the applicable governing codes to be used to assure that the proper allowable stresses (determined from the minimum material yield strengths) are used in the design. Sec-tion 4.2.5.1 of CPPP-7 deletes the use of cinched U-bolts / crosspiece supports with struts / snubbers. Attachment 4-5 of CPPP-7 establishes the requirement for the reduced allowables of high strength bolts used with A563 Grade A nuts.

A24. U-Bolt Twisting Section 4.2.5.1 and Attachment 4-8 of CPPP-7 provides guidance for the modification of U-bolt trapeze supports. Cinched U-bolts used with struts or snubbers are deleted from CPSES.

A25. Fisher / Crosby Valve Modeling/ Qualification The validation process requires a conservative 55/45 flow distribu-tion ratio on the outlet configuration.

Section 7.4.3 of CPPP-6 establishes the requirements for assuring that valves are properly qualified to the as-built loadings.

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("' Section 3.10.6.5 of CPPP-7 addresses the proper valve yoke modeling i of flexible valves.

A26. Piping Modeling Section 3.0 of CPPP-7 provides direction and requirements for the proper modeling of piping systems.

A27. Welding Section 4.4 and Attachment 4-2 of CPPP-7 provide requirements for the design and analysis of welded joints.

A28. Anchor Bolts /Embedment Plates Attachment 4-4 of CPPP-7 provides guidance and requirements for the evaluation of anchor bolt embedded depths and edge distances.

Project Procedure CPPP-6 provides controls to assure that reaction loads on embedded plates, attachment spacing between embedded plates, and as-built loads for through-bolts are transmitted to responsible groups-for evaluation.

A29. Strut / Snubber Angularity Section 4.2.6 of CPPP-7 specifies requirements to assure that force O

V components resulting from off-axis loading of struts and snubbers is included in the support design.

1 Specification No. 2323-MS-100, Construction Procedure CP-CPM-9.10A  !

(Reference C.12), and Quality Assurance Procedure QI-QAP-11.1.28 have been revised to incorporate the resolutions of the items related to this issue.

A30. Component Qualification Sections 3.4.5 and 4.2 of CPPP-7 delineate the requirements to assure that piping movements due to system design conditions are considered in the evaluations of frame gaps, swing angles, and spring and snubber travel.

Quality Assurance Procedures QI-QAP-11.1-28 and CP-QAP-12.1 (Refer-ence C.13) have been revised to include inspections for the existence and tightness of all locking devices on pipe supports.

A31. Structural Modeling for Frame Analysis Section 4.3.2.1 of CPPP-7 requires the use of AISC Manual of Steel Construction, 8th Edition for the selection of the member properties used in the analysis, including values for torsional resistance.

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Attachment 4-5 of CPPP-7 provides the modeling technique used for the

(,s). Richmond insert / tube steel connection.

LI Attachment 4-18 of CPPP-7 provides procedures for the proper modeling of the connection stiffness for use in the frame analysis.

A32. Computer Program Verification and Use Section 5.0 of CPPP-7 identifies the computer programs acceptable for  ;

use in the validation of piping and pipe supports. This list assures  !

that only those programs verified in accordance with SWEC standard QA program requirements for verification, technical adequacy, and appro-priate version are used in the validation program.

A33. Hydrotest Sections 3.6.2.4 and 4.7.2 of CPPP-7 provide guidance for the evalua-tion of piping and supports for hydrotest loading.

A34. Seiamic/Nonseismic Interface Attachment 4-10 of CPPP-7 provides requirements and instruction for the design of safety-related piping attached to nonseismic piping.

A35. Other Issues

, -~s CPPP-6 and CPPP-7 provide technical and administrative procedures to

() address the concerns described in the 51 DIRs referenced in Subappendix A35.

A36. SSER-8 Review Resolution of this issue requires no preventive action, since design allowables for Richmond inserts and anchor bolts are based on the actual strength of concrete at CPSES.

A37. SSER-10 Review No preventive action is required for the uncontrolled plug welding issue. As concluded by the CPRT Action Plan V.d Results Report (Reference C.14), the current procedures and practices for the repair of mislocated holes are adequate to preclude the recurrence of undoc-umented plug welds.

TU Electric Construction Procedure CP-CPM-1.2 (Reference C.15) and Project Procedure CPSP-30 (Reference C.16) provide procedures for the evaluation of the installed piping and pipe support configuration including the proper design of temporary supports prior to a piping system hydro to assure the integrity of the installed safety-related piping and pipe supports.

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f^ Project Procedure CPPP-28 (Reference C.17) and Attachment 4-10 to i

CPPP-7 provide direction and requirements for the identification and l evaluation of interface anchors between seismic and nonseismic piping  !

to - assure isolation of Category.I systems from non-Category I systems. ,

Quality Assurance Procedure QI-QAP-11.1-28 has been revised . (Revi-sion 30) to include acceptance criteria and measurement techniques I for the inspection of Type 2 skewed welds.

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A38. SSER-11 Review Attachment 3-15 to CPPP-7 provides the procedure to analyze ' girth I welds.

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Quality Control Procedures QI-QAP-11.1-28 and CP-QAP-12.1 have been revised to assure that the items related to the QA Inspection Program have been addressed.

A39. CPRT Quality of Construction Review on Piping and Pipe Supports TU Electric instituted the Post-Construction Hardware Validation Pro-gram (PCHVP) (Reference C.18) to validate that the as-built hardware complied with the design for Unit 1 and Common safety-related piping and pipe supports. The quality of construction requirements for pipe  ;

supports in the PCHVP were incorporated into Quality Assurance Pro-cedures QI-QAP-1.11-28 and CP-QAP-12.1.

2.0 APPENDIX B ISSUES - PREVENTIVE ACTION Bl. SDAR-CP-86-33, Stiffness Values for Class 1 Stress Analysis Project Procedure CPPP-6 requires that support stiffness values for pipe supports for Class 1 lines be computed and provided to Westing-house for use in the stress analysis of Class 1 lines.

B2. SDAR-CP-86-36, Large Bore Piping and Supports Design Basis Documents (DBD) (References C.19, C.20, and C.21) for large bore piping and the supports have been established. These doc-uments delineate the applicable specifications, detailed technical procedures, and construction and QC inspection procedures, required to maintain the validated design. ,

l B3. SDAR-CP-86-63, Pipe Support Installation f I

The as-built verification procedure, CPSP-12 (Reference C.22), and l the Pipe Stress / Support Final Reconciliation Procedure, CPPP-23 j (Reference C.23), combined with those Quality Assurance inspection procedures identified in the DBD-CS-067 (Reference C.18) provide as-O C-8

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,, -ss surance that pipe support installations will meet the requirements of l ) the design.

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B4. SDAR-CP-86-67, Preoperational Vibration Test Criteria The results of the preoperational vibration testing will be reviewed by SWEC-PSAS to assure that the results satisfy the design criteria. j No further preventive action is required because preoperational vi- f bration testing is a one-time event, which will not be repeated fol- ]

lowing the issuance of an operating license.

B5. SDAR-CP-86-73, ASME Snubber Attachment Brackets Quality Assurance Procedure QI-QAP-11.1-28 has been revised to in-spect for the incorrect use of the correct attachment brackets for  !

snubbers.

REFERENCES:

C.1 SWEC-PSAS Project Procedure CPPP-7, Design Criteria for Pipe Stress and Pipe Supports, Revision 3, February 27, 1987 C.2 SWEC-PSAS Project Memorandum PM-141, Unequal Shear Loading Effect on Richmond Insert and Threaded Rods Used in Conjunction with Tube Steel, Revision 0, March 25, 1987 p)

(, C.3 CPSES Quality Assurance Procedure QI-QAP-11.1-28, Fabrication and Installation Inspection of Safety Component Supports, Revision 35, January 8,1987 C.4 AISC Manual of Steel Construction, 8th Edition, 1980 C.5 CPSES Piping Erection Specification No. 2323-MS-100, Revision 9, August 17, 1987 C.6 SWEC-PSAS Project Memorandum PM-140, Flare Bevel Groove Welds, Revision 1, May 1, 1987 C.7 CPSES Nuclear Safety Class Pipe Hangers and Supports Specification No. 2323-46A, Revision 7, May 7, 1987 C.8 NRC Regulatory Guide 1.61, Damping Values for Seismic Design of Nuclear Power Plants, October 1973 C.9 SWEC-PSAS Project Procedure CPPP-1, Management Plan for Project Quality (Piping System Qualification /Requalification), Revision 7, March 25, 1987 C.10 SWEC-PSAS Project Procedure CPPP-6, Pipe Stress / Support Requal-ification Procedure, Revision 4, April 8, 1987

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C.11 SWEC-PSAS Project Procedure CPPP-10, Procedure for Review of Plant

( )s Operating Mode Conditions, Revision 1, April 1, 1986 C.12 CPSES Construction Procedure CP-CPM-9.10A, Installation of Vendor Supplied Component Supports Catalog Items, Revision 1, August 15, 1985 C.13 CPSES Quality Assurance Procedure CP-QAP-12.1, Mechanical Component Installation and N-5 Certification, Revision 18, Janua ry 12, 1987 C.14 CPRT Action Plan V.d Results Report, Revision 1, Plug Welds, December 18, 1986 C.15 CPSES Construction Procedure CP-CPM-1.2, Construction Activities for Systems and/or Areas Accepted and/or Controlled by TU Electric Plant Operations, Revision 5, March 4, 1987 C.16 SWEC-PSAS Project Site Engineering Procedure CPSP-30, Processing TU Electric Requests for Temporary Hangers, Revision 0, October 7, 1987 C.17 SWEC-PSAS Project Procedure CPPP-28, Procedure for Identification and Evaluation of Interfaces Between Seismic and Nonseismic Piping, Revision 0, February 20, 1987 C.18 TU Electric Engineering and Construction Procedure EC-9.04, Post

/"'N Construction Hardware Validation Program, July 29, 1987 V TU Electric Design Basis Document DBD-CS-065, ASME Class 1 Piping C.19 Analysis (Draft), August 14, 1987 C.20 TU Electric Design Basis Document DBD-CS-066, ASME Class 2 and 3 Piping Analysis, Revision 0, July 31, 1987 C.21 TU Electric Design Basis Document DBD-CS-067, ASME Class 1, 2, and 3 Pipe Support Design, Revision 0, July 31, 1987 C.22 SWEC-PSAS Project Site Engineering Procedure CPSP-12, As-Built Ver-ification (Piping), Revision 0, November 12, 1986 C.23 SWEC-PSAS Project Procedure CPPP-23, Pipe Stress / Support Final Rec-conciliation Procedure, Revision 0, March 2, 1987 1

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