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2121 N Cahfornia Blvd-. Suite 390. Walnut Creek, CA 94596                          415/934 5733 March 18,1987 84056.110 Mr. W. G. Counsil Executive Vice President Texas Utilities Electric Company Skyway Tower 400 North Oliver Street, L.B. 81 Dallas, TX 75201
 
==Subject:==
Questions for Upcoming March 24,25 Conduit Support Meeting Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 Job. No. 84056
 
==Dear Mr. Counsil:==
 
Enclosed is a preliminary set of questions to be addressed in the upcoming conduit support meeting based on Revision 0 to the Generic Issues Report.
If you have any questions or problems, please do not hesitate to call at your convenience.
Very truly yours,                          ,
            .gJg2 M l y Jessamyn Richards Administrative Assistant 3R:jst Enclosure cc:    Mr. L. Nace (TU Electric)
Mr. 3. Redding (TU Electric)
Mr. 3. Muffet (TU Electric)
                              ~
                                      ~
t Ms'.' AiViet'ti-C'ook (USNRC) #
Mrs. 3. Ellis (CASE)
Mr. C. Grimes (USNRC)
Mr. D. Pigott (Orrick, Herrington & Sutcliffe) 8703300104 870318                                              4 PDR A
ADOCK 05000445                                  .r f#          I PDR                        [.Fl l San Francisco Boston Chicago
 
l 3/20/87 TEXAS UTILITIES ELECTRIC COMPANY COMANCHE PEAK STEAM ELECTRIC STATION CABLE TRAY SUPPGtT DESIGN REVIEW CYGNA COMMENTS and QUESTIONS on EBASCO and TU ELECTRIC PROCEDURES and CRITERIA Responses to Conduit Support Review Issues List
: 1.      Governing Load Case for Design o            In Section 2.0 of the Evaluation and Resolution of Generic Technical Issues for Conduits and Conduit Support (GIR), the limit on stresses for the factored load condition is given as 0.9 Fy. For any structures with stresses above this limit, plastic analyses are to be performed.          In Section 3.0, the response states that, should any structures have stress levels beyond this limit, plastic analyses will be performed, and the criteria will be revised accordingly.
In Section 6.1 of the Unit 1 Design Criteria for Conduit Systems (SAG-CP-10) and Section 8.1 of the Unit 1 Design Criteria for Junction Boxes (SAG-CP-17), yield stresses are given as the upper bound for elastic analyses.
(a) Will the limits for elastic analyses be as stated in the GIR or in the design criteria?
(b )  If yield stress is to be used as the limiting stress, what is the basis for accepting Fy and Fcr as the limits for the factored load conditions?
(c) Please justify using the 0.9 Fy limit for compressive stresses.
(d) Please provide a design criteria to calculate allowables for single angles.
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o      Section 3.0 of the Guidelines for Calculations (CP-SG-03) presents allowable stresses for structural components. Allowables for lateral torsional buckling are not included. Please address this allowable and please discuss any allowables for cases where 0.9 Fy is exceeded.
(a) Has lateral torsional buckling been included in the development of the flexural allowables?
(b) Please address those allowables which exceed 0.9 Fy in light of the previous questions.
: 2. Dynamic Amplification Factors o        In EBASCO file SAG. TUG 1.329, " Technical Guidelines for System Analysis of Conduit Span Configurations", Rev. O, Section 2.1, a reference is made to Appendix 7 of the Design Criteria for conduit design "g" values. Cygna's copy of the GIR references a list of conduit "g" values in an Appendix 3. Is this the correct document?
If not, please provide Appendix 7.
How are the design "g" values in Appendix 3 derived? Do these include the 1.5 or 1.25 Dynamic Amplification Factor (DAF)? How do these design "g" values compare with those .used by Gibbs & Hill?
o        In DSAP VIII, Attachment 3, Section 2.1, Paragraph 6, it states that LLS-series (suspended lighting) conduit spans are longer than LS-series (suspended power and control) conduit spans. In Section 2.2, Paragraph 2, of SAG. TUG 1.329, it states that LLS-series conduit spans are shorter than LS-series conduit spans and are qualified by comparison. Please reconcile these two statements.
O      In Section 2.2, Paragraph 3(11), of SAG. TUG 1.329, Unit 2 experience is cited as the basis for removing consideration of span S5 from the analysis. Please provide the justification for this assumption.
l              o      In Section 2.2, Paragraph 4, of SAG. TUG 1.329,17 configurations are
!                      given in Attachment A. It appears that the DAF study chooses
!                      certain conduit sizes, span lengths, and number of spans. Please justify how these parameters envelop the Unit 1 population. Were
,                      the models tuned by varying support stiffnesses to maximize stress
!                      response and support load response?
l l
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      ;,        ;;;f;!i    Independent Assessment Program - All Phases Job No. 84056        TUG: 0651
 
In Section 4.0(vii) of SAG. TUG 1.329, a statement is made regarding adjustmant of support stiffnesses to avoid closely spaced modes.
What is the basis for these adjustments in light of the numerical idealizations in other aspects of this study?
o      In Section 3.0 of SAG. TUG 1.329, modal conbination by Complete Quadratic Combination (CQC) is specified as acceptable for usage.
Has this method been approved by the Final Safety Analysis Report (FS AR)?
o      In Section 4.0 of SAG. TUG 1.329, several guidelines are given for modeling of the conduit spans. The criteria given are not numerically specific to insure that response of a minimum frequency is captured. Was the actual required mass point spacing calculated and used in the analysis to capture a standard minimum frequency?
If so, what was that frequency?
o      In Section 4.0(i) of SAG. TUG 1.329, guidelines are given for modeling ,
of overhangs. How were cable air drops considered in the analysis?
o      In Section 4.0(viii) of SAG. TUG 1.329, guidelines are given to calculate spring constants for the support points. A lower bound frequency of 14.45 Hz is specified. Please justify this value. Was the minimum frequency of 14.45 Hz used in this calculation for all supports? What is the basis for assuming a fixed frequency value for all supports?
o      In Section 4.0(ix) of SAG. TUG 1.329, it states that conduit attached to a support junction box can be assumed to be a free end. Please provide assurance that this is a bounding assumption. Additionally, please provide a description of the method to determine the DAF for junction boxes and their attached conduits.
o      In Section 4.0(x) of SAG. TUG 1.329, it states that embedded conduits are assumed to be three-way hinges. What is the basis for this modeling assumption? How is it reconciled with the Cygna concerns regarding axial restraint of grouted penetrations? Is is realistic to omit moment restraint at the penetration, with respect to tuning of the analysis models?
o      In Section 5.2(111) of SAG. TUG 1.329, the " average" and " design" accelerations are compared neglecting the direction of application.
How can this be justified when the support design considers specific directions and their respective applied accelerations?
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Independent Assessment Program - All Phases Job No. 84056        TUG: 0651
 
1 1
If the comparison of the " average" and " design" accelerations fails, a square-root-sum-of-the-squares (SRSS) combination of the maximum and median accelerations is employed. What is the basis for this comparison?
What were the results of the work performed in this study?
o      In Section 3, Paragraph 2 of EBASCO Calculation Book No. 8, reference is made to six conduit groupings. What are those groupings? Please provide Calculation Book No.1.
o      In the last paragraph in Section 10.1, of the Unit 1 Design Criteria, a multi-mode amplification factor of less than 1.5 is allowed if justified by design verifying the conduit span allowables. Please justify how the applied DAF can be dependent on span allowables?
: 3. Combination of Deadweight and Seismic Responses No questions.
4    Measurement of Embedment from Top of Topping o    The Hilti Anchor Manual specifies a minimum embedment of 4-1/2 bolt diameters. Is this requirement considered when evaluating supports with anchors embedded through the topping?
: 5. Bolt Hole Tolerance and Edge Distance Violation A. Please discuss the applicability of the cable tray bolt hole review to the conduit support scope, since the cable tray designs did not specify a bolt hole tolerance.
B. See 5. A.
: 6. FSAR Load Combinations o    Paragraph 3 of Section 5.0 of Appendix 6 of the GIR states that displacements due to thermal accident loads less than 50% of the ultimate displacements for clamps and anchor bolts are acceptable.
Please define ultimate clamp and anchor bolt displacements. Please justify the 50% limit on displacements with respect to the other required FSAR loads.
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            ' ' jm" Independent Assessment Program - All Phases Job No. 84056                  TUG: 0651
 
o                    Cygna has the following questions on the Technical Guidelines for Thermal Analysis - Unit 1, SAG. TUG 1.427:
(a)                  In Section 3.2, a thermal expansion joint is discussed. Where is this joint documented in the 2323-S-0910 package? Was it used in Unit I?
(b)                  In Sections 3.4 and 3.5, a is given for normal and accident conditions. Cygna believes that the asient temperature used is 90*F. What is the basis for this a s ient temperature?
(c)                  In Appendix B, Figures 1 and 2 are missing from the copies provided to Cygna. Please provide these figures.
(d)                  In Section 2.0 of Appendix B, deviation of the applied load-deflection curve from the experimental data is discussed. What is the basis for adjusting the curves?
(e)                  In Section 2.0 of Appendix B, the modeling of nonlinear springs to resist expansion is discussed. How are restraints in the other two directions modeled in the typical case? How would they be modeled in a coupled case? What are the guidelines to decide whether the restraint directions are coupled?
(f) In Section 2.0 of Appendix B, surface-mounted conduits are mentioned. Are the supports for these conduits limited to CA-type supports (attached to walls, ceilings, etc.)?
(g)                  In Section 2.0 of Appendix B, Step 2 presents the method used to combine stiffness of the various components in a support.
Please define #s and #eq.
(h) Appendix C provides general instruction to perform thermal analysis of junction boxes. Please provide more detailed procedures.
: 7.          Support Self-Weight No questions.
Texas Utilities Electric Company                                                                                                                                    5 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 111lll111 1611111lllllll lll Job No. 84056                                                                    TUG: 0651
: 8. Torsion of Unistrut Menbers o        Conduit Support Tests (a)  Please provide a complete list of the generic and individually engineered Unistrut support designs being retained in Unit 1.
Do any of these contain P1001 C3 components?
(b) Of the retained Unistrut support designs, please provide documentation for the supports qualified by testing and by comparison to tested supports. Please provide documentation of the screening process performed to determine the worst case support configurations for the tests.
(c) Will American Iron and Steel Institute (AISI) requirements be used to qualify any supports not included in the test scope?
If so, which supports will be qualified in this manner? Will P1001C3 or similar unsymetric sections be used? Please provide the criteria and methodology to be used for AISI qualification.
(d) On page 25 of the conduit support test report, Configuration G13-T, Case 1, is shown. Was there a test configuration which placed the conduit directly over a Hilti anchor, which is allowed by the tolerances given in the design drawing? If not, please provide an evaluation that this is not a more critical configuration for the anchor bolt loads.
(e) On page 38 of the conduit support test report, results of the G1-T tests are discussed, including interactiori of the applied loads and their effect on the capacity of the support. Since the tested support capacity in one direction may be dependent on the simultaneous application of loads in another direction, how will these results be applied to general installation of the support where the load distribution is not the same as in the tests? Were single direction loads applied or a range of loads and load vector orientations used to obtain an enveloped capacity?
(f) On page 42 of the conduit support test report, a general discussion of results is presented. In the last paragraph on that page, the following statements are made:
The conduit slipped at loads significantly below the expected loads. The test program was not Texas Utilities Electric Company                                  6 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lilllilli 18111111111111lll Job No. 84056        TUG: 0651
 
established to investigate conduit and clamp interaction, so if the conduit slipped, it was blocked to prevent further movement and the test was continued.
How do the loads at conduit slippage from these tests compare with those of the conduit clamp tests? How is the data from the support tests used in the design verification effort? What are the minimum factors of safety for the supports?
: 9. Improper Use of Catalog Components A. Unistrut Allowables See Issue 8.
B. Unistrut/Superstrut Components See Issues 8 and 18.
: 10. Anchor Bolts A. Prying of Concrete Attachments o        Attachment G-4, Table 3, of the Conduit General Instructions (SAG. TUG 1.341) presents prying factors for 4-bolt baseplates.
The maximum prying factors for plates with Hilti bolts is
: 1. 3. The prying factors for plates with Richmond Inserts are as high as 2.16. Were prying factors developed for base plates with mixed Hilti bolts and Richnend Inserts? If so, please provide them.
o        Section 9.0 (page 10) of EBASCO Calculation Book No. 60 (Study on Conduit Support Anchorage) presents the conclusions of the study. Does the study apply only to those base plates using Hilti Kwik-bolts?    If so, are there similar studies for Richmond Inserts and mixed Hilti-Richmond Insert installations?
Prying factors are given for cases where different components of loads are applied to the plate. As more load components are added, the prying factor is reduced. Please provide calculation details which validate this result.
Texas Utilities Electric Company                                  7 Comanche Peak Steam Electric Station
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o      In Section 8.0, Paragraph 2, Item a., of EBASCO Calculation Book No. 8, what appropriate methods will be used to qualify the anchor bolts? In Table 5, prying is not explicitly included in the interaction formula. Will prying be appropriately considered?
B. CST-17 Anchorages See Issue 8.
C. Design of CA-2a Supports o    In Section 5.C. of Appendix 10 of the GIR, a discussion of the proximity violation between the Hilti Kwik-bolts on the header and the outriggers is provided. This discussion concludes that the maximum reduction is almost 4%. According to the requirements of the Hilti manual used in the original design, a minimum distance of 10d (or 3-1/8" between the 3/8" bolts on the header and the 1/4" bolts in the outriggers) must be maintained in order to use the full design values. If the bolts in question are separated by the 2-1/2" postulated in Section 5.C., the reduction in design values is 20%. Please justify the conclusion in the GIR.
In addition to the bolt proximity with the support, there is also concern that spacing violations between supports may also exist. In the Cygna walkdown effort, two pairs of supports (C12G05087-1/C12G05088-1 and C120505087-2/C12G05088-2) were closely spaced such that the outriggers of one support were located between those of another. The minimum spacing between the outrigger Hiltis was approximately 1-3/4". This results in a reduction of 30% of the design allowables for the outrigger Hiltis.
Please justify conclusions of Section 5.C in light of the 10d spacing requirements in the Hilti manual.
o    In the Guidelines for EESV (Engineering Evaluation of Separation Violation) and FPL (Footprint Loads) forms in CP-SG-03, cases 5 and 6 state that Hilti bolts for adjacent conduit supports should be acceptable without further review. Please provide the basis for these design rules.
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-                                                                                                              .  .                  1
                                                                                                                      -x    L      i o      In the instructions for the documentation of separation                              '
violations on EESV cards in CP-SG-03, Cas'e .I references TNE                    ,
procedure DBD-CS-15. 'What is this document?              ,
D.        Substitution of Anchor Bolts See Issue 12.                                                  .
2 E.        Anchorage Spring Rates o      In Section B.2) (page 2) of SAG.TUGI.341, a discusy5on of obtaining spring rates at snchorage points is' given.        Under what circumstances are springs modeled at anchorages?            Is there a criteria which specifies when springs are requirad?            r o      In the " Study on Conduit Support Anchorages", Ebasco calculation book 60 (Unit 2), the base plate stiffness is defined as the applied moment divided by the summation of the average rotations at various points along the attachment perimeter. Please define average rotation and describe which points the rotations are succed over, o            In Section 2.0, page 2-1, 'of' CP-SG-03, a discussion of the calculation support frequencies and their acceptability-is presented. In paragraph B.1), a rigid base plate assumption is                                    -
first used. This will tend to overestirrate the support frequfncy 3f the base plate is flexible. Please justify this assunction.
                                                                                                        '?
o            In Table 2 of CP-SG-03, for Type 2, configuration 2.'), a rdational stiffness is given for a rectangular plate.          Does this stiffness apply to all directions of rotation?          s F.        Torque Testing of Existing Installations o      Section 4.1.7 of ISAP VII.b.4 proposes torgdtesting of existing bolts to verify' adequacy of the bolt-installations.
Were bolt projections a,lso checked?                -                    ,
: 11.          Longitudinal Loads on Transverse Supports                          ,
o            In Section 5.0 of Appedix 11 of the GIR, the clamps used on transverse supports are discussed as having possible irregular gaps between the clamp and the 1:onduit. Have the clamp with gap as described in Section 5.0 been included in the testing program?                        .
Texas Utilities Electric Company                                          9 Comanche Peak Steam Electric Station k      bJ' A                        Independent Assessment Program ~ All Phases 18641ll1lllll11lllll1ll11lll!!
Job No. 84056        TUG: 0651
 
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: 12.        Hilti_ Kwik-bolt Substitution o      Section 2.0 of Appendix 12 of the GIR states t'nat c generic study will be performed to address bolt substitutica for genaric support desi gns. What are the study's conclusions relative to bolt capacity
              ?                                  reductions?                                              -
o    Section 3.0 of Appendip 12 of the GIR also states that a review of 4                    -      -                      the Unit 2 installatiori will be done to determine the frequency of such substituticns. Is the Unit 2 data caplicab'le to Unit I?
                                            - es                                                  l
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        '                        13. Substitutior of Smaller Conduits on CA-Type Supports '
o      Section 2.0 of Appendix 13 of the GIR discusses the one-to-one sJbstitution of small conduits for large condsits. Unless the drLwings specifically preclude the mass substitution, general note I.4 on Sheet G-la of the S-0910 package states:
Capacities.. are given both in weight (lbs.) and in conduit nurber and sizes. Capacity of'a support is limited to one of the groups of number and size of conduits shown in the corresponding table. However, any nunber and size of conduits may be grouped provided the total capacity in lbs. does not exceed that given in the corresponding
:                                                      ,  tatele. If weight capacTty table is used, then capacity of hangers shall be verified in the.. field. LS and LA series drawings show how to determine conduit loads on each support, based on tributary spans.
                  */
Far Cycre' Review Issue 13, a substitution such as this may be done
                                                                  ~
with sup,' ort CA-15. Has this note been considered in conjunction
                                .                with the 90neric support drawing sheets?
e            1            ,
                                                    ~
                                          .o      Section 3.0 of Appendix 13 of the GIR discusses support frequencies in the 12 to'15 H ran ge.        How do these lower frequency supports
            ~
affect the DAF study, which assumes a minimum frequency of 14.45 Hz?
            -                    14      'dse of CA-Type Supports in LS Spans o'    Section 3.0 of Appendix 14 of the.GIR discusses dynamic analyses performed for generic conduit runs to address the dynamic load distribution between CA-type (attaching conduits to walls, ceilings, etc.) and CSH-type (suspending conduits in space) supports. Section Texas Utilities Electric Company                                  10 Comanche Pbk Steam Electric Station L        I. J L A            Independent Assessment Program - All Phases
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s 5.0 states that the overload of a CA-type support is acceptable if. 's j            the sum of the two LA spans on either side are less than or equal to. T g(-
an LS span, since LS spans have been qualified. Does the generic study address the scenario of a failed CA-type support? Does it f
consider redistribution of dynamic loads to the adjacent CA- and CSM-type supports?
o        Section 5.0 of Appendix 14 of the GIR states that CA supports 1                                      adjacent to CSM/ CHM supports have been identified in a pre-walkdown. Was the pre-walkdown a documentation review or a physical
                                      . observation of the plant condition.
o        It is Cygna's understanding that the results of the pre-walkdown identified 1775 support configurations. Is this correct?                      s o        Section 5.0 of Appendix 14,0f the GIR states that the conduit runs with CA supports adjacent to CSM/ CHM supports will be evaluated using response spectrum analyses. Please provide the procedures for the dynamic analyses.
4
    +                              s Cygna understands that the :1775 occurences will first be reviewed to determine if they are adequate with respect-to the current deisgn allowables. Those which do not pass this review are to be modified          s or analyzed using response spectrum analysis. Is this correct?.
s-The results of the dynamic analyses will be incorporated into the LA series drawings. In what form will the results be incorporated into the LA series drawings?                          '
s
: 15. Stresses in Cable Trays Due to Attached Conduit Supports l                            o        What parameters will be included in the test program? How will the test results be considered in the qualf,fication? Who will perform the qualification?
                                                                                  ~
si l
l                      16. Increases in Allowable Span Lengths                    (                        w
!                            See Review Issue 2 for span configuration in the EAF study.
17    Substitution of Next Heavier Structural Member                                      T No Questions.
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: 18. Clamp Usage A.      Reaming of Bolt Holes I
o    On page 4 of the Phase I Test Report, item 5 discusses an erection tolerance for the clamps. Cygna has reviewed procedure ECP-19 and has not identified this tolerance. What are the tolerances and were they specified in the original installation documentation?
o    On page 11 of the Phase I Test Report, Table 5.1 provides capacity data for three different sizes of clamps for three different bolt sizes. Some of the clamps show a decrease in capacity when the bolt size is increased. Will a lower bound be used or will a check of actual installed bolt type be performed? How will these results be extended to other clamp sizes and types?
B.      C-708-S Clamps o    How were the clamp types determined in the walkdown effort?
How were C-708-S clamps distinguished from P-2558 and C-708-U clamps?
C.      Clamp Distortion o    How was this considered in the test program?
D.      Clamp Tests o    On page 17, Section 7, of the Phase I Test Report, load categories are discussed. Do each of the three load categories described correspond to one of the three loading directions for the clamp? It appears that Category 1 refers to axial conduit loads, Category 2 refers to " vertical" conduit loads, and Category 3 refers to lateral conduit loads. Is this correct?
o    On pages 17 and 18 of the Phase I Test Report, the methodology l
for determining the cyclic test loads is described. What is the basis for the factor of safety chosen for each of the three Texas Utilities Electric Company                                  12 Comanche Peak Steam Electric Station
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                      . . ,,{    Independent Assessment Program - All Phases on......  ...........m Job No. 84056        TUG: 0651
 
categories? Why is a factor of safety of 3 used for Category 1 and a factor of safety of 4 used for the other two categories?
o  On page 18 of the Phase I Test Report, the method of calculating the minimum number of required cycles is presented. This method is based on the assumption that the clamps respond to the maximum support / conduit frequency at the peak of the response spectrum, 13.23 Hz. Is it feasible that lower design loads applied over a greater nunber of cycles could be more critical than the tested cases?
o  On page 19, Table 7.1 of the Phase I Test Report, maximum applied test loads are calculated. How do these values compare with the design loads?
o  On page 11 and 12 of the Phase II Test Report, Section 3.3 describes changes in the test scope due to information regarding existing configurations at the site. Are all clamp installations at CPSES covered by the test? For the new P2558 clamps with revised spacing, what is the basis for performing only one cyclic test and no static tests? It appears that these clamps were distorted in the test configuration. Is this representative of all plant applications of this clamp?
o  On page 45 of the Phase II Test Report, Section 7 discusses the allowables derived from the results of the cyclic load tests.
It states that the allowables are for the simultaneous application of three mutually orthogonal loads. However, it also states, No interaction equation is given nor implied as testing performed is insufficient to develop a reliable, three-directional, interaction formula.
Each calculated load must be lower than the allowable given in the attached tables before any clamp may be approved.
Although no interaction is intended by the allowables, there is an implicit interaction suggested by the tests. Were the tests adequate to ensure that all three loads can be maximized in the design and still be adequate? Is there a factor of safety on these allowables? Please discuss in detail how the final allowable loads were determined, including adjustments made to relative load magnitude between the three loading directions.
Texas Utilities Electric Company                                13 Comanche Peak Steam Electric Station b,, ,,,,,b      A-  Independent Assessment Program - All Phases J b,,,UUUI Job No. 84056        TUG: 0651
: 19. Documentation Deviations Between Inspection Reports, CMCs and IN-FP Drawings A. Errors on Inspection Reports
: 1. In item 1 of Section 5.0 of Appendix 19 of the GIR, the Inspection Report (IR) error for support C11003395-1 is classified as an " isolated inconsistency" and not a
                                                        " discrepancy". What are the definitions of " isolated inconsistency" and " discrepancy"? Please discuss how this item was classified and how it will be used in root cause evaluations?
Since the irs are to be used to define a population from which a sample will be chosen, the accuracy of the irs is important for this task. How are possible " inconsistencies" in the irs considered in the sampling task? How are Component Modification Cards (CMCs) considered in the sampling task?
: 2. Cygna identified five occurrences in the review scope (7% of the supports) where the drawing references listed on the CMCs differed from the drawing revision listed on the inspection report. The implementation addresses only one such occurrence and classifies it as random. Please discuss how the support adequacy can be ensured by the fact that the final inspection and CMCs were written against different drawing revisions.
: 3. Will the conduit support tests determine if there is any functional or capacity difference between CA-la supports without anchor bolts in the outriggers and CA-2a supports with anchor bolts in the outriggers? How will the Cygna concern regarding accuracy of the irs with respect to CA-la and CA-2a supports be considered in the QA/QC root cause evaluation?
: 4. Of all the items discussed in this section, Cygna considers missing CMCs on the irs to be the most significant. If sampling activities are to be performed using the irs, their accuracy is important. If the occurrence of missing CMCs proves not to be random, please discuss its impact on the i                                                        sampling and review efforts using the IRS. How will all concerns in Item A.4 be considered in the QA/QC root cause evaluation?
Texas Utilities Electric Company                                                    14 Comanche Peak Steam Electric Station JL A          Independent Assessment Program - All Phases 1111ll111111111111111ll1111lll Job No. 84056                        TUG: 0651
 
B.        Installed Deviations With Inspection Reports
: 1. IRME-16236F was not updated after line C12002935 was rerouted. Was this line inspected?            If so, what was the date of the inspection?
: 2. Is there a typographical error which calls out IRME-14604F?
Cygna is in possession of a copy of IRME-14684F which does not list either CSM-15b or IN-CSM-15b. In that copy, only IN-CSM-15a is listed. Please provide Cygna with the documentation supporting closure of this issue.
: 3. The last sentence on page A19.4 of Appendix 19 of the GIR states that all IRMEs that Cygna has found errors in will be updated to agree with all the latest documentation. Since the IRMEs are intended to be used as the means to insure that the conduit and supports were installed as designed and not merely to document the presence of certain supports, how will the implementation of the resolution address possible deficiencies in the inspection process?
: 4. Page A19.5 of Appendix 19 of the GIR also discusses a walkdown, sampling, and verification effort for conduit runs and supports. How was support type determined? What are the results of the walkdowns? Has the comparative review been completed? If so, what are the conclusions?
: 20.          Nelson Studs o            No questions.
: 21. Conduit Fire Protection Calculations A.        Thermolag Configuration 16 questions.
B.        CA-la Capacities i
o    Were the CA-la capacities revised?          If so, in what way were the designs impacted?
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                                                                                                        )
i C.      CA-2a Capacities o      In what way were the designs impacted due to the revised loads?
D.      IN-FP (Fire Protection) Calculations Section 5.0 of Appendix 21 of the GIR discusses walkdown o
verification of IN-FP drawings. How was this accomplished given the presence of Thermolag?
: 22. Span Increase for Fire Protected Spans o        Please provide Cygna a copy of the conduit material yield stress test report in SDAR (Significant Deficiency Analysis Report) CP                            19.
o          In Section 3.0 of Appendix 22 of the GIR, a Dynamic Amplification Factor (DAF) is mentioned in relation to the RSM analyses. Please explain how the analyses are performed, how the supports are evaluated, and the significance of the DAF.
: 23. Grouted Penetrations o          Section 5.0 of Appendix 23 of the GIR states that loads on grouted penetrations will be calculated using both " fixed" and " hinged" boundaries. Please justify the assumptions for the two boundary conditions with respect to the actual installation, o          Section 5.0 of Appendix 23 of the GIR discusses the intended approach to determine the bond strength of grouted penetrations.
What is the status of the literature search?          If tests are to be performed, please describe the tests methods and the parameters to be considered.
24  Rigidity of CA-Type Supports o          Section 5.0 of Appendix 24 of the GIR states that tests were used to verify the rigidity of CA-type Unistrut supports. Were the test configurations and load applications selected to provide lower bound stiffnesses? Which support types are covered by the test results?
o          Which structural steel support types were determined to have frequencies below 33 Hz? Were these results considered in other generic studies involving CA-type supports?
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o            Section 5.0 of Appendix 24 of the GIR states that the design verification of non-rigid CA-type supports was performed using "g" values from RSM analyses of LS spans. Please elaborate on this statement.                                                                                            {
: 25. Enveloping Configurations for Design o          Section 3.0 of Appendix 25 of the GIR states that verification of the Unit I supports will rely on CMCs and IN-drawings (i.e., for individually-engineered supports), as they are expected to reflect the actual installed support condition.                  Please substantiate this assumption with respect to the installation documentation errors discussed in Review Issue 19.
o          The 2323-S-0910 package has several sheets of general notes which are applicable to all generic support designs.                    How were these general notes and other allowances included in the EBASCO design verification? How were the generic supports evaluated such that all revisions of the drawings and general notes are enveloped by the design verification?
I o            In Section II.A) (page 6) of SAG. TUG 1.341, a discussion of loading of the support ~ to maximize support member stresses is given. What assurances were made to maximize forces and stresses in other components as well?
o            How are working point eccentricities considered?
o          The adequacy of the conduit attachments referenced in Paragraph 4 of Section 3 of EBASCO Calculation Book No. 8 has been verified in Calculation Book No. 44 Was analysis or comparison with test results used in the verification?
o            In Section 4.5.1, of EBASCO Calculation Book No. 8, the BEAMS element is to be used for the modeling of various support members, which include angles and channels. Does this element account for the shear center offset of these types of members? If not, how will torsional effects be considered?
Texas Utilities Electric Company                                                            17 Comanche Peak Steam Electric Station L                k A              Independent Assessment Program - All Phases 184ll11lll1111lll11llllll11lll Job No. 84056                          TUG: 0651
 
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.        26. Design Drawing Discrepancies o    How will the resolution ensure that the supports installed using current and previous revisions of drawings with missing information are adequate?
: 27. Walkdown Discrepancies o    Please discuss any differences in the Unit I walkdown procedures with respect to those provided for Unit 2. Please discuss the walkdown tolerances with respect to the construction tolerances.
'                  Are documentation discrepancies also addressed in this walkdown (see i
Review Issue 19)?
Are the comparisons of the as-built systems and the 2323-S-0910 requirements available? If so, please provide them. Do the comparisons consider the revisions to which the supports were inspected?
Section 3.0 of Appendix 27 of the GIR discusses a possible root I                  cause for'the listed discrepancies. What is the basis for this conclusion?
o    How will inaccessible attributes be handled in the as-built
:                  process?      If a portion of a conduit system is inaccessible, will the l                  attributes be assumed or will another run be selected for the sample?      If the former choice is selected, what criteria will be used in      assuming the attributes? If the latter choice is selected, how much of the first run must be inaccessible before another run is i
selected? If the latter choice is selected, would the fire-protected runs be excluded from the random sampling process?                                                                        If so, how are the fire-protected runs considered?
!              o    Cygna has the following questions on walkdcwn procedure TNE-FVM-CS-016 Revision 1:
(a) How are welds considered? Is the Visual Weld Acceptance Criteria (VWAC) used? How are any partial penetration welds
!                          considered?
I (b)      In Section 3.2.B.2 why are the fittings limited to the sizes indicated?
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1                      Texas Utilities Electric Company                                                                                                    18 i                      Comanche Peak Steam Electric Station i          b  L A      Independent Assessment Program - All Phases MNNNmWNmNHmm                              TUG: 0651 Job No. 84056 4
 
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r (c)    In Section 3.2.B.3 why isn't the shortest cable slack noted?
(d) Are the general conditions of the support installation noted
,                                                  (e.g., properly seated nuts, plumbness, etc.)?
(e)  In Section 3.2.B.4.b why is only the thickness recorded for single conduit supports?
(f) How are anchorage spacing violations considered? How are connections to embedded plates considered?
: 28. Systems Concept o    Section 5.0 of Appendix 28 of the GIR discusses the concept of shared moments between conduit supports. What is the basis for this assumed behavior? How has the moment transfer between the conduits and supports through the clamps been addressed? What system models are used for this verification effort?                                        Have variations of span lengths and configurations been considered? How were they chosen to envelop the total population?
: 29. Cumulative Effort of Review Issues To be discussed later.
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Texas Utilities Electric Company                                                                19          j Comanche Peak Steam Electric Station k            b            k A      Independent Assessment Program - All Phases 111lll11lllll14lll111lll1lll11 Job No. 84056            TUG: 0651
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Latest revision as of 05:18, 30 December 2020

Forwards Comments & Questions on Ebasco & Util Procedures & Criteria Re Responses to Conduit Support Review Issues List for Upcoming 870324 & 25 Conduit Support Meetings Per Rev 0 to Generic Issues Rept
ML20205C074
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/18/1987
From: Richards J
CYGNA ENERGY SERVICES
To: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
84056.110, NUDOCS 8703300104
Download: ML20205C074 (21)


Text

  • y*G; -- -

2121 N Cahfornia Blvd-. Suite 390. Walnut Creek, CA 94596 415/934 5733 March 18,1987 84056.110 Mr. W. G. Counsil Executive Vice President Texas Utilities Electric Company Skyway Tower 400 North Oliver Street, L.B. 81 Dallas, TX 75201

Subject:

Questions for Upcoming March 24,25 Conduit Support Meeting Comanche Peak Steam Electric Station Independent Assessment Program - Phase 4 Job. No. 84056

Dear Mr. Counsil:

Enclosed is a preliminary set of questions to be addressed in the upcoming conduit support meeting based on Revision 0 to the Generic Issues Report.

If you have any questions or problems, please do not hesitate to call at your convenience.

Very truly yours, ,

.gJg2 M l y Jessamyn Richards Administrative Assistant 3R:jst Enclosure cc: Mr. L. Nace (TU Electric)

Mr. 3. Redding (TU Electric)

Mr. 3. Muffet (TU Electric)

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t Ms'.' AiViet'ti-C'ook (USNRC) #

Mrs. 3. Ellis (CASE)

Mr. C. Grimes (USNRC)

Mr. D. Pigott (Orrick, Herrington & Sutcliffe) 8703300104 870318 4 PDR A

ADOCK 05000445 .r f# I PDR [.Fl l San Francisco Boston Chicago

l 3/20/87 TEXAS UTILITIES ELECTRIC COMPANY COMANCHE PEAK STEAM ELECTRIC STATION CABLE TRAY SUPPGtT DESIGN REVIEW CYGNA COMMENTS and QUESTIONS on EBASCO and TU ELECTRIC PROCEDURES and CRITERIA Responses to Conduit Support Review Issues List

1. Governing Load Case for Design o In Section 2.0 of the Evaluation and Resolution of Generic Technical Issues for Conduits and Conduit Support (GIR), the limit on stresses for the factored load condition is given as 0.9 Fy. For any structures with stresses above this limit, plastic analyses are to be performed. In Section 3.0, the response states that, should any structures have stress levels beyond this limit, plastic analyses will be performed, and the criteria will be revised accordingly.

In Section 6.1 of the Unit 1 Design Criteria for Conduit Systems (SAG-CP-10) and Section 8.1 of the Unit 1 Design Criteria for Junction Boxes (SAG-CP-17), yield stresses are given as the upper bound for elastic analyses.

(a) Will the limits for elastic analyses be as stated in the GIR or in the design criteria?

(b ) If yield stress is to be used as the limiting stress, what is the basis for accepting Fy and Fcr as the limits for the factored load conditions?

(c) Please justify using the 0.9 Fy limit for compressive stresses.

(d) Please provide a design criteria to calculate allowables for single angles.

Texas Utilities Electric Company 1 Ag ,

Comanche Peak Steam Electric Station lilllllillllilillllllililillil Independent Assessment Program - All Phases Job No. 84056 TUG: 0651

o Section 3.0 of the Guidelines for Calculations (CP-SG-03) presents allowable stresses for structural components. Allowables for lateral torsional buckling are not included. Please address this allowable and please discuss any allowables for cases where 0.9 Fy is exceeded.

(a) Has lateral torsional buckling been included in the development of the flexural allowables?

(b) Please address those allowables which exceed 0.9 Fy in light of the previous questions.

2. Dynamic Amplification Factors o In EBASCO file SAG. TUG 1.329, " Technical Guidelines for System Analysis of Conduit Span Configurations", Rev. O, Section 2.1, a reference is made to Appendix 7 of the Design Criteria for conduit design "g" values. Cygna's copy of the GIR references a list of conduit "g" values in an Appendix 3. Is this the correct document?

If not, please provide Appendix 7.

How are the design "g" values in Appendix 3 derived? Do these include the 1.5 or 1.25 Dynamic Amplification Factor (DAF)? How do these design "g" values compare with those .used by Gibbs & Hill?

o In DSAP VIII, Attachment 3, Section 2.1, Paragraph 6, it states that LLS-series (suspended lighting) conduit spans are longer than LS-series (suspended power and control) conduit spans. In Section 2.2, Paragraph 2, of SAG. TUG 1.329, it states that LLS-series conduit spans are shorter than LS-series conduit spans and are qualified by comparison. Please reconcile these two statements.

O In Section 2.2, Paragraph 3(11), of SAG. TUG 1.329, Unit 2 experience is cited as the basis for removing consideration of span S5 from the analysis. Please provide the justification for this assumption.

l o In Section 2.2, Paragraph 4, of SAG. TUG 1.329,17 configurations are

! given in Attachment A. It appears that the DAF study chooses

! certain conduit sizes, span lengths, and number of spans. Please justify how these parameters envelop the Unit 1 population. Were

, the models tuned by varying support stiffnesses to maximize stress

! response and support load response?

l l

Texas Utilities Electric Company 2

. Comanche Peak Steam Electric Station j h;4

,  ;;;f;!i Independent Assessment Program - All Phases Job No. 84056 TUG
0651

In Section 4.0(vii) of SAG. TUG 1.329, a statement is made regarding adjustmant of support stiffnesses to avoid closely spaced modes.

What is the basis for these adjustments in light of the numerical idealizations in other aspects of this study?

o In Section 3.0 of SAG. TUG 1.329, modal conbination by Complete Quadratic Combination (CQC) is specified as acceptable for usage.

Has this method been approved by the Final Safety Analysis Report (FS AR)?

o In Section 4.0 of SAG. TUG 1.329, several guidelines are given for modeling of the conduit spans. The criteria given are not numerically specific to insure that response of a minimum frequency is captured. Was the actual required mass point spacing calculated and used in the analysis to capture a standard minimum frequency?

If so, what was that frequency?

o In Section 4.0(i) of SAG. TUG 1.329, guidelines are given for modeling ,

of overhangs. How were cable air drops considered in the analysis?

o In Section 4.0(viii) of SAG. TUG 1.329, guidelines are given to calculate spring constants for the support points. A lower bound frequency of 14.45 Hz is specified. Please justify this value. Was the minimum frequency of 14.45 Hz used in this calculation for all supports? What is the basis for assuming a fixed frequency value for all supports?

o In Section 4.0(ix) of SAG. TUG 1.329, it states that conduit attached to a support junction box can be assumed to be a free end. Please provide assurance that this is a bounding assumption. Additionally, please provide a description of the method to determine the DAF for junction boxes and their attached conduits.

o In Section 4.0(x) of SAG. TUG 1.329, it states that embedded conduits are assumed to be three-way hinges. What is the basis for this modeling assumption? How is it reconciled with the Cygna concerns regarding axial restraint of grouted penetrations? Is is realistic to omit moment restraint at the penetration, with respect to tuning of the analysis models?

o In Section 5.2(111) of SAG. TUG 1.329, the " average" and " design" accelerations are compared neglecting the direction of application.

How can this be justified when the support design considers specific directions and their respective applied accelerations?

Texas Utilities Electric Company 3 Comanche Peak Steam Electric Station b..... pY.1.

Independent Assessment Program - All Phases Job No. 84056 TUG: 0651

1 1

If the comparison of the " average" and " design" accelerations fails, a square-root-sum-of-the-squares (SRSS) combination of the maximum and median accelerations is employed. What is the basis for this comparison?

What were the results of the work performed in this study?

o In Section 3, Paragraph 2 of EBASCO Calculation Book No. 8, reference is made to six conduit groupings. What are those groupings? Please provide Calculation Book No.1.

o In the last paragraph in Section 10.1, of the Unit 1 Design Criteria, a multi-mode amplification factor of less than 1.5 is allowed if justified by design verifying the conduit span allowables. Please justify how the applied DAF can be dependent on span allowables?

3. Combination of Deadweight and Seismic Responses No questions.

4 Measurement of Embedment from Top of Topping o The Hilti Anchor Manual specifies a minimum embedment of 4-1/2 bolt diameters. Is this requirement considered when evaluating supports with anchors embedded through the topping?

5. Bolt Hole Tolerance and Edge Distance Violation A. Please discuss the applicability of the cable tray bolt hole review to the conduit support scope, since the cable tray designs did not specify a bolt hole tolerance.

B. See 5. A.

6. FSAR Load Combinations o Paragraph 3 of Section 5.0 of Appendix 6 of the GIR states that displacements due to thermal accident loads less than 50% of the ultimate displacements for clamps and anchor bolts are acceptable.

Please define ultimate clamp and anchor bolt displacements. Please justify the 50% limit on displacements with respect to the other required FSAR loads.

Texas Utilities Electric Company 4 Comanche Peak Steam Electric Station h.

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' ' jm" Independent Assessment Program - All Phases Job No. 84056 TUG: 0651

o Cygna has the following questions on the Technical Guidelines for Thermal Analysis - Unit 1, SAG. TUG 1.427:

(a) In Section 3.2, a thermal expansion joint is discussed. Where is this joint documented in the 2323-S-0910 package? Was it used in Unit I?

(b) In Sections 3.4 and 3.5, a is given for normal and accident conditions. Cygna believes that the asient temperature used is 90*F. What is the basis for this a s ient temperature?

(c) In Appendix B, Figures 1 and 2 are missing from the copies provided to Cygna. Please provide these figures.

(d) In Section 2.0 of Appendix B, deviation of the applied load-deflection curve from the experimental data is discussed. What is the basis for adjusting the curves?

(e) In Section 2.0 of Appendix B, the modeling of nonlinear springs to resist expansion is discussed. How are restraints in the other two directions modeled in the typical case? How would they be modeled in a coupled case? What are the guidelines to decide whether the restraint directions are coupled?

(f) In Section 2.0 of Appendix B, surface-mounted conduits are mentioned. Are the supports for these conduits limited to CA-type supports (attached to walls, ceilings, etc.)?

(g) In Section 2.0 of Appendix B, Step 2 presents the method used to combine stiffness of the various components in a support.

Please define #s and #eq.

(h) Appendix C provides general instruction to perform thermal analysis of junction boxes. Please provide more detailed procedures.

7. Support Self-Weight No questions.

Texas Utilities Electric Company 5 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 111lll111 1611111lllllll lll Job No. 84056 TUG: 0651

8. Torsion of Unistrut Menbers o Conduit Support Tests (a) Please provide a complete list of the generic and individually engineered Unistrut support designs being retained in Unit 1.

Do any of these contain P1001 C3 components?

(b) Of the retained Unistrut support designs, please provide documentation for the supports qualified by testing and by comparison to tested supports. Please provide documentation of the screening process performed to determine the worst case support configurations for the tests.

(c) Will American Iron and Steel Institute (AISI) requirements be used to qualify any supports not included in the test scope?

If so, which supports will be qualified in this manner? Will P1001C3 or similar unsymetric sections be used? Please provide the criteria and methodology to be used for AISI qualification.

(d) On page 25 of the conduit support test report, Configuration G13-T, Case 1, is shown. Was there a test configuration which placed the conduit directly over a Hilti anchor, which is allowed by the tolerances given in the design drawing? If not, please provide an evaluation that this is not a more critical configuration for the anchor bolt loads.

(e) On page 38 of the conduit support test report, results of the G1-T tests are discussed, including interactiori of the applied loads and their effect on the capacity of the support. Since the tested support capacity in one direction may be dependent on the simultaneous application of loads in another direction, how will these results be applied to general installation of the support where the load distribution is not the same as in the tests? Were single direction loads applied or a range of loads and load vector orientations used to obtain an enveloped capacity?

(f) On page 42 of the conduit support test report, a general discussion of results is presented. In the last paragraph on that page, the following statements are made:

The conduit slipped at loads significantly below the expected loads. The test program was not Texas Utilities Electric Company 6 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lilllilli 18111111111111lll Job No. 84056 TUG: 0651

established to investigate conduit and clamp interaction, so if the conduit slipped, it was blocked to prevent further movement and the test was continued.

How do the loads at conduit slippage from these tests compare with those of the conduit clamp tests? How is the data from the support tests used in the design verification effort? What are the minimum factors of safety for the supports?

9. Improper Use of Catalog Components A. Unistrut Allowables See Issue 8.

B. Unistrut/Superstrut Components See Issues 8 and 18.

10. Anchor Bolts A. Prying of Concrete Attachments o Attachment G-4, Table 3, of the Conduit General Instructions (SAG. TUG 1.341) presents prying factors for 4-bolt baseplates.

The maximum prying factors for plates with Hilti bolts is

1. 3. The prying factors for plates with Richmond Inserts are as high as 2.16. Were prying factors developed for base plates with mixed Hilti bolts and Richnend Inserts? If so, please provide them.

o Section 9.0 (page 10) of EBASCO Calculation Book No. 60 (Study on Conduit Support Anchorage) presents the conclusions of the study. Does the study apply only to those base plates using Hilti Kwik-bolts? If so, are there similar studies for Richmond Inserts and mixed Hilti-Richmond Insert installations?

Prying factors are given for cases where different components of loads are applied to the plate. As more load components are added, the prying factor is reduced. Please provide calculation details which validate this result.

Texas Utilities Electric Company 7 Comanche Peak Steam Electric Station

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o In Section 8.0, Paragraph 2, Item a., of EBASCO Calculation Book No. 8, what appropriate methods will be used to qualify the anchor bolts? In Table 5, prying is not explicitly included in the interaction formula. Will prying be appropriately considered?

B. CST-17 Anchorages See Issue 8.

C. Design of CA-2a Supports o In Section 5.C. of Appendix 10 of the GIR, a discussion of the proximity violation between the Hilti Kwik-bolts on the header and the outriggers is provided. This discussion concludes that the maximum reduction is almost 4%. According to the requirements of the Hilti manual used in the original design, a minimum distance of 10d (or 3-1/8" between the 3/8" bolts on the header and the 1/4" bolts in the outriggers) must be maintained in order to use the full design values. If the bolts in question are separated by the 2-1/2" postulated in Section 5.C., the reduction in design values is 20%. Please justify the conclusion in the GIR.

In addition to the bolt proximity with the support, there is also concern that spacing violations between supports may also exist. In the Cygna walkdown effort, two pairs of supports (C12G05087-1/C12G05088-1 and C120505087-2/C12G05088-2) were closely spaced such that the outriggers of one support were located between those of another. The minimum spacing between the outrigger Hiltis was approximately 1-3/4". This results in a reduction of 30% of the design allowables for the outrigger Hiltis.

Please justify conclusions of Section 5.C in light of the 10d spacing requirements in the Hilti manual.

o In the Guidelines for EESV (Engineering Evaluation of Separation Violation) and FPL (Footprint Loads) forms in CP-SG-03, cases 5 and 6 state that Hilti bolts for adjacent conduit supports should be acceptable without further review. Please provide the basis for these design rules.

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-x L i o In the instructions for the documentation of separation '

violations on EESV cards in CP-SG-03, Cas'e .I references TNE ,

procedure DBD-CS-15. 'What is this document? ,

D. Substitution of Anchor Bolts See Issue 12. .

2 E. Anchorage Spring Rates o In Section B.2) (page 2) of SAG.TUGI.341, a discusy5on of obtaining spring rates at snchorage points is' given. Under what circumstances are springs modeled at anchorages? Is there a criteria which specifies when springs are requirad? r o In the " Study on Conduit Support Anchorages", Ebasco calculation book 60 (Unit 2), the base plate stiffness is defined as the applied moment divided by the summation of the average rotations at various points along the attachment perimeter. Please define average rotation and describe which points the rotations are succed over, o In Section 2.0, page 2-1, 'of' CP-SG-03, a discussion of the calculation support frequencies and their acceptability-is presented. In paragraph B.1), a rigid base plate assumption is -

first used. This will tend to overestirrate the support frequfncy 3f the base plate is flexible. Please justify this assunction.

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o In Table 2 of CP-SG-03, for Type 2, configuration 2.'), a rdational stiffness is given for a rectangular plate. Does this stiffness apply to all directions of rotation? s F. Torque Testing of Existing Installations o Section 4.1.7 of ISAP VII.b.4 proposes torgdtesting of existing bolts to verify' adequacy of the bolt-installations.

Were bolt projections a,lso checked? - ,

11. Longitudinal Loads on Transverse Supports ,

o In Section 5.0 of Appedix 11 of the GIR, the clamps used on transverse supports are discussed as having possible irregular gaps between the clamp and the 1:onduit. Have the clamp with gap as described in Section 5.0 been included in the testing program? .

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12. Hilti_ Kwik-bolt Substitution o Section 2.0 of Appendix 12 of the GIR states t'nat c generic study will be performed to address bolt substitutica for genaric support desi gns. What are the study's conclusions relative to bolt capacity

? reductions? -

o Section 3.0 of Appendip 12 of the GIR also states that a review of 4 - - the Unit 2 installatiori will be done to determine the frequency of such substituticns. Is the Unit 2 data caplicab'le to Unit I?

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' 13. Substitutior of Smaller Conduits on CA-Type Supports '

o Section 2.0 of Appendix 13 of the GIR discusses the one-to-one sJbstitution of small conduits for large condsits. Unless the drLwings specifically preclude the mass substitution, general note I.4 on Sheet G-la of the S-0910 package states:

Capacities.. are given both in weight (lbs.) and in conduit nurber and sizes. Capacity of'a support is limited to one of the groups of number and size of conduits shown in the corresponding table. However, any nunber and size of conduits may be grouped provided the total capacity in lbs. does not exceed that given in the corresponding

, tatele. If weight capacTty table is used, then capacity of hangers shall be verified in the.. field. LS and LA series drawings show how to determine conduit loads on each support, based on tributary spans.
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Far Cycre' Review Issue 13, a substitution such as this may be done

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with sup,' ort CA-15. Has this note been considered in conjunction

. with the 90neric support drawing sheets?

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.o Section 3.0 of Appendix 13 of the GIR discusses support frequencies in the 12 to'15 H ran ge. How do these lower frequency supports

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affect the DAF study, which assumes a minimum frequency of 14.45 Hz?

- 14 'dse of CA-Type Supports in LS Spans o' Section 3.0 of Appendix 14 of the.GIR discusses dynamic analyses performed for generic conduit runs to address the dynamic load distribution between CA-type (attaching conduits to walls, ceilings, etc.) and CSH-type (suspending conduits in space) supports. Section Texas Utilities Electric Company 10 Comanche Pbk Steam Electric Station L I. J L A Independent Assessment Program - All Phases

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s 5.0 states that the overload of a CA-type support is acceptable if. 's j the sum of the two LA spans on either side are less than or equal to. T g(-

an LS span, since LS spans have been qualified. Does the generic study address the scenario of a failed CA-type support? Does it f

consider redistribution of dynamic loads to the adjacent CA- and CSM-type supports?

o Section 5.0 of Appendix 14 of the GIR states that CA supports 1 adjacent to CSM/ CHM supports have been identified in a pre-walkdown. Was the pre-walkdown a documentation review or a physical

. observation of the plant condition.

o It is Cygna's understanding that the results of the pre-walkdown identified 1775 support configurations. Is this correct? s o Section 5.0 of Appendix 14,0f the GIR states that the conduit runs with CA supports adjacent to CSM/ CHM supports will be evaluated using response spectrum analyses. Please provide the procedures for the dynamic analyses.

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+ s Cygna understands that the :1775 occurences will first be reviewed to determine if they are adequate with respect-to the current deisgn allowables. Those which do not pass this review are to be modified s or analyzed using response spectrum analysis. Is this correct?.

s-The results of the dynamic analyses will be incorporated into the LA series drawings. In what form will the results be incorporated into the LA series drawings? '

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15. Stresses in Cable Trays Due to Attached Conduit Supports l o What parameters will be included in the test program? How will the test results be considered in the qualf,fication? Who will perform the qualification?

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l 16. Increases in Allowable Span Lengths ( w

! See Review Issue 2 for span configuration in the EAF study.

17 Substitution of Next Heavier Structural Member T No Questions.

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18. Clamp Usage A. Reaming of Bolt Holes I

o On page 4 of the Phase I Test Report, item 5 discusses an erection tolerance for the clamps. Cygna has reviewed procedure ECP-19 and has not identified this tolerance. What are the tolerances and were they specified in the original installation documentation?

o On page 11 of the Phase I Test Report, Table 5.1 provides capacity data for three different sizes of clamps for three different bolt sizes. Some of the clamps show a decrease in capacity when the bolt size is increased. Will a lower bound be used or will a check of actual installed bolt type be performed? How will these results be extended to other clamp sizes and types?

B. C-708-S Clamps o How were the clamp types determined in the walkdown effort?

How were C-708-S clamps distinguished from P-2558 and C-708-U clamps?

C. Clamp Distortion o How was this considered in the test program?

D. Clamp Tests o On page 17, Section 7, of the Phase I Test Report, load categories are discussed. Do each of the three load categories described correspond to one of the three loading directions for the clamp? It appears that Category 1 refers to axial conduit loads, Category 2 refers to " vertical" conduit loads, and Category 3 refers to lateral conduit loads. Is this correct?

o On pages 17 and 18 of the Phase I Test Report, the methodology l

for determining the cyclic test loads is described. What is the basis for the factor of safety chosen for each of the three Texas Utilities Electric Company 12 Comanche Peak Steam Electric Station

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categories? Why is a factor of safety of 3 used for Category 1 and a factor of safety of 4 used for the other two categories?

o On page 18 of the Phase I Test Report, the method of calculating the minimum number of required cycles is presented. This method is based on the assumption that the clamps respond to the maximum support / conduit frequency at the peak of the response spectrum, 13.23 Hz. Is it feasible that lower design loads applied over a greater nunber of cycles could be more critical than the tested cases?

o On page 19, Table 7.1 of the Phase I Test Report, maximum applied test loads are calculated. How do these values compare with the design loads?

o On page 11 and 12 of the Phase II Test Report, Section 3.3 describes changes in the test scope due to information regarding existing configurations at the site. Are all clamp installations at CPSES covered by the test? For the new P2558 clamps with revised spacing, what is the basis for performing only one cyclic test and no static tests? It appears that these clamps were distorted in the test configuration. Is this representative of all plant applications of this clamp?

o On page 45 of the Phase II Test Report, Section 7 discusses the allowables derived from the results of the cyclic load tests.

It states that the allowables are for the simultaneous application of three mutually orthogonal loads. However, it also states, No interaction equation is given nor implied as testing performed is insufficient to develop a reliable, three-directional, interaction formula.

Each calculated load must be lower than the allowable given in the attached tables before any clamp may be approved.

Although no interaction is intended by the allowables, there is an implicit interaction suggested by the tests. Were the tests adequate to ensure that all three loads can be maximized in the design and still be adequate? Is there a factor of safety on these allowables? Please discuss in detail how the final allowable loads were determined, including adjustments made to relative load magnitude between the three loading directions.

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19. Documentation Deviations Between Inspection Reports, CMCs and IN-FP Drawings A. Errors on Inspection Reports
1. In item 1 of Section 5.0 of Appendix 19 of the GIR, the Inspection Report (IR) error for support C11003395-1 is classified as an " isolated inconsistency" and not a

" discrepancy". What are the definitions of " isolated inconsistency" and " discrepancy"? Please discuss how this item was classified and how it will be used in root cause evaluations?

Since the irs are to be used to define a population from which a sample will be chosen, the accuracy of the irs is important for this task. How are possible " inconsistencies" in the irs considered in the sampling task? How are Component Modification Cards (CMCs) considered in the sampling task?

2. Cygna identified five occurrences in the review scope (7% of the supports) where the drawing references listed on the CMCs differed from the drawing revision listed on the inspection report. The implementation addresses only one such occurrence and classifies it as random. Please discuss how the support adequacy can be ensured by the fact that the final inspection and CMCs were written against different drawing revisions.
3. Will the conduit support tests determine if there is any functional or capacity difference between CA-la supports without anchor bolts in the outriggers and CA-2a supports with anchor bolts in the outriggers? How will the Cygna concern regarding accuracy of the irs with respect to CA-la and CA-2a supports be considered in the QA/QC root cause evaluation?
4. Of all the items discussed in this section, Cygna considers missing CMCs on the irs to be the most significant. If sampling activities are to be performed using the irs, their accuracy is important. If the occurrence of missing CMCs proves not to be random, please discuss its impact on the i sampling and review efforts using the IRS. How will all concerns in Item A.4 be considered in the QA/QC root cause evaluation?

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B. Installed Deviations With Inspection Reports

1. IRME-16236F was not updated after line C12002935 was rerouted. Was this line inspected? If so, what was the date of the inspection?
2. Is there a typographical error which calls out IRME-14604F?

Cygna is in possession of a copy of IRME-14684F which does not list either CSM-15b or IN-CSM-15b. In that copy, only IN-CSM-15a is listed. Please provide Cygna with the documentation supporting closure of this issue.

3. The last sentence on page A19.4 of Appendix 19 of the GIR states that all IRMEs that Cygna has found errors in will be updated to agree with all the latest documentation. Since the IRMEs are intended to be used as the means to insure that the conduit and supports were installed as designed and not merely to document the presence of certain supports, how will the implementation of the resolution address possible deficiencies in the inspection process?
4. Page A19.5 of Appendix 19 of the GIR also discusses a walkdown, sampling, and verification effort for conduit runs and supports. How was support type determined? What are the results of the walkdowns? Has the comparative review been completed? If so, what are the conclusions?
20. Nelson Studs o No questions.
21. Conduit Fire Protection Calculations A. Thermolag Configuration 16 questions.

B. CA-la Capacities i

o Were the CA-la capacities revised? If so, in what way were the designs impacted?

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i C. CA-2a Capacities o In what way were the designs impacted due to the revised loads?

D. IN-FP (Fire Protection) Calculations Section 5.0 of Appendix 21 of the GIR discusses walkdown o

verification of IN-FP drawings. How was this accomplished given the presence of Thermolag?

22. Span Increase for Fire Protected Spans o Please provide Cygna a copy of the conduit material yield stress test report in SDAR (Significant Deficiency Analysis Report) CP 19.

o In Section 3.0 of Appendix 22 of the GIR, a Dynamic Amplification Factor (DAF) is mentioned in relation to the RSM analyses. Please explain how the analyses are performed, how the supports are evaluated, and the significance of the DAF.

23. Grouted Penetrations o Section 5.0 of Appendix 23 of the GIR states that loads on grouted penetrations will be calculated using both " fixed" and " hinged" boundaries. Please justify the assumptions for the two boundary conditions with respect to the actual installation, o Section 5.0 of Appendix 23 of the GIR discusses the intended approach to determine the bond strength of grouted penetrations.

What is the status of the literature search? If tests are to be performed, please describe the tests methods and the parameters to be considered.

24 Rigidity of CA-Type Supports o Section 5.0 of Appendix 24 of the GIR states that tests were used to verify the rigidity of CA-type Unistrut supports. Were the test configurations and load applications selected to provide lower bound stiffnesses? Which support types are covered by the test results?

o Which structural steel support types were determined to have frequencies below 33 Hz? Were these results considered in other generic studies involving CA-type supports?

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o Section 5.0 of Appendix 24 of the GIR states that the design verification of non-rigid CA-type supports was performed using "g" values from RSM analyses of LS spans. Please elaborate on this statement. {

25. Enveloping Configurations for Design o Section 3.0 of Appendix 25 of the GIR states that verification of the Unit I supports will rely on CMCs and IN-drawings (i.e., for individually-engineered supports), as they are expected to reflect the actual installed support condition. Please substantiate this assumption with respect to the installation documentation errors discussed in Review Issue 19.

o The 2323-S-0910 package has several sheets of general notes which are applicable to all generic support designs. How were these general notes and other allowances included in the EBASCO design verification? How were the generic supports evaluated such that all revisions of the drawings and general notes are enveloped by the design verification?

I o In Section II.A) (page 6) of SAG. TUG 1.341, a discussion of loading of the support ~ to maximize support member stresses is given. What assurances were made to maximize forces and stresses in other components as well?

o How are working point eccentricities considered?

o The adequacy of the conduit attachments referenced in Paragraph 4 of Section 3 of EBASCO Calculation Book No. 8 has been verified in Calculation Book No. 44 Was analysis or comparison with test results used in the verification?

o In Section 4.5.1, of EBASCO Calculation Book No. 8, the BEAMS element is to be used for the modeling of various support members, which include angles and channels. Does this element account for the shear center offset of these types of members? If not, how will torsional effects be considered?

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. 26. Design Drawing Discrepancies o How will the resolution ensure that the supports installed using current and previous revisions of drawings with missing information are adequate?

27. Walkdown Discrepancies o Please discuss any differences in the Unit I walkdown procedures with respect to those provided for Unit 2. Please discuss the walkdown tolerances with respect to the construction tolerances.

' Are documentation discrepancies also addressed in this walkdown (see i

Review Issue 19)?

Are the comparisons of the as-built systems and the 2323-S-0910 requirements available? If so, please provide them. Do the comparisons consider the revisions to which the supports were inspected?

Section 3.0 of Appendix 27 of the GIR discusses a possible root I cause for'the listed discrepancies. What is the basis for this conclusion?

o How will inaccessible attributes be handled in the as-built

process? If a portion of a conduit system is inaccessible, will the l attributes be assumed or will another run be selected for the sample? If the former choice is selected, what criteria will be used in assuming the attributes? If the latter choice is selected, how much of the first run must be inaccessible before another run is i

selected? If the latter choice is selected, would the fire-protected runs be excluded from the random sampling process? If so, how are the fire-protected runs considered?

! o Cygna has the following questions on walkdcwn procedure TNE-FVM-CS-016 Revision 1:

(a) How are welds considered? Is the Visual Weld Acceptance Criteria (VWAC) used? How are any partial penetration welds

! considered?

I (b) In Section 3.2.B.2 why are the fittings limited to the sizes indicated?

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r (c) In Section 3.2.B.3 why isn't the shortest cable slack noted?

(d) Are the general conditions of the support installation noted

, (e.g., properly seated nuts, plumbness, etc.)?

(e) In Section 3.2.B.4.b why is only the thickness recorded for single conduit supports?

(f) How are anchorage spacing violations considered? How are connections to embedded plates considered?

28. Systems Concept o Section 5.0 of Appendix 28 of the GIR discusses the concept of shared moments between conduit supports. What is the basis for this assumed behavior? How has the moment transfer between the conduits and supports through the clamps been addressed? What system models are used for this verification effort? Have variations of span lengths and configurations been considered? How were they chosen to envelop the total population?
29. Cumulative Effort of Review Issues To be discussed later.

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