View source for TXX-4145, Forwards Comments on Cygna Independent Assessment Program, Per Request.Some Comments Relate to Concerns in Util

{{Adams
| number = ML20083K086
| issue date = 04/06/1984
| title = Forwards Comments on Cygna Independent Assessment Program, Per Request.Some Comments Relate to Concerns in Util
| author name = Schmidt H
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Youngblood B
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-4145, NUDOCS 8404160060
| title reference date = 04-02-1984
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 12
}}

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* Log # TXX-6145 File # 10010 TEXAS UTILITIES GENERATING COMPANY M KYWAY TE DWEN
* 4470 NHHTil E SLIVE MTHEE T, L.fl. Mt
* IDALLAM, TEXAM 73201 April 6, 1984
+
Mr. B. J. Youngblood Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.             20555

==SUBJECT:==
TUGC0 COMMENTS ON CY2..\'s INDEPENDENT ASSESSMENT PROGRAM

==Reference:==
Schmidt (TtGCO) to foungblood (NRC) letter TXX-4134, dated April 2, 1984

==Dear Mr. Youngblood:==

Atta_hed are TUGCO's comments on CYGNA's Independent Assessment Program as requested by you. Some comments that were made directly relate to concerns previously addressed in the above referenced letter.
If there are any further questions of clarifications requested regarding the CYGNA report or these comments, please contact us.
Very truly yours, d
f H. C. Schmidt o
HCS:kp Attachment (s)-
c - Ms. Nancy Williams, CYGNA Mr. Nicholas.S. Reynolds h-
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Page 1
         ~
LTUGC0 REVIEW.0F CYGNA'S INDEPENDENT ASSESSMENT PROGRAM
   .       u.'       1 Volume /Section/
Item               Page                           Cygna Statement                                TUGC0 Comments
,.-        :10     LVolume 1J             End~ connections consisting of angles anchored to    End connections of angles anchored to f                   HCTS-00-031          . concrete by either one or <two bolts were modeled   concrete by one or two bolts is modeled as Page 8 af 13:         as hinges'in the cableitray support frame            a hinge connection in the cable tray support
                             ;(b).        analysis. The assumption of a fixed joint is         frame analysis. Cygna suggests that a fixed more appropriate considering the rigidity of the     joint is more appropriate considering the base angle connection.                               rigidity of the base angle connection.
s Texas Utilities suggests that this                   '
difference of opinion is a matter of engineering judgement, that the modeling
 '                                                                                             technique used is justifiable and that the des"gn compensates for the differences in
'                                                                                              the boundary conditions of the connections (i.e., tension, shear, prying action, etc.)
:2.     'Section!1'          f0f the six conduits checked, one instance was         Editorial, C-03015123-2 should be read
                   .Page 13/13            found where the Cable and Raceway Schedule           C-03015123.
                                         . identified the conduit :between Spent Fuel
                                        . Cooling Panel XLV-06 and T130FCZ33 as
                                        'C-03015123-2. The installation and. routing drawing identified this as Conduit No.
                                         -C-13015123.
3.-     Page~3-10             Check electrical isolation between safety and        Editorial, currer.ts should read circuits, non-safety currents.
:           4.1    . Exhibit 3.1.         This is'a reportable finding to CG&E under           Editorial, CG&E should read CPSES.
requirements of 10CFR Part 21.                                                                             ~
: 15. :    Vol ume' I t.         Cygna does suggest that the anchor bolt              Embedment depth question was discussed in Page 4-10             enbedment. lengths be removed from the support       letter to NRC, TXX-4134 (Homer Schmidt to
                                        . drawings during the next revision.                   B. J. Youngblood.

Page 2
                                           .TUGC0 P: VIEW 0F CYGNA'S INDEPENDENT ASSESSMENT PROGRAM Volume /Section/
Item ^         Page                               Cygna Statement                                 TUGC0 Comments 6.-      Page 4-12         .There was no clear assurance, however, that            Cygna states "there was no clear assurance, sufficient margins existed for all the other           however that sufficient margins existed for support design within the plant.                       all other support designs within the plant."
Although the topic of the above discus; ion is the cable tray supports, it is not clear that this sentence is referring to other cable tray supports in the plant or other types of supports. A clarification is required.
: 17.       Page.4-15          ... routing of the 3-1/C-753 MCM w2s verified          Cable denoted 3-1/C-750 MCM should read up...                                                  "(3) 1/C 750 MCM Cable."
: 8.       Page 4-16          Editorial                                              T120/FBU12 should read T120FBU12 T120/FBU11 should read T120FBUll 3-1/C-750MCM should read (3) J/C 750 MCM C130FCZ33 should read C-13015123 C-030/15123-Z should read C-13015123 C-130/15123 should read C-13015123
: 9.      -Page 4-17          It was further noted that cable E0/018815 is           (1) Editorial E0/018815 should read E0018815 listed as being deleted in the Unit 1 cable schedule issue 308. .The cable is terminated           (2) Motor Control Center designated as at the Unit 2 B0P Auxiliary Relay Rack 4 in                 EPS-EPMD B-3 is not a correct number, accordance with connection drawing E2-0158.                 It should be CP::-EPMCEB-03. This can bc The. termination of the cable at Motor                      verified by reviewing the terininal block
<                                Center EPS-EPMDEB-3 was verified.                           diaaram E-2-0158 and drawing El-0071 sheets 14 and 24.
(3) Editorial, C-13015123 should read C-03015123.

f,        , ,.
                        ,                                                                                                                     Page 3'
           ~
iTUGC0 REVIEW 0F.CYGNA'S INDEPENDENT. ASSESSMENT FROGRAM
                             ' Volume /Section/:
                ~ Item.
2
:Page'                             '
                                                                                      - Cygna Statement                         'TUGC0 Comments
: 10. . :- Vol ume' 11                     List of drawings reviewed for-Spent Fuel Pool          "Page" used in this reference is actually a Section C ..                 LCooling System -(Train A)'                              sheet number and'sume page numbers do not PageJ7 of.;11                                                                         apply for some electrical drawings.
11.'- ' Appendix E-                    ' When compared to the pipe support as-built             The tolerances provided by Design
: s.                          -Page 8                   . configuration, these. locations should be within       Specification 2323-MS-46A, Revision 3,
:DC-l'                        ' the' tolerances of Project Design Specification        Section 3.6.2.1.1 are for original support 3323-MS-46A.        Section 3.6.2.1.1., i.e.,            design. The tolerances provided in Revision 3 of. the specification are co.npatible with
     ,                                                                                                             the tolerances provided in construction 1                                                                                                                  procedures CP-CPM-9.10. The' tolerances provided in MS-46A and CP-CPM-9.10 are
+
bounded by the tolerances provided in the
                                                                                                                    'As-Built' verification program procedure CP-EI-4.5-1.
: 12.       Page 11-14'                     Editorial                                             1/2 SSE should read OBE.
DC !                  13.- -Page 4-11=                         ASME Boiler and Pressure Vessel Code Section III, ASME B&P Vessel Code Section III, Subsection DC                         -Sub-section NF,:1977 edition.
NF, 1977 Edition is not the code that was committed to for CPSES. The code is the 74 The-stiffness 'of a pipe support in the pipe's         Edition through and including the Winter restrained-direction must meet the required           Addenda, 74.
                                                       ,     stiffness'shown in'Exhioit 4.1-l'according to i-                                                           the nominal . size of restrained pipe.                Cygna states that the " stiffness of a pipe
,                                                                                                                  support must meet the required stiffness P                                                                                                                  shown..." It is Texas Utilities practice that the actual 'as built' stiffness for Class 1 piping system supports are P
                                                                               .r                       v

Pags 4.
                                                                                                                                 ~
TUGC0 REVIEW OF CYGNA'S INDEPENDENT ASSESSMENT PROGRAM Volume /Section/-
Item-        Page                             Cygna Statement                              TUGC0 Comments calculated and provided for the 'as built' analysis. Other non-Class 1 systems do not require this stiffness to conform to the the indicated stiffness values. These values are used by the piping analyst as generic stiffness input into the pipe stress analysis model. Deflection calculations are used as the design guideline for pipe supports. It is requested that Cygna either clarify this statement or identify the industry standard, specification, or guideline on which it is based.
: 14. Page 5-11          The maximum total gap allowed in the restrained     Gaps provided for restraints are installed DC-2               direction is 1/8". In unrestrained directions,   with the tolerances provided in the (4.1.2)            the support design shall allow clearance for        construction procedure CP-CPM 9.10, Section the most severe thermal plus seismic movements      3.3.1.2. The maximum total diametrical gap of the pipe.-                                       normally allo.ied is 3/16", not 1/8" as indicated.
: 15. Page.5-ll          Deviations                                          See Item 11 above.
        .DC-2 (4.1.3)
: 16. Page 6-11          The spring's available travel will be checked       Spring supports are not checked against both DC-2               against all the thermal and seismic movements.      thennal and seismic movement, aq1y thermal.
All piping supports are designed to be essentially rigid. Seismic motion is considered neglible.

Paga.5-TUGC0 REVIEW 0F CYGNA'S INDEPENDENT. ASSESSMENT PROGRAM Volume /Section/                                                                       TUGC0 Comments Item          Page-                            Cygna Statement The midpoint of thermal travel for snubber             The' snubber cold and hot normal operating 17.- -Page 6-11                                                                 setting is provided on drawings. However, DC             . strokes shall be set at the midpoint of the (4.1.6)            total travel with . hot and cold settings             some snubbers are set near their limits due established accordingly.-                             to space limitations. A snubber is set with at least a 1/4" margin provided within the snubber stroke after worst case thermal conditions are considered.
: 18. Page 7-11.         All seismic supports shall be plus and minus          Cygna states that seismic restraints shall restraints. Regardless of other imposed loads,        be in each direction along the restraining DC-2 (4.1.10)
                         .the pipe must be physically restrained in each        axis. However, uni-directional supports can direction along the. restraining axis.                be used if the dead weight of the unrestrained load is considered as its own restraint.
Friction loads (FL) are to be applied in the         The friction load is considered the product
: 19. Page 8-11.
DC-2                direction of thermal movement. Its magnitude     of a friction factor and the sum of the dead shall-be the friction coefficient times the           and thermal loads. The friction load can, (4.2)                                                                    at times, be less than the pipe's dead load, algebraic sum of the pipe's dead load and the normal thermal load but shall not be less than        A clarification or basis of Cygna's comments should be provided. PSE and ITTG only the pipe's dead load.
consider friction loads if thermal movement is greater than 1/16".
Page 9-11          Editorial                                             Type, E705 should read E70S.
20.
DC-2 (4.4)
: 21. Page 9-11'         Concrete expansion anchors should not be used         Expansion anchors are not used indiscrim-indiscriminately.                                     inately. The preferred methods are embedded DC-2 plates, bolts or Richmond inserts. However, (4.5.1)

i Page 6
                                          ' TUGC0 REVIEW 0F CYGNA'S . INDEPENDENT ASSESSMENT PROGRAM Volume /Section/
Item          Page-                              Cygna Statement                                TUGC0 Comments many of the pipe supports use expansion anchor bolts in their design. This is due to construction and design requirements.
: 22. . Page 5-8.             Editorial                                             1/2 SSE should read OBE.
DC-3
         '(4.2).
  '23. Appendix F'           Centralization of existing document distribution      (2.0a) Six satellites are being fonned, not Obs.~ Record Rev. points (file custodians) into eight remote           the eight indicated.
DC-01-01.          - Document Control Center (DCC) Satellite" stations.
24.. PI-02            The. tolerance for support design location is + 1      Specification 2323-MS-46A, Rev. 3, Paragraph Page 1 of 1          pipe. diameter per Gibbs & Hill Specification          3.6.2.1.1 is not applicable to the 2323-MS-46A, Rev. 3, Paragraph 3.6.2.1.1.              'as built' analy?.is. Tolerances for as-built conditions are provided in procedure CP-CPM 4.5.1.
: 25. WC     03           Of the six conduits checked, one instance was           C-03015123-2 should read C-03015123 Page-1 of-2       -found where the Cable and Raceway Schedule               C-13015123 should read C-13015123 identified the conduit between Spent Fuel              The first (3) number indicate unit, voltage Cooling Panel XLV-06 and T130FCZ33 as                   and function only.
C-13015123. The installation and routing drawing identified this as conduit number C-13015123.
The conduit identification number consists of the last five digits (i.e., 15123). This
                            . number is consistent with the reference documents and the installation. The first

s
* Page 7 TUGC0 REVIEW 0F CYGNA'S INDEPENDENT ASSESSMENT PROGRAM Volume /Section/.
Item-          Page                             Cygna Statement                                 TUGC0 Comments three numbers indicate unit, function, and voltage only. Since. the only discrepancy is the unit. number,'there is no safety impact.
26 . PS-02/03             - See Item 5 above.                                   Embedment length concern addressed in NRC Att. A                                                                     letter. Embedment lengths on drawing are used during installation and QC inspection.
       .e
: 27. F5-09                - The working range for spring hanger SI-1-042-       Incorrect support number is provided, the 002-S22K (i.e., top up or bottom out) was            number may be SI-1-079-001-S22. Displace-not checked to ensure that the travel due to         ment due to seismic motion is not included seismic movement was within the working range        in any site specific guidelines due to the of the hanger,                                       rigidity of the piping systems. In addition, the spring is designed within its working range and springs have enough travel outside the working range to account for any seismic motion.
: 28. PS-10                 The design input data for support RH-1-064-          The design input data for support RH-1-064-010-522R contained an. error in the X                010-S22S contains no values for an X displacement sign (+ .395" vs. 395"). This           displacement of + or - 0.395". This seers error appears on the form transmitted from           seems to be an incorrect support drawing
                            - the pipe stress group to the pipe support           drawing number.
_ group for the use in the design.
: 29. Volume 2              Does FSEG maintain a log for each drawing that       The scope of procedure CP-El-4.04 is limited Appendix H             shows any deviations for that drawing?               to conduit support design drawings, DC-01-01              Comments:                                            2323-S-910 Series. Prior to January, 1984, Page_6 of 8                                                                FSEG kept logs of deviations for conduit
      .(Item 25)             1. Per procedure for internal documents.           support drawings (S-910). Subsequently this responsibility has been transferred to DCC

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Page 8 TUGC0 REVIEW 0F?CYGNA'S INDEPENDENT ASSESSMENT PROGRAM
                  . Volume /Section/
Item             Page-                                 Cygna' Statenent                                TUGC0 Comments
: 2. ' Logs for older drawings received from DCC        as indicated in Section 2.2.2 of procedure
                                             . are not completely up-to-date when compared      CP-EI-4.0.4. .Cygna suggests that older logs
                                              -with DCC.                                        received from DCC are not up-to-date. For conduit supports, older logs were not kept
                                         ;3. See Attachment 7 for the change matrix.         by DCC. In addition, the attachment does not refer to S-910 drawings. Further clari-fication is required by Cygna to determine if they are only considering conduit supports or have included cable tray supports in this review. The cable tray support documents including logs of deviations have always been maintained and controlled by DCC.
       '3).-      0C-01-01L              ;Is a ..los maintained indicating all outstanding      Procedure CP-El-4.0-22 is the procedure used Page 6 o6'8             design changes against BRPs?_                         by the Technical Services Mechanical Item 36-                                                                       Drafting (TSMD) for design and drawing Per procedure for sample reviewed.                    control. Specifically, Section 3.3 requires TSMD to maintain a log of outstanding design changes against drawings they issue. The TSMD group maintains this log. DCC maintains a similar log that does not specifically implement this procedure, but is used as their control of document changes and drawings. Item 36 implies that the logging system .or procedure CP-El-4.0-22 is unsatisfactory, but the comments sections does not not clarify any reasons. In fact, the comments state "per procedure for sample received." Texas Utilities feels that there is an inconsistency in Cygna's remarks, and

              , '               ' t ';
p-                                                                        ~
Paga'9                 .
TUGCO. REVIEW OFLCYGNA'S INDEPENDENT ASSESSMENT PROGRAM.
: l.                ..
                            ; Volume /Section'/'
Cygna Statement
!.            Item                      Page                                                                                             TUGC0 Comments                          i I                                                                                                                                                                                t
                                               '    1
                                                                                                                          'furthermore, we feel that the TSMD group correctly implements their procedure and             !
logging system.
: 31.          :DC-01              ' Change Distribution Matrix                                             Some of the observations by Cygna regarding
* AttachmentL7 the DCTG log are incorrect due to updating.
However, due to the periodic revising and-         .t
,4                                                                                                                          updating of the DCTG log specific comments
: s.         .
will not be provided in this report.                 ;
321 - DC-01-03                       .The Design' Change Tracking Group (DCTG) is                             Item I st;stes that DCTG is established to i-
                        - : Page 1-7 .                established to approve design changes,                                approve design changes is incarrect. The             ;
DCTG is solely an admiristrative group Item 1
                                                                                                                                                                                 ~
responsible to control the design change
* cycle. The appropriate engineering department (originating engineer) actually approves and reviews design changes.
:33.-           PS-01                    No check on stiffness was provided in the                             Stiffness is required to be checked for
                           -IDRL                   1 support. calculation.- See Note 2 on attachment                        pipe supports on Class 1 stress problems             i Page 3-4                  to this checklist..                                                   only. Cygna should provide a basis for
                           ; Item II                                                                                        their comments.
l              34.           PS                   Comments,1 through.4 regarding embedment                              See letter to the NRC, TXX-4134.
:Page 1-4                : lengths-for Hilti bolts.
Item 1
             '35.            PS-07                 :.The base plate'. input torsional load (Mx) should                      This is considerea an isolated error and             '
should be indicated as such in the comments.
                                                                                    ~
l Page 3-4                 be 52824-in-lb but.28848.in-1b was used in                                                                                 -
Item 10-                . design calculation. -Since this load only                                                                                ;
2 E

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Page 10                  ,.
i l
                                           'TUGC0 REVIEW OF'CYGNA'S INDEPENDENT ASSESSMENT PROGRAM l Volume /Section/
.   . Item          Page                              Cygna Statement                                 TUGC0 Comments i                               . induces shear in the anchor bolt, the .effect of this error is minor because a doubling of the
                                . bolt shear stress does not impact the bolt qualification.
    .36.   'PS-09                 Seismic movement not considered in the spring        . Seismic movement is not considered in spring
           'Page 2-4'            . design calculation.                                  design calculations because of its Item 6                                                                     negligible design impact.
37.. PS-10                See Item 28 above.                                    Itsn requires transmittal number or correct
           -Page 1-4                                                                    hanger drawing number.
Item I
: 38. PS               Bill of materials Item No. 6 is the base plate.       FUB II locates attachments with respect to Page 3-4.             It was analyzed using the Grinnell program.           the bolt holes not with respect to the plate Item 10              FUB II centers-the attachment on the plate. In    edges. This is illustrated by the FUB II
;                                 the actual design it is offset 1" towards bolts       Data Input Preparation Form. 3 and 4. This
                                .will not af fect- the design since the bolt allowable . interaction ratios are sufficiently low.
: 39. PS-30                 SA-193-87 rods were used to replace normal Hilti      SA-193-B7 rods were used. They were not Page.3-4              bolts, and are acceptable.                            " replacements" for Hilti bolts. By design, Item 10                                                                     thru-bolts of SA-193-87 material were used due to an anticipated high load.
40    .IDR-                  Editorial                                             6.0KV should read 6.9KV.
Checklist
;           EE-01 t           Page 11-13.-
i

fl p-                                                                                                                      'Paga 11 TUGC0 REVIEN OF CYGNA'S INDEPENDENT ASSESSMENT PROGRAM P                    .
                  - Volume /Section/ .
Item            Page                                Cygna Statement                                 TUGC0 Comments
:41.      IDR                     Defines requirement that valve 1-88118 be            See letter to the NRC, TXX-4134.
Checklist              --interlocked to prevent opening until pressure EE-02.(#1)            .to 425-psig.
: 42.      P1-02                   Editorial                                            1/2 SSE Spectra should read OBE.
Page 2-10 Item 5 T43    - WD-07'                   Editorial                                            C-020/11928 should read C-02011928
    ''            Page 4-6
:            'As-Built' l
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