ML20211C385

Forwards Background Info on Facility for Ofc of Congressional Affairs.Related Documentation Encl

ML20211C385
Person / Time
Site:	Comanche Peak
Issue date:	04/28/1983
From:	Triner E NRC
To:	Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20211C348	List: IR 05000445/1981020 ML20211C341 ML20211C385 ML20211C402 ML20211C418 ML20211C452 ML20211C502 ML20211C508 ML20211C539 ML20211C565 ML20211C593 ML20211C608 ML20211D561
References
FOIA-85-312 NUDOCS 8606120304
Download: ML20211C385 (145)

Text

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APR 2 81983 1

MEMORANDUM FOR: Thomas A. Rehm, Assistant for Operations OEDO FROM: Edwin G. Triner, Director, RM/B

SUBJECT:

BACKGROUND INFORMATION ON COMANCHE PEAK ,

Attached is the backoround information you requested on Comanche Peak for the Office of Congressional Affairs.

The information was primarily obtained from the Resident inspector, the Licensing Project Manager, the ELD case attorney and the Division of Emer-gency Preparedness, IE.

If you have any questions, please contact me.

Original Signed by Edwin G.Triner Edwin G. Triner, Director, RM/B

Attachment:

As stated bec:

L. Barry, RM R. Scroggins PJi

• E. Triner, ,RM/B MEL ,

RM/B R/T (6)

RM/BMA Chron/Subj S. Burwell, NRR R. Taylor, Resident Inspector T. Rothschild, ELD R. Roher EP/IE C. Wisner, PAO, R IV 0606120304 060606

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' '*"'" Undepos:jhlark Triner 4/74'83 y 442(/83 44[/83 FotA TR33fD

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.i C0F.ANCHE PEAK Unit 1 Unit 2 Utility: Texas Utilities Generating Same Location: 4 mi N of Glen Rose, Texas "

Somervelle Co., Texas ,

Docket No.: 50-445 .

50-446 CPPR & Date: CPPR-126 12/19/74 CPPR-127 12/19/74 Power Level (MWe; MWt): 1150(MWe);3411(MWt) Same Reactor Type: PWR "

Architect / Engineer: GibbsandHill(G8H) "

Nuclear Steam Supply System (NS$$) Vendor: Westinghouse "

Constructor: Brown & Root (BRRT)

Condenser Cooling Method: Once-thru "

Condenser Cooling Water: Squaw Creek Reservoir with " -

makeup water taken fron Lake Granbury on the Brazos River Applicant's Estimated

. Fuel Load Date: 9/83 .

c

NRC Estimated Fuel Load Date: 12/83 Approx. 16 mos.

(Ref. NRC Staff Resp. after Unit 1 to Board Order Request-ing Info. dated March 3, 1983)

NRC Percent Construction Complete: 95% 62%

NRC Licensing Project Manager (Tel.): SpotBurve11(3014927563) Same .

Resident Inspectors (Tel.): DennisXelly(817897-2201) "

Robert Taylor Unit No. 1 .

Preoperational testing is approximately 50 percent complete.

Hot functional testing is in progress.

Containment leak rate test has been completed.

• Unit No. 2 The reactor vessel and steam generators have been installed. Reactor loop piping is in place.

The balance of the plant piping is approxinately 75 percent completb.

Most of the electrical work is yet to be done.

1 4/21/83

,.- . \

l COMANCHEPEAK(Continued)

Emergency Preparedness Exercises An onsite emergency preparedness implementation appraisal is scheduled for July 1983.

A full-scale emergency preparedness exercise with the licensee, the state and local counties will be observed by NRC for licensee actions and by FEMA for offsite actions in October 1983.

Summary of liajor Issues to be Heard in Upcoming Hearings There are two contentions remaining on which testimony has not been completed.

These are: Contention 5 QA and QC during construction has not been adequate; and Contention 22. Emergency Preparedness is inadequate. These two contentions are the only remaining issues of significance.

QA/QC Contention - Relative to the QA and QC contention, the utility, the staff and the intervenor have all presented their testimony on the broad issue before the ASLB. However, in the course of the hearing, the intervenor has introduced many witnesses who have made allegations about things they perceived to be

. deficiencies in construction and design of the plant. In most of these cases, the utility and the staff have given testimony rebutting the allegation, in the last hearing session, two engineering technicians made extensive allegations that the piping supports were improperly designed. The utility furnished testimony in rebuttal of these allegations, but the staff was not prepared to do so on such short notice. to give tie staff an opportunity to investigate The ASLB these adjourned allegations. Thethe hearing? formed a special staf inspection team to look into the allegations on the pipe supports, and this team issued its report in mid-February 1983. The ASLB has scheduled the staff testimony.on the pipe support inspection to be heard at the next hearing session -5/16/83 5/20/83.

In January through March 1983, the NRC sent out a Construction Appraisal Team (CAT) to perform an in depth inspection on the quality of construction at Comanche Peak, its report was issued to the ASLB as a Board Notification on April 10, 1983. This inspection found items that require attention in the (1) heating, vent.ilation, and air conditioning (HVAC) syste&, (2) cable separation, and (3) cable and pising supports. The HVAC item was considered a breakdown in quality assurance; t1e other two items had random deficiencies which were not indicative of such a breakdewn. The ASLB has scheduled a second hearing session (6/13/836/17/03) to hear testimony on the CAT inspection report.

At this time, the staff testimony on its inspection of the design of piping supports,andthetestimony(bystaffandtheutility)ontheCATinspection

, report are the only tw items remaining to be heard on Centention 5, provided the Comissioners rule in favor of the staf f in its appeal of the ASLO order to identify individual interviewed in an investigation of an allegation concerning the improper terinination of a quality control inspector.

2 4/21/83

?

COM/ ACHE PEAK (Continued)

Emergency Dreparedness Centention - The ASLB has heard nearly all of the -

testimony c,n this contention. The applicant, the state emergency organization, .

the staff and FEl'.A all testified at the last hearing session. The testimony by FEMA identified three minor items which were not fully resolved at that time.

Also, FEMA did net n.ake it Interim Finding until shortly after the last hearing session. The staff also issued its safety evaluation on the utilities' emergency program in March 1983. The A$lB has indicated it will have questions ,

concerning the FEMA Interim Finding and the staff's safety evaluation at the '

forthcoming hearing ses: ion.

Inadequacies of emergency planning include:

1) Exact pros ..on,of offsite warning system--e.g., siren placement;

2) Assessment an accident - due to the fact that many of the emergency action levels are tied to technical specifications which are still under development.

Beard Ouestions

• The Board has also identified certain Board Notifications on which they wish to question the staff on their significance and relevance to Comanche Peak. The

. Board also identified several unresolved safety issues on which it wishes an update on the status of resolution end whether staff conclusions that it is acceptable to license Comanche Peak prior to their resolution remain unchanged.

The evidentiary hearing considering the application for an operating license for Comanche Peak began in Decertber 19ul.

' '12/2/01 '18/3/81 - Th'eiYsth'cWing'sesIio'n'was'heldin'FortWor't'h, Texas. '

f

. . .... .. issues heard were. financial qualifications and.the operating .... ~

. . . . . Quality Assurance /Ouality Control (0A/0C) program.

6/7/02 - 6/11/82 - The second, third and fourth sessions addressed the adequacy 7/26/82 - 7/30/82 of the applicant's OA/0C during construction and the 9/13/82 - 9/17/02 adequacy of emergency preparedness. At the close of the evidentiary hearing on September 17,1982, the Licensing

. Board inquired whether the hearing tould be closed or whether additional evidence was necessary to complete the record. Responses were due on October 11, 1982. The staff indicated that the Board could close the record at to the emergency planning contention and as to all aspects of the 0A/0C contentionbywith the excep(tion of the matters currently i

being evaluated the staff. "Walsh/Doyle" allegations) 3/31/83 ASLR cancelled its " arch 4,1983 erdar f eheduling'a hearing session for April 4 C,1983 to contid'r the stvf s per-l fornance and allegations concerning the staff's investiga-l tion of a " whistle blower's" charges. Walsh/Doyle I

allegations, and emergency planning.

3 4/21/03 l

COMANCHE PEAK (Contir.ued) s -

4/4/83 - ASLB reconstituted by appointing a new Board chairman.

5/16/83 - 5/20/83 - ASLB rescheduled further evidentiary hearings to be held to 6/13/83 - 6/17/83 consider the staff's inspection report on the Walsh/Doyle allegations, Board questions on emergency planning, Board questions on the significance of certain Board Notifications provided by the NRC staff, and Board questions on the unresolved safety issues. The second session will hear testimony on the NRC staff's Construction Appraisal Team Inspection Report issued April 11, 1983.

Quality Assurance /Ouality control (0A/0C) Allegations During the evidentiary hearing the intervenors offered testimony containing allegations with regard,to the design and construction of the plant.

Three concerns were expressed in this category:

a Inadequate foundation b problems in welding and concrete work, and c, Non-regulation of pipe supports in the containment building As part of rebuttal testimony, the applicant responded to these allegations.

.The staff. indicated that.its. assessment.of certain of the allegations was not complete, and therefore, the staff can neither affirm nor deny whether the applicant's response is in fact complete and satisfactory with respect to these

..,, ,.allegatjons. .The staff comp 1.eted its.. spec.ial jaspection report conducted... ... . . . . . . . ,

of these allegations which is documented in an inspection report (82-26/82-14),.

v...... o . issued.on February.15, 1983..,.w ,.l. v.P .. . . . .L . . .... . . . . . . '. n . . . e , . b . ...*.....s.4.-

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The Licensing Board has not made a decision on this matter. Hearings on the staff's special inspection report, as well as other matters, are to be con-

.. . ducte,d Mag 1,6,-20, 1983. , , , , ., ,

Atomic Safety and Licensing Board (ASLB) Order to Show Cause During the evidentiary hearing the staff testimony put into evidence certain investigation reports which identified the informants of the infermstie.n by letter rather than by name. In response to a direction by the Licensing Boerd to identify the informants, the staff refused on the grounds that that would be detrimental to the staff's investigative capability and was unnecessary

, for the development of a factual, record in-the proceeding. . .

4 4/21/83

\

L

8 /

e C0f1ANCHE PEAK (Continued)

ASLB Order to Show Cause (Continued) 8/4/82 - The Licensing Board issued an Order requiring the hRC staff to show cause why sanctions should not be imposed for the staff's

., refusal to obey the Board's orders to identify individuals interviewed in connection with an investigation of an informant's quality control allegations, and for the staff's refusal to produce unexpurgated copies of signed witness statements taken from persons identified'by the informant.

8/24/82 - The staff responded to that order and included in its response a motion for reconsideration.

9/13-17/82 - During the continuation of the evidentiary hearing, the Board stated that it would not reconsider its orders to the steff to produce the information and that a written order would follow.

9/30/82 - The Atomic Safety Licensing Board (ASLB) issued an order denying the NRC staff's motion for reconsideration and once again directed the NRC staff to identify individuals interviewed in connection with the investigation.

10/8/82 - The NRC staff filed with the Atomic Safety Licensing Appeals Board (ASLAB) a notice of appeal and exception to the ASLB's

. . . Septembe r..3.0, ISS2..erder denying. r.econsideraticn, < - . .

10/12/82 - The NRC staff filed with the ASLAB an applicatien for a Stay c'f

' ~

. ... . . .the, effect.iv'eness.s cf.the. ASLBs Sept 4mber 30,1900:ordet. . . . . . . . ...w

.,. o,s . .d/19/.83, .; .~ The .ASL AB.hea rd-cral -argument .onAhe .staf.fs'.s, eppeal.-f vom

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. . <.-e ,

. - . .. 0 .i. t. ,. r.  : .. order.. issued by, the Board on. August. 4w1983;.. .The< Appeals ,Boardi ~; u --

refused thp staff's appeal and upheld the ASLB's orcer.

2/,24/,83 ^

- Appeal Board issued a decision dismissing staff's appeal for~

~

~ ^

want of a" gen' u ine"cinEroversyisithdrawing gran't Wf staff's petition for directed certification and leaving the Licensing

. Board's order standing.

2/25/83 - Sta.ff fi. led application with Appeal Board for .3 stay of its Februs ry 24, 1983 decision.

3/1/83 - Appeal Board denied staff's request for a stay.

3/1/83 Staff:.fiJ ed.reouest withethe Cornissione.rs efor a.4tay of- - . -

Appeal Beard's dec'uon.

3/4/83 - Commission issued an Order granting staff's request for a stay.

5 4/21/83

C0HANCHE PEAK (Continued)

ASLB Order to Show Cause (Continued) 3/11/83 -

Staff filed petition with Cormission for review of Appeal Board's decision.

3/30/83 -

Comission issues order staying ASLB's March 4,1983, Notice of Resumed Evidentiary Hearing and March 9,1983 Order to the extent that they entail in any way a Board inqu.iry which could, directly or indirectly, result in the identification of persons interviewed by NRC staff when conducting its investigation.

. . 4/11/83 -

Comission issued Order: extending until.. April 29,.1983,.the ,

time for it to consider whether to review the Appeal Board's decision.

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l DEFINITION OF INTIMIDATION, HARASSMENT AND DISCRIMINATION Intimidation or Harassment: Incidents, statements or other actions that are reasonable likely to influence employees to refrain from performing safety-related work in accordance with requirements or identifying or reporting quality discrepancies or safety problems. In determining whether the incident, statement or actions was reasonably likely to influence employees, a number of factors will be considered including: 1) the nature of the statement or action; 2) the intent of the person making the statement or taking the action; 3) the perception of the recipient of the statement or action;and4)thepositionsofandrelationship5etweenthepersonmakingthe statement or taking the action and the recipient.

Discrimination: The showing of prejudice in the treatment of employees for performing safety-related work or reporting quality discrepancies or safety problems to their management or to the NRC. The showing of prejudice may include adverse actions such as discharge or other actions that relate to the terms, conditions, and privileges of employment.

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o' FORMAT FOR ANALYSIS OF INTIMIDATION AND DISCRIMINATION AT COMANCHE PEAK

1. Description of the intimidation / discrimination incident including:

a) Name, position, and duties of person subject to intimidation; b) Name, position and duties of person alleged to have intimidated; c) Names and positions of other persons either subject to or involved in the incident; d) Area of work involved - welding, coatings, etc.;

e) Date and place of incident; f) the nature of the statcment or action; l g) the intent of the person making the statement of taking the action; h) the perception of the recipient of the statement or action; and

( i) the positions of and relationship between the person making the statement or taking the action and the recipient.

l 3. The effect of the statement on the recipient including any specific failures to report safety problems and the basis for the conclusion that the effect occurred.

4. Reference to documents where incident is described such as Investigation Reports, deposition, hearing transcripts, etc. (title, dated, pages).

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Ashok Thadani Draft 2/12/85 Steps In Assessing Quality of Comanche Peak

1. List Allegations by period

2. List Findings in CAT SIT SRT Hearing Records / Summary Dispositions Various Region IV Inspections Other Inspections SALP and Trend Reports CYGNA TRT

3. Integrate Findings On Each Issue

4. Determine Safety Significance of Each Issue Possible Categories

' Paper Problems, Hardware OK

' Hardware Concern

-Negligible effect on function

-May affect one Train

-May af fect multiple trains

' exceed DNBR or Press Limit"

' core melt *

'lj n > !e r . conditions

-M.iy ctuse .i t r ins i ent Foi a .*5. 512 f/- 5' .

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-May cause an accident

5. Determine significance of all issues collectively

6. Assess the Applicant Program Against 5 i

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COMANCHE PEAK CIVIL / STRUCTURE AND E CHANICAL/ PIPING TEAM L. SHA0', GROUP LEADER CIVIL / STRUCTURE ECHANICAL/ PIPING D. JENG', SUB-GROUP LEADER ( 36 Ph S. HOU', SUB-GROUP LEADER t

Ow e*g J.DEAVERS,PARAMETERb

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W. P. CHEN, ETEC V.FERRARINI,EASh40*h C. HOFMAYER, INEL T. LANG0WSKI, ETEC (e 2 W ) D. HANSEN, INEL R. HUBBARD', SANDSTONE, INC>

1 R. LIPINSKI, liRC O 3~

R. PHILLE0, PARAMETER (H f D. LANDERS, TELEDYNE J. MALONSON, TELEDYNE

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CIVIUSTRUCTURAL AND ECHANICAUPIPING TEAM e 6 STRUCTURAL ENGINEERS AND 10 ECHANICAL ENGINEERS l

e EXPERTS IN

(A) CONCRETtDESIGNANDCONSTRUCTION 1

! (s) PIPING DESIGN AND CONSTRUCTION

(c) PIPE SUPPORTS DESIGN AND CONSTRUCTION (D) WELDING AND IN3PECTION l

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l SCOPE OF CIVILMCiislii;it ALLEGATIONS FIFTY-SEVEN (57) ALLEGATIONS IN CIVIL / STRUCTURAL AREA.

THE ALLEGATIONS PERTAIN TO THE FOLLOWING SIX BROAD i

AREAS:

i;

1. DESIGN DEFICIENCY i

2.TESTINGORINSPECTIONIRREGULARITIES[#d,j73) 3',' INCORRECT CONSTRUCTION PRACTICES f-

x. ,,

4. INADEQUATE REPAIRS 1

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5.' UNCORRECTED'l UNSAFE CONDITIONS IN THE COMPLETED Me W STRUCTURES P 3 **

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6',' PREMATURE STRUCTURAL LOADINGS l

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r SCOPE OF ECHANICAL/ PIPING ALLEGATIONS 1.

ONE HUNDRED FORTY SEVEN ALLEGATIONS IN MECHANICAU PIPING AREA',

ALLEGATIONS PERTAIN TO THE FOLLOWING 4 BROAD AREAS:

• WELDING (85 r//eg AWt Igm /o/skW f}nou M ) ey g/u/ [

• PIPING [2omA / 6 $' 4,/e m3 Q ~y u pb 44 <o a u b eg J

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• SUPPORTS f' ,, #3 g g kg g gy

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l BASIC APPROACH ,,

I o REVIEW ALL RELATED DOCUMENTS SUCH AS ALLEGER TESTIMONIES, ASLB HEARING RECORDS, NEWSPAPER ARTICLES, I INTERVIEW RECORDS, ETC TO FORMULATE ALLEGATIONS.

o THROUGH INTERVIEWS WITH ALLEGERS AND INFORMAL MEETINGS AND DISCUSSIONS WITH THE APPLICANT AND THEIR CONTRACTORS, DEVELOP THE NECESSARY BACKGROUND INFORMATION:

o EVALUATE AND ANALYZE ALLEGATIONS IN RELATION TO CONSTRUCTION, ANALYSIS, DRAWINGS, SPECIFICATIONS, CODES, PROCEDURES, FSAR AND OTHER COMMITTED DOCUMENTS.

l o DETERMINE THE VALIDITY OF ALLEGATIONS ONCE THE ALLEGATION IS FOUND TO BE VALID, DETERMINE WHETHER IT HAS POTENTIAL SAFETY SIGNIFICANCE AND GENERIC IMPLICATION. -

o THE VIOLATION THAT HAS POTENTIAL SAFETY SIGNIFICANCE IS TERMED AN OPEN ISSUE.

o OPEN ISSUES WERE TRANSMITTED TO THE APPLICANT FOR ACTION. .

t o DISCUSS FINDINGS W1TH ALLEGERS.

9 e

4

, ,_ _ . . . --_- , -. - - - . - . , , , . - - -4 ,

r DEFINITION OF " LACK OF SAFETY SIGNIFICANCE" LACK OF " SAFETY SIGNIFICANCE" PERTAINING TO OR AS A RESULT OF A GIVEN DEFICIENCY, OR VIOLATION OF APPLICANT'S COMMITMENTS, CODES, OR FSAR REQUIREMENTS MEANS THAT WHILE AN ACTIVITY OR ITEM DOES NOT FULLY CONFORM TO ALL APPLICANT'S C0ft11TMENTS, OR APPLICABLE CODES OR FSAR REQUIREMENTS, TRT CONCLUDES ON A TECHNICAL BASIS THAT THE STRUCTURE OR COMPONENT WILL NEVERTHELESS FUNCTION PROPERLY WITHOUT INTERFERRING WITH SAFETY'.'

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r OPEN ISSUE  ;} gh NN h(( M k C)q e ALLEGATION IS VALID o wI f** ""

e THERE IS VIOLATION e THERE IS POTENTIAL SAFETY SIGNIFICANCE W

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r POTENTIAL OPEN ISSUES ,

1, CIVIL / STRUCTURES 1.1 UNABLE TO JUSTIFY REINFORCING STEEL OMITTED IN REACTOR CAVITY 1.2 FALSIFICATION OF CONCRETE COMPRESSION STRENGTH TEST RESULTS 1.3 MAINTENANCE OF AIR GAP BETEEN CONCRETE STRUCTURES 1.4 SEISMIC DESIGN OF CONTROL ROOM CEILING

• ' ELEMENTS

~

1,5 UNAUTHORIZED CUTTING 0F REBAP. IN THE FUEL HANDLING BUILDING

2. MECHANICAL AND PIPING l',1 INSPECTION OF CERTAIN TYPE OF SKEED FILLET ELDS 1.2 PIPING DESIGN CONSTRUCTION BETEEN CATEGORY I

~

AND NON CATEGORY I BUILDINGS 1.3 UNAUTHORIZED CUTTING 0F EQUIPMENT RESTRAINT ANCHOR BOLTS IN THE REACTOR BUILDING 1.4 UNCONTROLLED PLUG ELDS ,

1,5 PIPE INSTALLATION

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. . O CIVll/ STRUCTURAL j CATEGORY N0, 8 - FALSIFICATION OF COKRETE COMPRESSION STRENGTil TEST RESULTS i

POTENTiALOPENISSUE

ALLEGATION ON FALSIFICATION OF CONCRETE COMPRESSIVE STRENGTH TEST REST lLTS l COULD NOT BE PROVED VAllD OR INVALID. CONCRETE STRENGTH LOWER THAN THAT I SPECIFIED IN THE DESIGN MAY REDUCE THE LOAD RESISTING CAPACITY OF STRUCTURES, i

t l ACTION REQUIRED BY TUEC TUEC SHOULD DETERMINE AREAS WHERE SAFETY RELATED C0 K RETE WAS PLACED

! DURING THE PERIOD FROM JANUARY 1976 TO FEBRUARY 1977 AND CONDUCT I APPROPRIATE RANDOM StimIDT HAN!ER TESTS ON THE CONCRETE IN AREAS WHERE l SAFETY IS CRITICAL.

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CATEGORY NO.11 - MINTENAEE OF AIR GAP BETWEEN COKRETE STRUCTURES

) POTENTIAL OPEN ISSUE -

i BASED ON THE REVIEW OF AVAILABLE INSPECTION REPORTS AND RELATED DOCUMENTS, FIELD l

) OBSERVATIONS AE DISCUSSIONS WITH TUEC ENGINEERS, THE TRT CANfl0T DETERMINE WHETHER l AN ADEQUATE AIR GAP HAS BEEN PROVIDED BETWEEN CO K RETE STRUCTURES.

ACTION REQUIRED BY TUEC PROVIDE DOCUMENTS OR INSPECTION RESULTS TO DEMONSTRATE THAT ADE00 ATE SEPARATION l BETHEEM ALL COKRETE STRUCTURES !MS BEEN PROVIDED. PERFORf1 ANALYSIS TO DEMONSTRATE

) THAT THE AS BUILT COEITIONS DO NOT SIGNIFICANTLY IKREASE THE SEISMIC RESP 0MSES OF j CATEGORY I STRUCTURES Af!D COMPONEfRS.

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CIVIUSTRUCTURAL l CATEGORY N0.14 - SEIStilt DESIGN OF CONTROL ROOM CEILING ELEMENTS _

POTENTIAL OPEN ISSUE FIELD RUN CONDulT, THE SUSPENDED r ~ ELEMENTS, AS THE LIGHTING FIXTURES .

j INSTALLED IN THE CONTROL R0(r '" . CLASSIFIED AS NON-SEISMIC OR SEISMIC

! CATEGORY II AE FIAY FALL AS i. nf.SULT OF A SEISMIC EVENT.

• i

! ACTION REQUIRED BY TUEC l

) PROVIDE OR MODIFY SEISMIC CALCULATIONS ON SEISMIC CATEGORY II AND MON-SEISMIC ELEE NTS IN THE CONTROL ROOM CEILING TO DEMONSTRATE THAT THEIR FAILURES WILL NOT AFFECT SAFETY RELATED COMPONENTS OR CAUSE INJURY TO OPERATORS.

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1 CIVIUSTRUCTURAL i CATEGORY NO.15 - UMUTHORIZED CUTTING OF REBAR IM THE FHEL Mt!DLING BUILDING l

i POTENTIAL OPEN ISSUE UMUTHORIZED CUTTING OF REMR ASSOCIATED WITH THE INSTALLATION OF THE TROLLEY PROCESS AISLE RAILS IN THE FUEL HANDLING BUILDING MAY HAVE

OCCURRED. LOSS OF THE RE3AR MY REDUCE THE LOAD RESISTING CAPACITY OF THE

CONCRETE FLOOR SLAB.* ~.-

j ACTION REQUIRED BY TUEC l Pfl0 VIDE TIE FOLLOWING Ilf0RMAT10N REGARDING DRILLING OF RE3AR:

i (1) ITFORETION TET DEMONSTRATES TET ONLY THE UPPERMOST # 18 BAR WAS

! CUT, OR (2) DESIGN CALCULATIONS THAT DEMONSTRATE TM T STRUCTURAL INTEGRITY IS  ;

MAINTAINED IF # 18 BARS IN THE UPPERMDST AND T!E LOWERMOST LAYERS ARE CUT.

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i ECHANICAL AND PIPING CATEGORY MO. 31 - INSPECTION OF CERTAIN TYPE OF SKEED FILLET WELDS IN NF SUPPORTS l POTENTIAL OPEN ISSE

~

v TEE WAS A LACK OF PROPER INSPECTION DOCLENTATION FOR SKEWED FILLET ELDS

, /WHENWELDINGAPIPESTAKHiONTOAPIPESTAKHION','ORAPIPESTANCHIONTOA CURVED PLATE FOR CLASS 2.AND 3 NF SilPPORTS'. IPPROPER INSPECTION TECHNIQUES

1. ~

ild COULD d k wd ESULT IN UNDERSIND ggjg FILLET gQ3 ELDS. $W V

nrnels fw G A 2-(t l 8 ACTION BY TEC l

Y PROVIE TE FOLLOWING:

(1) EVISE BtR WELD INSPECTION PROCEDUES CP-QAP-12.1 AND QI-QAP-11.'l-28 TO PROPERLY ADDESS ALL TYPES OF SKEWED

~

I FILLET WELDS, INCLUDING PIPE TYPE CONNECTIONS.

l (2) '-

j PROVIE EVIENCE TO VERIFY THAT PEVIOUS INSPECTION OF TESE TYPES OF SKEED FILLET WELDS WAS PERFORED TO THE

) APPROPRIATE INSPECTION TECHNIQUES'.

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1 ECHANICAL AND PIPING i

CATEGORY N0 4 - UNCONTROLED PLUG ELDS POTENTIAL OPEN ISSUE

] .

HOES IN UNIT 1 & 2 PIPE SUPPORTS? CABLE TRAY SUPPORTS AND BASE PLATES WHICH HAD BEEN MISDRILED DURING FABRICATION HAVE BEEN REPAIRED IN AN

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j UNCONTROLED MANNER BY PLUG ELDS.

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ACTIONS REQUIRED BY TUEC TUEC SHALL PERFORM ONE OF THE FOLLOWING 1.~ PROVIDE A PROPOSED PLAN OF RESOLUTION INCLUDING A SAT LING INSPECTION l OF ALL AREAS OF THE PLAN HAVING PLUG ELDS WHICH ItiCLUDES CABE TRAY 1 SUPPORTS, PIPE SUPPORTS AND BASE PLATES 1

2', PERFORM BOUNDING ANALYSIS TO ASSESS THE GENERIC SAFETY SIGNIFICANCE, OF UNCONTROLED PLUG ELDS.

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ECHANICAL AMD PIPING CATEGORY NO. 11 - PIPE INSTALLATION l P0TENTIAL OPEN ISSUE TErPORARY SUPPORTS FOR THE UNIT 1, LOOP 1,' MAIN STEAM LINE SETTLED DURING l

CONSTRUCTION, THE LINE WAS SUBSEQUENTLY REPOSITIONED USING THE MAIN FOLAR CRANE AND COE ALONGS'. ASSESSENTS OF EFFECTS ON QUALITY OF THE MAIN STEAM AND FEEDWATER LINES HAVE NOT BEEN PERFORED FOR THE FULL SEQUENCE OF

!' EVENTS INVOLVED',' .

ACTION REQUIRED' BY TUEC (1) PERFORM AN ASSESSENT_OF THE STRESSES IN THE AFFECTED PIPING (2) PERFORM NDE'0F AREAS WHERE STRESSES EXCEED ALLOWABLES (3) REVIEW RECORDS OF HYDROSTATIC TESTING TO VERIFY QUALITY OF

AFFECTED PIPING (14) PROVIDE ASSESSENT OF EFFECTS ON OTHER SAFETY RELATED PIPING

]

l WHICH WAS INVOLVED IN SIMILAR INCIDENTS OF SETTLEENTS OF

! TEMPORARY SUPPORTS. ..

1 I

1 . .

CATEGORY N0' 18 - UNAlHHORIZED CUTTING OF EQUIPENT RESTRAINT ANCHOR BOLTS IN THE REACTOR BUILDING l POTENTIAL OPEN ISSE pN UNAUTHORIZED CUTTING OF THE BASE PLATE ANCHORING BO Y

gglATERALSUPPORTSFORTHESTEAMGENERATORMAYHAVEOCCURRED'.' THE CUTTING

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,ge TESE BOLTS MAY REDUCE TE LOAD CAPACITY OF THE LATERAL SUPPORT'.

1. / ACTION REQUIRED BY TUEC I PROVIDE EVIDENCE SUCH AS ULTRASONIC EASUREENT RFeULTS TO VERIFY THE INSTALLED l 8 LENGTH OF BOLTING'. SHOULDUNAUTHORIZEDBOLTCUTTINGBEVERIFIED'lTUECSHALL:

i

\ (1) REPLACESHORTENEDBOLTSWITHBOLTSOFPROPERLENGTH'lORPROVIDE.

Y ,p ANALYSIS TO JUSTIFY TE ADEQUACY OF SHORTENED BOLTS AS INSTALLED'.

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3 (2) PROVIDE JUSTIFICATION OR PROPOSE EASURES TO ENSURE THAT NO SIMILARCONCERNEXISTSFORBOLTINPi.

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m ECHANICAL/ PIPING CATEGORYN0'l36-PIPINGDESIGNCONSIDERATIONSBETWEENCATEGORY1ANDNON-CATEGORY 1 BUILDINGS

(# b d POTENTIAL OPEN ISSUE I<N*/

PIPING SYSTEMS SUCH AS MAIN STEAM'l AUXILIARY STEAM AND FEEDWATER ARE ROUTED FROM ELECTRICAL CONTROL BUILDING (SEISMIC CATEGORY I) TO TURBINE BUILDING (NON-SEISMIC CATEGORY I) WITHOUT ANY ISOLATION'l EACH SEISMIC CATEGORY I PIPING SYSTEM SHOULD BE ISOLDATED FROM ANY NON-SEISMIC CATEGORY I PIPING SYSTEM BY SEPARATION'iBARRIERORCONSTRAINT'l IFNOT'lTHEEFFECTOFTHEFAILUREOFNON-SEISMIC CATEGORY I STRUCTURES AND PIPING ON SEISMIC CATEGORY I PIPING SYSTEMS MUSTBECONSIDERED'l ACTIONS REQUIRED BY TUEC TUEC SHALL PROVIDE DOCUENTATION THAT PIPING SYSTEMS GOING BETWEEN CATEGORY I AND NON-CATEGORY I BUILDINGS EET ST4TEDFSARCRITERIA'.

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$ US[15H $ $IN U Page 1 l

PIPE STRESS I Open Items and Generic Issues

1. Mass Participation /Hass Point Spacing

References:

1. R.E. Ballard (G&H) letter to J.B. George (TUGCO),

" Mass Participation," GTN-69454 September 14, 1984

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Phase 3 Open Items - Mass Partici-pation," 84042.017, September 21, 1984

3. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Phase 3 Open Items - Mass Participa-

' tion," 84042.019, October 2, 1984

4. letter to N.H. Williams

)

L.H.

(Cygna)Popglewell (TUGCO)l Finding Report Mass Cygna Potentia

. Participation and the Mass Points Spacing Error in Problem AB-1-61A," December 7, 1984

5. N.H. Williams (Cygna) letter to J.B. George O'- (TUGCO), " Phase 3 Open Items - Hass Participation and Mass Point Spacing," 84042.021, February 8, 1 1985

6. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Observation PI-00-05, and PFR-01

- Sunnary: Pipe stress seismic analyses did not include sufficient modes to comply with FSAR requirements. Mass point spacing for dynamic analyses did not always meet project criteria.

Status: Cygna has issued Reference 5 which documents Cygna's eva-luation of the Gibbs & Hill piping reanalysis report and lists recommended actions. Awaiting response from TUGC0/Gibbs & Hill.

2. Incorrect Pipe Schedule Used for Calculation of Nozzle Allowables

Reference:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation PI-02-05 Sunnary: Cygna noted one instance in which nozzle allowables were calculated using an incorrect wall thickness. '

bji@gg Texas Utilities Generating Company i

'byJ L f A Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 11llll111111ll1111111l1111!!ll Job No. 84056 Pol A 85-38 3

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[i,{ 8 : s h ti s f, t PIPE STRESS Open Items and Generic Is w Status: Closed out based on expanded review to include pumps on diesel generator system.

3. Finite Element Model Error in Flued Head Analysis

Reference:

1. Cygna Phase 1 and 2 Final Report TR-83090-01, Revision 0, Observation PI-03-01 Sunmary: The flued head finite element model was found to contain a 9eometry error in which some elements were improperly generated.

Status: Closed based on review of 15 of the remaining 18 flued head analyses

4. Inclusion of Fluid and Insulation Weight at Valves and/or Flanges Cm

Reference:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Observation PI-00-04 and Section 5.1., Page 5-6 Sunmary: Cygr.a found that it was Gibbs & Hill's standard practice not to include fluid and insulation weight at valves and flanges.

Status: Closed based on Gibbs & Hill's reanalysis showing that the effect is minor.

5. Discrepancies in Pipe Support Loads Between Analyses and Support Design

Reference:

1. Cygna Phase 3 Final Report, TR-84042.01, Revision 0, Observation PI-00-06 j

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 29, 1984.

l l Summary: Cygna found that in some instances the latest support loads were not used in the pipe support design calculations.

l Status: Closed.

GffCM Texas Utilities Generating Company 4 y l g Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Hillllllillllllllllilillllill Job No. 84056

. p 3/13/85 j k Revision 0 i}u.Loml Hn i "

PIPE STRESS .

Open Items and Generic Issues

6. Snubbers'on Fisher Valves

References:

1. Cygna Phase 3 Final Report TR-84042-01, Observation PI-00-07 and PFR-02

2. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated July 9,1984

3. L.M. Popplewell (TUGCO) letter to N.H. Williams

. (Cygna) dated August 29, 1984.

Sumnery: The snubbers on the Fisher valve operators not qualified for the as-built loads. This issue led to questioning whether the valve itself was capable of transmitting these loads and

- still naintaining operability.

Status: Closed based on requalification of valves and snubbers.

O

7. Snubbers close to Equipment Nozzles

Reference:

1. Cygna Phase 4 Pipe Stress Walkdown Checklists (not issued)

Sununary: Cygna noted several snubbers on the CCW system which were located close to equipment nozzles. Due to their proximity to a rigid attachment point, the dynamic displacements at these locations will be very small such that the snubbers may not perform their intended function.

Status: Closed with Cygna's recomendation that these snubbers be l

candidates for a snubber elimination program.

i

8. Lack of Traceability for ANSYS/Relap Runs

Reference:

1. Comunication Report between S. Lim (Gibbs & Hill) and L. Weingart (Cygna) dated 3/8/84, 8:45 a.m.

2. Comunication Report between H. Mentel (Gibbs &

Hill) and J. Minichiello (Cygna) dated 3/13/84, 3:00 p.m., Revision 1 BOA =A Texas Utilities Generating Company 3[@TEy Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 1111ll111lllll11111111lllll111 Job No. 84056

1 6.

V w 75 $$ I 3/13/85 Revision 0 g { , .g ;h- Page 4

( ,

PIPE STRESS Open Items and Generic Issues

3. Consnunications Reports between S. Lim (Gibbs &

Hill) and L.Weingart (Cygna) dated 3/15/84, 8:15 a.m.

Susuary: Per reference 1,

" . . . the original RELAP analyses for the Main Steam were run circa 1981-1982. These files were subsequently lost and then re-generated well after the ANSYS analyses which unde use of the RELAP data."

Per reference 3 There are four pr grams involved in the Steam Hansner anal sis:

f RELAP ll GHFORCE - provides imbalance loads

( Program to convert to ANSYS format (4) ANSYS Steve has no concrete documentation linking the four for a particular loop. He will attempt to provide a tape / file list from the day files for these runs.

The list provided by Gibbs & Hill did not provide the needed l cross reference when compared to the ANSYS and RELAP

( analyses. Gibbs & Hill did provide ANSYS plots of loads at axial restraints for comparison to RELAPs plots of forcing functions. This provided sufficient assurance for Cygna to close the issue technically.

Per reference 1, f

i "The binder which is labeled "RELAP Results" f for Loop 2 contains only ANSYS output."

This was further evidence of improper documentation and filing for special analyses at Gibbs & Hill.

Texas Utilities Generating Company NifM93B Comanche Peak Steam Electric Station j }'y l y Independent Assessment Program - All Phases f lilllillifililillfilill!!Illll Job No. 84056

i 3/13/85 l g f1. ! k IN Revision 0 fQb,o NYthk " '

P PIPE STRESS Open Items and Generic Issues Status: Closed technically. Open from a QA standpoint. This issue will be addressed as part of Cygna's Phase 4 design input control review.

9. Inclusion of Support Mass In Pipe Stress' Analysis

References:

1. Communications Report between G. Krishnan (Gibbs &

Hill SSAG) and J. Minichiello (Cygna) dated .

3/19/84, 8:30 a.m.

2. ,Gibbs & Hill letter GTN-68852 dated April 25, 1984

3. Comunications Report between H. Mentel (Gibbs &

Hill), G. Grace (EBASCO), N. Williams and L.

Weingart (Cygna) dated 5/24/84,10:00 a.m.

4. ASLB Hearings, Doyle Questions #4 h 5. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0. Pipe Stress Checklist General Note 1

6. Comunications Report between D. Wade (TUGCO) and N. Williams (Cygna) dated 10/11/84, 4:00 p.m.

7. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

84042.022, dated January 18, 1985 "Open Items Associated with Walsh/Doyle Allegations."

Susuary: The weight of the pipe supports was included in the stress analyses for the Main Steam Inside Containment only. In

. Reference 1, Cygna requested justification for this prac-tice. Gibbs & Hill responded in Reference 2, basically by pointing out the relatively massive supports associated with the pain steam lines.

i However, per Reference 4, the effect of this omission on j support loads was shown to be as high as 24%.

Status: Open. Per Ref. 7 Item 13, further Cygna review is not authorized.

M M1 Texas Utilities Generating Company Comanche Peak Steam Electric Station

( Independent Assessment Program - All Phases j

lilllilllllililillifililllilli Job No. 84056 l

3/13/85 h r.io g rn 1yn$y(

1 fl g,%gy7 M Revision 0

[dgdII'{viUsni, Page 6 PIPE STRESS Open Items and Generic Issues .

10. Stress Intensification Factors (SIFs)

References:

1. Cygna Phase 1 and 2 Report, TR-83090-01, Revision 0, Observation PI-00-01

2. Cygna Phase 3 Report, TR-84042-01, Revision 0, Observation PI-00-01 Suasury: Cygna found numerous instances where G8H either neglected to input the required SIF (Reference 1 & 2) or miscalculated the SIF (Reference 2).

Status: Closed based on expanded reviews.

.q 11. Welded Attachments >

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-00-02, PI-02-03, and PI-02-04.

2. Cygna Phase 3 Report, TR-84042-01, Revision 0, Observations PI-00-02 and PI-06-01 Summary: Cygna found several problems with G&H's treatment of welded attachments:

e Use of an increased allowable in the evaluation of local stresses for upset and emergency combinations (Reference 1).

e Use of thermal expansion loads rather than load ranges for evaluation of local stresses (Reference 1).

• Failure to consider local stresses in break exclusion zones (Reference 2).

e Failure to consider combined effects of two supports at -

a single welded attachment (Reference 2).

• Use of incorrect attachment size in evaluation of local stresses (Reference 1).

Status: Closed based on use of rationale from later codes, recalcu-lations, and expanded reviews.

NNNE Texas Utilities Generating Company A Mg'] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Willlllllllilillllilllllillli Job No. 84056

. h$ . v Page 7 on 0 PIPE STRESS Open Items and Generic Issues

12. Use of Incorrect Pipe Wall Thickness

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-01-01 Summary: Cygna found two piping segments were input to the stress analysis with the incorrect wall thickness.

Status: Isolated; closed based on Cygna recalculation of stresses.

13. Inclusion of Appropriate Responses Spectra

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-02-01 Summary: C na noted that stress analysis AB-1-70 did not consider a the appropriate response spectra from all buildings.

Status: Closed based on evaluation of the omitted spectra and expanded review.

14. Support Location Discrepancy

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-02-02

2. Cygna Phase 3 Report TR-84042-01, Revision 0, Checklist PI-09. Item 14 Sunmary: Supports were modeled at locations outside of tolerance.

Reference 1 as closed based on evaluation of stresses and states that this is isolated.

Status: Closed.

ENib*r Texas Utilities Generating Company Comanche Peak Steam Electric Station

[eg'y , ,

Independent Assessment Program - All Phases lilillilillillilillllittililli i

Job No. 84056 l

t

3/13/85 Revision 0 Page 8 PIPE STRESS Open Items and Generic Issues

15. Use of Incorrect damping in Seismic Analyses

Reference:

1. Cygna Phase 3 Report, TR-84042-01, Revision 0, Observation PI-00-03 Susunry: Cygna noted that G&H did not consider the lower damping response spectra in some systems with mixed sized piping.

Status: Closed based on expanded review.

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' f j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases liffilliffilillifilllil ill Job No. 84056

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$ $ , ;, 3/13/85 Qa ht, l

l Etkulm f8 j % 'k Q j y Revision 0 Page 1 1 '

PIPE SUPPORTS Open Items and Generic Issues

1. Box Frames With 0" Gap

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Box Frames with 0" Gap", 84042.023, dated January 28, 1985

2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84 Item 2

3. letter to N.H. Williams L. M. Poppelwell (Cygna) (TUGCO)1984 dated April 19,

4. 1.. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) Attachment B, dated June 8,1984

5. " Affidavit of John C. Finneran, Jr. Regarding Consideration of Local Displacement and Stress" Sumary: e Original support calculations did not consider the ef-6ex <r "4 Pi ae '#ter ctio" (a r re"ce O < ct < t" 2).

. Later TUGC0 calculations (References 4 and 5) used unconservative temperature and frame stiffness assump-tions.

. Later calculations did not include effects of Cygna comments.

Status: On hold pending TUGC0 response to Reference 1.

2. Design of Welded / Bolted Connections

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Design of Welded / Bolted Ccnnections,"

84042.024, dated January 28, 1985

2. Comunication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/21/84, item 1.c.

3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984

' N.- Texas Utilities Generating Company h(f, Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Nillll11111111111lltlltlll111 Job No. 84056

I -

d ev n0 Page 2 e

PIPE SUPPORTS Open Items and Generic Issues

4. Cygna Phase 3 Final Report TR-84042-01, Revision 0, Observation PS-06 4 Susamry: Cygna found no evidence that welded / bolted connections are designed in accordance with paragraph XVII-2442 of Section III of the ASME B&PV Code.

Status: On hold pending TUGC0 response to Reference 1.

3. Richmond Insert Allowables

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Richmond Insert Allowables and Bending Stresses," 84042.025, dated January 31, 1985

2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/16/84, Item 2

3. Communication Report between Rencher (TUGCO) and O.- Minichiello (Cygna) dated 3/30/84, Item 1

4. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 2,1984

5. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 8,1984

6. Communication Report between Bezkor (Gibbs & Hill) and Minichiello (Cygna) dated 6/12/84, Iten 4

7. " Affidavit of John C. Finneran, Jr., Robert C.

Iotti, and R. Peter Deubler Regarding Design of Richmond Inserts and their Application to Support Design" Summary: Cygna has concerns with the following issues:

• Justification for single insert allowables based on test concrete strength, e Justification for bolt loads due to " axial torsion" of the tube steel.

Texas Utilities Generating Company A[ , Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Nillllllllillllllillllllllll!

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. MI i o 3/13/85 Revision 0 Page 3 PIPE SUPPORTS Open Items and Generic Issues e Interaction results from Strudt analyses.

e Bending stresses in bolts.

Status: On hold pending TUGC0 response to Reference 1.

4 Punching Shear (U-Bolt - Tube Steel Design)

References:

1.

N. H. Williams (TUGCO), " Phase (Cybna) 4 letter to J. B. Georgepen Items - Punchin 84056.053, dated January 31, 1985

2. Comunication Report between Finneran (TUGCO) and Minichiello (Cygna) dated 10/4/84

3. TUGC0 Calculations dated 10/11/84, received by Cygna 10/18/84

4. Comunication Report between Finneran (TUGCO) and

. { Minichtello (Cygna) dated 10/30/84

5. J.B. George (TUGCO) letter to N.H. Williams (Cygna) dated November 8,1984

6. N.H. Williams (Cygna) letter to J.B. George (TUGCO) " Phase 4 Open Items - Punching Shear" 84056.0$8, dated March 12, 1985.

Summary: Cygna has not found evidence of an evaluation of the stresses in the tube steel or coverplate in support MS-1-002-005-$72R near the U-bolt hole. This lack of calculation is typical of this design.

Status: On hold pending TUGC0 response to Reference 1.

5. Mass Participation / Mass Point Spacing

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Mass Participation /Hass Point Spacing,"

94042.021, dated February 8,1985 e

Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Ninilllinilillllulillllll Job No. 84056

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Page 4 PIPE SUPPORTS Open Items and Generic Issues

2. R. E. Ballard (G&H) letter to J. B. George (TUGCO), " Mass Participation," GTN-69454, dated September 14, 1984

3. N. H. Williams (Cygna) letter to J. B. George (TUGCO)," Phase 3OpenItems-Mass Participation " 84042.017, dated September 21, 1984

4. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Phase 3 Open Items - Mass Participa-

, tion," 84042.019, dated October 2,1984

5. L.M. Poppelwell (TUGCO) letter to N. Williams (Cygna), "Cygna Potential Finding Report Mass

• • ' Partic9pation and the Mass Point Spacing Error in

- Problem AB-1-61A," dated December 7,1984 Suseury: Due to the detailed nature of this subject, please see O Reference 1.

Status: On hold pending TUGC0 response to Reference 1.

6. Stability of Pipe Supports

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Stability of Pipe Supports," 84042.035, dated February 19, 1985

2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/20/84, Item 3

3. L. M. Poppelwell (TUGCO)1984 letter to N.H. Williams (Cygna) dated April 19,

4. Comunication Report between Rencher/ Grace (TUGCO) and Minichiello/Wong (Cygna) dated 5/24/84, Item 15

5. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated July 12, 1984 l

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6. Affidavit of John C. Finneran Jr. regarding Sta-bility of Pipe Supports and Piping Systems, dated June 17, 1984

7. Cygna Phase 3 Final Report TR-84042-1, Rev. O, Appendix J General Note 12, and Appendix G, Observation PS-02.

Susuary: The issue of support stability is quite detailed. Please see Reference 1 for a discussion of Cygna's concerns.

7. Cinching of U-Bolts

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cinching of U-Bolts," 84042.036, (to be issued March 18,1985).

h 2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84, Item 5

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984

4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) Attachment C, dated June 8,1984

5. Affidavit of Robert C. Iotti and John C. Finneran, Jr., regarding Cinching Down of U-Bolts (received July 12, 1984)

6. Westinghouse Electric Corp. Report EQ&T-EQT-860 Revision 0, " Comanche Peak Steam Electric Station U-Bolt Support / Pipe Test Program" (received July 12,1984)

7. Westinghouse Electric Corp. Report entitled

" Comanche Peak Steam Electric Station U-Bolt Finite Element Analysis", dated June 12, 1984 (receivedJuly 12,1984) bA Texas Utilities Generating Company Li(d [ 9 Hilllllllitillit!lililllillit Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Job No. 84056

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1 PIEMNARY !a"!O PIPE SUPPORTS Open Items and Generic Issues

8. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "U-Bolt Cinching Test / Analysis Program - ,

Phase 3 Open Item," 84042.015, dated August 23, i 1984 l

9. Transcript of Meeting between Cygna Energy Ser-vices and Texas Utilities Generating Company and  !

Ebasco Services, Inc. dated September 13, 1984

10. R.C. Iotti (Ebasco) let'ter to N.H. Williams (Cygna), " Additional Information as Follow-Up to Meeting of 9/13/84," 3-Z-17 (6.2), ETCY-1, dated

. September 18, 1984

11. letter to J.B. George N.H. Williams (TUGCO), (Cygna)

" Status of C inched U-Bolt Testing and Analysis Program," 84042.018, dated October 1, 1984

12. J.B. George (TUGCO) letter to N.H. Williams O_ (Cygna), " Cinched U-Bolt Testing and Analysis Program - Additional Information," dated November 1, 1984

13. J.B. George (TUGCO) letter to N.H. Williams (Cygna ), Cinched U-Bolt Testing and Analysis Program - Additional Information," dated November 16, 1984 Summary: Please see Reference 1.

Status: On hold pending TUGC0 response to Reference 1.

8. Richmond Insert Allowable Spacing

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/10/84, Item 1

2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/12/84 m.m L9M _I Texas Utilities Generating Company h [d [ fd Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Illilillllililllliittillllilli Job No. 84056

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PIPE SUPPORTS Open Items and Generic Issues Summary: Cygna had asked TUGC0 how the designers ensured the allowables they used were for the correct spacing. TUGC0 had stated that their designers used minimums, unless a walkdown was done. There was no written procedure for this.  ;

While Cygna could not f'nd evidence that this unwritten procedure was not followed, Cygna has no assurance that conservative allowables were always used.

Status: See cable tray generic item 3.

9. Embedment Attachment Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Pipe Support Review Questions," item 5,

- 84056.13, dated July 31, 1984

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams O (Cygna) dated August 24, 1984

3. Communication Report between Purdy (Brown & Root) and Minichiello (Cygna) dated 3/4/85

, 4. Brown & Root Procedure CCP-45, Revision 1, dated 8/18/80

5. Brown & Root Procedure QI-QAP-11.1-28, Revision l

24, dated April 18, 1984 l '

r 6. Brown & Root Procedure QI-QAP-11.1-28 Revision 29, dated January 25, 1985 ,

7. Communication report between Warner (TUGCO) and Williams /Minichiello/Russ (Cygna) dated 2/27/85.

8. CPSES procedure Ql-QP-19.5-1 " Separation Inspection for Unit 1 and Common Buildings."

Sunmary: Cygna has four.d two pipe support base plates welded to embedded plates with less than 12" required spacing between the edges of the support base plates (per Reference 4).

This was not an inspection item at the time of the Cygna review (Reference 5) but is now (Reference 6). Since this

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bd 9 Hilllllllillililllilitilllill Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Job No. 84056

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a I f PIPE SUPPORTS Open Items and Generic Issues affects all hardware attached to embedded plates (HVAC, raceway, and pipe supports), not just a single discipline, and since it was not an inspection item in cther disciplines (per References 7 and 8), this item has generic implication.

Status: Open. Cygna will issue a letter describing this issue and requesting assurance that the spacing requirement has been and will be checked throughout CPSES.

10. Thru-Bolts and Concrete Acceptability

References:

1. Communication Report between Rencher (TUGCO) and

'Minichiello (Cygna) dated 3/30/84, Item 2

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 2,1984

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated June 8,1984, Item 9 and Attachment D 0 Sumery: In thru-bolt designs, Cygna is concerned that the loads on the walls or floors nay not be acceptable. Per Reference 3, there is no written procedure documenting transmittal of loads on concrete structures, although Gibbs & Hill had walked down several highly loaded areas. This does not provide assurance that each area, particularly near free edges, would be acceptable.

Cygna lacks assurance that the designs across the plant are acceptable, since no procedures regarding load transfer exist.

Status: Open for internal Cygna discussion.

11. Bolt Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Pipe Support Review Questions," item 3, 84056.14, dated August 6, 1984

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 I

QM$3 Texas Utilities Generating Company Comanche Peak Steam Electric Station 4 @ l f Aj Independent Assessment Program - All Phases Nilillfillillilifilllifillill Job Ho. 84056

PIPE SUPPORTS Open Items and Generic Issues Susunry: In certain base plate designs in Phase 4 (CC-2-019-715-A43K, for example), the bolt hole is located from the edge of the plate with "1-1/2 MIN TYP." In some cases, this could re-sult in a dimension from 1-1/2 to 3-1/2 inches. While this may have little effect on the bolt load, it does effect the maximum plate stresses by as much as 15% for a strut, spring, or snubber 5" offset.

Status: Open for internal Cygna discussion; Cygna does not require further TUGC0 response at this time.

12. Support Self Weight Excitation During a Dynamic Event

References:

1. Comunication Report between Rencher/Finneran (TUGCO) and Minichiello (Cygna) dated 3/10/84

2. TUGC0 memo CPP-9977

3. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Appendix J. Note 7

4. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

"Open Items Associates with Walsh/Doyle Allega-tions," 84042.022, dated January 18, 1985 Summary: TUGC0 has not considered the loads due to the support dynamic excitation in the design of the support.

Status: Cygna has deferred this issue to the USNRC review, as noted

- in Reference 4, item 14.

j

13. Support Stiffnes's j

i

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Appendix J, Note 8

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

! "Open Items Associated with Walsh/Doyle Alle9a-tions," 84042.022, dated January 18, 1985 UE5&Q ,

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, A. lt k '9 PIPE SUPPORTS Open Items and Generic Issues Susunary: In designing Class 2 and 3 supports, TUGC0 has used a de-flection criteria. At low load, this can result in very flexible supports, which would affect the stress analysis results and redistribute support loads.

Status: Cygna has deferred this issue to the USNRC per Reference 2, item 15.

14. Hydrotest Support / Stress Design

References:

1. Comunication Report between Rencher (TUGCO) and

.Minichiello (Cygna) dated 3/20/84, Item 1

2. L.H. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 with TUGC0 Instruc-

.s tions CP-El-4.0-30 Revision 1 attached

3. D.G. Eisenhut (USNRC) letter to M.D. Spence (TUGCO). Item V.E., dated November 29, 1984 Susunary: Cygna did not find any evidence in either the support design calculations or the pipe stress analyses that hydrostatic loads had been considered. TUGC0 responded with a copy of their procedure.,

Status: Open for internal Cygna discussion.

15. Dynamic Pipe Movements in Support Design

References:

1. Communication report between Wade (TUGCO) and Williams (Cygna) dated 9/28/83, pipe support item 3

1. Communication re Williams (Cygna) port10/4/83, dated between Wade pipe support (TUGCO) item and

• 3

2. Cygna Phase 2 Report TR-83090-01, Revision 1 Observation PS-09-01

3. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/20/84 Item 2 b=55Ng' Texas Utilities Generating Company B'd , Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Nililllilllilillllilllilllill Job No. 84056

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PR,,LIMMY m" PIPE SUPPORTS l

Open items and Generic Issues

4. L.M. Poppelwell (TUGCO) letter to N.W. Williams (Cygna) dated April 19,1984 Summary: TUGC0 does not. include dynamic pipe movement;. in cupport design when checktr.g frame gaps, swing angles, or spring travel. Cygna was concerned this could affect design, but had considered only the seismic ef fects.

Status: Open for internal Cygna discussion.

16. Dual Strut / Snubber Design

References:

1. Communication Report between Pencher (TUGCO) arid Minichiello (Cygna) dated 3/22/84, Item 2.b

2. L.M. Poppelwell letter to N.H. Williams (TUGCO)984 (Cygna) dated June 8,1

3. Cygna Phase 3 Final Report, TR-84042 01, Revision 0, Observation PS-03

4. Cygna Phase 3 Final Report TR-84042-01, Revision 0 Page 5-5.

5. " Affidavit of Robert C. Iotti and John C.

Finneran, Jr., Regarding Consideration of Force Distribution in Axial Restraints"

6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Force Distribution in Axial Restraints -

Phase 3 Open Item" 84042.014, dated August 10, 1984 Sunmary: While most of the discussion on this subject hac been about axial restraints Cygna wishes to twke clear tnat our cen-cern is about all_ types of dual restraint desions (trapezes, double trunnions, riser clamps with shear lug.}, 10GC0 has designed each restraint in these cases to take only 1/2 the total load. Also, Gibbs & Hl)1 stated standard practice in local stress analysis assumes the trunnions share the loa d. Cygna finds this inconsistent With other desf 0n organizations, which usually assume one side takes riore than

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Status: Open pending TUGC0 response to Reference 6.

17. Hilti Bolt Dbedment length References

References:

1. Comunication Report between Wade (TUGCO) and Williams (Cygna) dated 9/28/83, pipe support item '

1

2. ' Communication Report between Wade (TUGCO) and Williams (Cygna) dated 10/4/83, pipe supports item 1

3. Comunication Report between Rencher (TUGCO) and Minichiello (CYGNA) dated 10/6/83, item 1 0 4. Cygna Phase 2 Report TR-83090-01, Revision 1 Observation PS-02-01 Svanary; Embedment lengths shown on the support drawing do not patch those in the support calculation. This is due to the support designer calculating a minimum possible embedment from the bolt length.

Status: Closed.

18. Incorrect Data Transmittal

References:

1. Cygna Phase 2 Report TR-83090-01, Revision 1 Observation PS-10-01 Suapary: The displacement transmitted for support RH-1-064-001-522R had an incorrect sign.

Status: Closed.

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[ h] p , Comanche Peak Steam Electric Station independent Assessment Program - All Phases Niimillillililliittilililli Job No. 84056

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PIPE SUPPORTS Open Items and Generic Issues

19. Incorrect Standard Component Allowables

References:

1. Communication Re Williams (Cygna) port between Wade (TUGCO) anddated 9/2 4

2. Comunication Re Williams (Cygna) dated port Between 10/4/83, pipe Wade support(TUGCO) item and 4

2

3. Cygna Phase 2 Report TR-83090-01, Revision 1, Observation PS-12-01 Summary: The incorrect U-bolt allowables were used in the design of support RH-1-064-011-522R (formerly RH-1-062-002-522R).

. Status: Closed.

h 20. Input Errors in _the design of Suppor_t MS-1-001-006-C72K Comunication Report between Grace CTUACO) and

References:

1.

Minichtello (Cygna) dated 5/22/84, ttem 10

2. L.M. Poppelvell (TUGC01 letter to N.H. Williams (Cygna) dated June 2, h984, item (41)

3. Cygna Phase 2 Re ort TR 84042-01, Revision 0, ,

Observation PS-0 Summary: Errors in section properties and boundary conditions will affect STRUDL results. STRUDL input was neither cnecked nor opproved.

Status: Closed technically. Open for ()A signif tcance.

21. Understred rillet Welos Referencest 1. Comunication Report between Rencher (TUGCO) and Mtnichtello (Cygna) dated 5/16/84, item 5.

2. L.M. Poppelwell (TUGC01 letter to N.H. W1111ams (Cygns) dated June 8, h984, item (31). ^

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Texas tit 111 ties Generating Coripany AAGf (e)Wl , Counche Peak Steam Electric Station Independent Assessment Program - All Phases luilillilittlimitalilit Job No. 84056

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PIPE SUPPORTS Open Items and Generic Issues

3. Cygna Phtse 3 Report TR-84042-01, Revision 0, Observation PS-04. ,

Susumry: Two fillet welds were designed under the minimum required by the ASME B&PV code Table XVil-2452.1-1.

Status: Closed.

22. Improper Weld Calculations for 3 Sided Welds

References:

1. Communication Report between Grace [1UGCO

'Minichiello (Cygna) dated 5/22/84, 9 tem 1) and

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated June 8,1984, item (32)

3. Cygna Phase 3 Report TR-84042-01, Revision 0, Observation PS-05

4. letter to J.B. George N.H. Williams (Cygna)ith (TUGCO) " Box Frames w 0" Gap," 84042.023 dated January 28,1985, item 3 of the Attachment G. N.H. W1111ans (Cygna) letter to J.B. George .

(TUGCO) "Hass Participation and Mass Point Spacing,' 04042.021 dated February 8,1985. Pipe Support Review item 5 Suenary: TUGC0 does not always consider the eccentricity between the enber center of gravity and the weld center of rigidity when determining weld loads.

Status: Closed for the supports reviewed in Phase 3 and 4 (that revision gon1 ). & pen for any revision to the pipe stress analysis which increases 1 cads (such as noted in References 4 and 5).

23. Improper _We_1_df4_culatio_nforCom_cositeSections 1

References:

1. Comunication Report between Finneran LTUGCOD and Williams /Minichiello (Cygna) dated 7/1L/84, ttem 1

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PIPE SUPPORTS Open items and Generic Issues

2. Comunication Report between Finneran (TUGCO) and Minichiello (Cygna) dated 7/11/84 .

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 7/12/84

4. Cygna Phase 3 Report TR-84042-01, Revision 0, Observation PS-07 Susunry: When weldin cover plates to tubesteel or wideflanges to form compos te sections, the design method for the weld is not always correct and all the loads are not always considered.

Status: Closed as far as the Phase 3 review is concerned, but the errors must be corrected if loads increase in later revisions to the stress analysis.

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' 94 = ^ Texas Utilities Generating Company g [ g , Comanche Peak Steam Electric Station Independent Assessment Program - All Phases I -

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CA8LE TRAY Open Items and Generic Issues

1. Conto 111ng Load Case for Design

References:

1. Gibbs & Hill Calculation Binder SCS-101C, Set 5, Sheets 16-20. Revision 5

2. Comunication Report between P. Huang, S. Chang (Gibbs & Hill) and J. Russ and W. Horstman (Cygna) dated 11/13/84

3. Gibbs & Hill Calculation Binder SCS-101C, Set 5 Sheets 1-7, Revision 1

4. CPSES FSAR, Sections 3.8.3 and 3.8.4 Suasury: Gibbs & Hill design calculations Reference 3. assumed that

'c% the design of cable tray supports was governed by the 1/2 SSE seismic event. This was based on a comparison between a 50% increase in seismic accelerations from the 1/2 SSE event at 45 damping the SSE event at 55 damping, and an allowed increase in design stresses of 601 for the, SSE event, per O- Reference 4.

For the design of structural steel members, the 601 increase cannot be applied to certain allowable stresses. Fcr exam-ple, using a 331 increase, allowable stresses for weak axis bending of wide flange beams and bending in base plates, will equal the yield stress. In addition, the allowable loads for concrete anchors (see Generic Issue 3) cannot be heressed by 601 for the SSE event. Neither of the above limitations were considered in the selection of the govern-ing load case for design.

In order to reduce the loads for SSE, Gibbs A Hill elected to use 75 demping for the cable trays at SSE, as allowed for bolted structures.

Status: Gibbs & Hill provided tables of peak spectral accelerations for 1/2 SSE at 41 damping and SSE at 71 damping (Reference 1). The reduced $$E accelerations appear to demonstrate that 1/2 SSE governs for support designs on a generic basis.

However, for supports designed based on the accelerations for a specific building elevation, e.g., elevations 773',

785' and 790' in the Safeguards Butiding, the ratio of SSE to 1/2 $$E exceeds 1.33, the increase allowed for Hilti k i Texas utilities Generating Company Mh6 lilt!!!!!:':":'"!!tillitill 3

Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Job No. 84056

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CABLE TRAY Open Items and Generic Issues expansion anchors (see Generic Issue 3). SSE will poten-tially govern the design of these supports. Support systems at these building elevations are not included in Gibbs &

Hill's dynamic models. Additional review of the supports, at the three elevations indicated above, ney be required.

2. Method of Combination of Seismic Responses

References:

1. CPSES FSAR Section 3.78.2.7

2. Gibbs & Hill Calculation Binder SCS-215C Sets 2-6

3. USNRC Regulatory Guide 1.92, Revision 1

4. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.031, dated 8/31/84

5. Gibbs & Hill calculation response to IAP Phase 2 O- questions, Cygna Technical File 83090.11.2.1.50 Suseury:

A. Closely Spaced Modes (10% Modal Combination) in Spectral Analysis Cygna noted that in the response spectrum analyses performed for the working point deviation study (Reference 2), modal responses were not combined considering closely spaced modes as required by References 1 and 3.

B. Inclusion of Dead Load in SRSS Combination In design calculations, Gibbs & Hill typically included the dead load in the SRSS with the multi-directional seismic loads. This issue was discovered in Phase 2 of this review, and Gibbs & Hill performed a study of the impact of this error (Reference 4). For a detailed discussion of this issue, see Reference 5.

Status: A. Gibbs A Hill has evaluated the working point analyses to account for closely spaced modes in accordance with Reference 3. For discussion of other discrepancies in the working point deviation study, see Generic Issue 14.

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[h@tIli'k7t Page 3 l CABLE TRAY Open Items and Generic Issues B. Quantification of the effects is complete; however, additional discussion may be required.

3. Anchor Bolt Design

References:

1. Gibbs & Hill calculations, evaluation of Detail 1, single bolt etnnection, Cygna 7echnical File 84056.11.1.259

2. Gibbs & Hill Calculation Binder SCS-212C, Set 7, Sheet 4-11. Revision 0 ,

3. Gibbs & Hill calculations, " Justification of the adequacy of 1" Richmond Insert's for the etfects of prying action," Cysna Technical File 84056.11.1.

Sunnery:

A. Additional Tensile Forces Induced by Rotstion of Base Angles About the Centerline of Bolt Pattern.

Gibbs & Hill has. evaluated Alternate Detail 1 and a single anchor base angle using A4 loads (Reference 1). These loads were chosen since the questions of design adequacy criginated from discussion I

of the A4 design. The resolution of this generic issue requires an evaluation of _ the worst case load and grometry. Geometries should include the effects of any generic change notices such as those for the base angle edge distance (CHC 1970) and the use of shims under base plates (CMC 1969).

B. Safety Factor on Hilti Expansion Anchors at SSE Levels.

C. Inconsistent Application of ACI 349-76, Appendix B.

Gibbs & Hill has used the provisions of Reference 1 to qualify several designs. Examples include the qualification of anchorages for Detail "11" (Gibbs & Hill drawing 2323-S-0905) (Reference 2) and the use of code provisions as justification of factors of safety for Richmond Inserts. However, oth2r code sections, such as B.7.3, which requires a factor of safety of 6.0 for single expan-sion anchor connections were not adhered to. Cygna believes that l

the philosophy of codes must be adopted and not specific code seetions.

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CABLE TRAY Open Items and Generic Issues D. Factor of Safety on Richmond Inserts.

E. Richmond Insert Design Allowables.

1. Prying action was not considered in the original design of Richmond Insert connections for cable tray supports. To qualify those connections which utilize Richmond Inserts, Gibbs & Hill performed calculations which reference the results of the Richmond Insert testing program (Reference 3). These calculations showed that the Richmond Inserts were not the controlling anchorage type, but rather that Hilti expansion anchors were. Cygna has the following comments regarding these calculations:

a. The calculations do not account for the instances where the allowable values for Richmond Inserts from Gibbs &

Hill Specification 2323-SS-30 (Ta = Va = 11.5 kips) were

. used without the factor for prying. This situation O ce"id eccer he ever e cac revie ed- aithe=9" ai"",

& Hill has stated that their engineers were instructed i

to include the prying factor, Cygna did not locate any documentation of those instructions.

b. The original design calculations for concrete connec-tions utilizing Richmond Inserts employed allowable values of tension (Ta = 10.1 k) and shear (Va = 9.5 kips). With the issuance of Gibbs & Hill Specification 2323-SS-30, restrictions were placed on the allowable values for Richmond Inserts. These restrictions dealt with the use of Richmond Inserts in cluster arrangements l and show that Richmond Inserts nay be used in spacings less than that originally considered by Gibbs & Hill, but with a corresponding decrease in allowable tensions and shears. Since these restrictions were imposed after the original design of the Richmond Insert connections, Cygna is concerned that they were not properly evaluated

by Gibbs & Hill. In discussions with TUGCO, Cygna was l told that the smaller spacings of Richmond Inserts were for clustered areas that were reserved for whip re-straints. Any use of Richmond Inse^rts in these areas would require authorization from the responsible group and a corresponding evaluation of the installation.

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Texas Utilities Generating Company W[ej l M Comanche Peak Steam Electric Station illlillllll!!'!!!Illllllilill! Independent Assessment Program - All Phases Job No. 84056

, ae CABLE TRAY Open Iteurs and Generic Issues F. Connection Designs.

The cable tray support designs provide for the use of angles or plates at base connections. These designs also provide for various tolerances in the anchor bolt spacings and member placement.

Additionally, field requirements may produce concrete connections wheich are outside the tolerances provided by the designs.

Gibbs & Hill has not fully evaluated the effects of all allowed tolerances on the base member stresses or the anchorages. '

Status: A. Gibbs & Hill is to provide justification for the use of A4 loadings for base plate and anchor loadings.

B. Cygna has collected data on the issue of the Hilti expansion factor of safety and is evaluating it inter-

. nally.

C. TUGC0/Gibbs & Hill are to provide justification for the

'O usage of the Appendix B sections.

D. Cygna has not found sufficient justification for the safety factor of 1.8 for Richmond Inserts for the emer-gency/ faulted conditions. Cygna is presently reviewing the number of tests used to arrive .at this value.

E. Cygna requires verification that controls on the use of

, Richmond Insert allowables and the prying factor were in place and enforced by all responsible groups.

l F. Gibbs & Hill is to provide technical justification for their base plate designs.

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Texas Utilities Generating Company l 3'g;l M Comanche Peak Steara Electric Station l 111lll11111llll1lll111!!!11111 Independent Assessment Program - All Phases Job No. 84056

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! YdN jjf Page 6 CABLE TRAY Open Items and Generic Issues

4. Design of Compression Members,

References:

1. Gibbs & Hill Calculation Binder SCS-101C, Set 1

2. Gibbs & Hill Calculation Binder SCS-215C, Sets 2-6

3. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.022, dated August 17, 1984, question 4 .

Sunumary: In the design of compression members for trapeze type sup-port frames, Gibbs & Hill failed to consider the entire unsupported length of the channels in calculation of their slenderness ratios (Reference 1, Sheets 11 and 18 for sup-port types A 4 and B4 , respectively). If the correct unsup-ported lengths and pinned ends are assumed, the slenderness ratio for these members will exceed 200, the limit for compression members per AISC Specification Section 1.8.4.

h In order to reduce the slenderness ratios below 200, calcu-lations were generated (Reference 1, Sheets 128-146, Revi-sion 3, and Reference 2) which assumed that rotational restraint is provided by the clip angle used to attach the hanger to the bottom of the slab, giving k=0.8. Addition-ally, since the compressive load is appled at several points over the length of the member, the allowable axial stress was increased based on the buckling analysis of columns with distributed axial loads.

Status: Cygna has performed analyses of one and two-bolt clip angles under compressive loading and determined that it is reason-

. able to assume partial rotational fixity for weak axis bending of the attached hanger. The assumption that the tray provides lateral bracing to the frame has not been validated (see Generic Issue 20 for a discussion of tray clamps). Cygna believes that it is acceptable to consider the effective increase in allowable axial loads based on a distributed load application. However, the increase is a function of the applied load, and must be calculated indivi-dually for each support configuration and load case.

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i h I a CABLE TRAY Open Items and Generic Issues

5. Vertical and Transverse Loading on Longitudinal Type Supports

References:

1. Gibbs & Hill Calculation Binder SCS-101C, Set 2

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.025, dated August 21, 1984, questions 3 and 4

3. R.E. Ballard (Gibbs & Hill) letter to N.H.

Williams (Cygna), GTN-69437, dated September 10, 1984, with attached calculations

4. Gibbs & Hill Calculation 3inder SCS-101C, Set 5

• % Summary: In the design of longitudinal trapeze type supports, e.g.,

L-C4, etc., these supports were assumed to act L-A 1

, L.A 4,ly of the transverse supports (see Reference independent 4). Calculations for these supports (Reference 1) consider h only longitudinal loads in the design of frame members and anchor bolts. Since these supports are rigidly connected to the cable trays with " heavy duty clamps", a tributary tray mass wi?1 be associated with these supports. It is Cygna's belief that they must be designed for vertical and trans-verse sejsmic loads just as the transverse supports are (see References 2 and 3). Cygna does not accept the simplified l reasoning which considers only relative stiffness of support types as provided in Reference 3.

Status: Gibbs & Hill is to consider these effects in the dynamic models being run in response to generic issues. In addition to the Gibbs & Hill analysis of selected systems, performed in response to Cygna generic issues, further consideration must be given to isolate the above effects to ensure accept-ability on a generic basis.

D " Texas Utilities Generating Company

%d l fj Comanche Peak Steam Electric Station 1611111111llllllllllll1111llll Independent Assessment Program - All Phases Job No. 84056

PREUMiNARY 5"-

CABLE TRAY Open Items and Generic Issues

6. Differences Between the Installation and the Design / Construction Drawings without Appropriate Documentation

References:

1. Gibbs & Hill, Inc., support layout drawing 2323-El-0713-01-S

2. Brown & Root, Inc., fabrication drawing FSE-00159

3. American Institute of Steel Construction, Inc.,

Manual of Steel Construction, 7th Edition

4. Gibbs & Hill support layout drawing 2323-El-0601-01-S

5. Gibbs & Hill support layout drawing 2323-El-0700-01-S

6. Gibbs & Hill cable tray support design drawings 2323-S-0900 series O Susuary: Cygna performed walkdown inspections on 49 of the 92 sup-ports within the review scope. Certain discrepancies be-tween the as-built support configurations and the design l requirements were as noted below.

A. Support No. 481, Longitudinal Type A4

. Single angles were installed as braces in the longitudinal direc-tion, not pairs which are required by the design drawing. No change documentation was located.

1 B. Support No. 408 Type B4 )

The lower corner of the frame is modified by CMC 9916, Revision 1, to avoid interference with the CCW heat ex* changer. This change shows that 4" channel sections are to be used for the prescribed  :,

1 modification. A 6" channel section is actually installed. l C. Support No. 649 Type At f This installation uses concrete anchorage " Alternate Detail 1" (G&H design drawing 2323-5-0903) which requires the use of an L6x6x3/4.

Cygna's field inspection discovered that an L5x5x3/4 was installed.

No existing documentation accounted for this discrepancy. J i

N Texas Utilities Generating Company

[Mtj l 9 Comanche Peak Steam Electric Station 11111llll11!!I11!!I111111111ll Independent Assessment Program - All Phases Job No. 84056

l CABLE TRAY Open Items and Generic Issues D. Support Nos. 722 and 2606, Detail "N", Drawing 2323-El-0601-01-S Cygna's field inspection found a working point violation on the brace attachment to the wall. Design drawing 2323-S-0929 Connec-gionDetail"F"wasused(2323-5-0903) which has a tolerance of i 0.3b where 12"<bc3g". Cygna's field inspection results show fhe line tolerance with one bolt). used was 7 -(i.e.,

0.5bthe brace was located in E. Support Nos. 2992, 2994, 3005, 3017, 3021, 6654, Type A2 Reference 1 identified the above six supports as follows: "A2 (ex-cept all members shall be MC6x12)," where L = 8'-3" (frame width),

h = 4'-2" (frame height).

The Cygna walkdown results show the installed hanger member sizes are as noted in Table 1, below. Due to the presence of Thermolag coating, Cygna was unable to determine the installed beam member Or size. No documentation existed to reconcile the differences be-tween the design requirements and the installation.

I TABLE 1 Cable Tray Support Member Sizes Dimensions (See Note 1) Member Size

, Flange

! Support Depth Width Existing l No. (In) (In) (Note 1) l 2992 6 1-7/8 C6 x 8.2 2994 6 1-7/8 C6 x 8.2 3005 6 1-7/8 C6 x 8.2 3017 6 1-7/8 C6 x.8.2 3021 6 1-7/8 C6 x 8.2 6654 6 2-1/8 C6 x 13 Note: 1. Dimensions of the vertical channels are based on mea-surements by Cygna. Member sizes are determined by selecting the channel type from Reference 3 which most closely aetches the measured depth and flange width.

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t M bpi[ JL'A Texas Utilities Generating Company Comanche Peak Steam Electric Station 11lllllll111ll1llll1111ll11lll Independent Assessment Program - All Phases Job No. 84056

PR[ lim! NARY E"-

CABLE TRAY ,

Open Items and Generic Issues l 1

l F. Support No. 455, Type SP-8 Cygna's field inspection indicated that the brace connected to the wall on one side of the support is located outside of the bolt pat-tern on the base angle. The "B" (2323-S-0903) connec-tion requires a tolerance off ,gype i 0.2b . Detail TUGC0 issued CMC 99307, Revision 0, to document this Biscrepancy in response to Cygna's question.

G. Support Nos. 2998 and 13080, Special Type Supports These supports were installed in floor slabs with 2" topping. The topping depth was apparently not considered in selecting the length of the anchor bolt. Therefore, the required embedment length was not achieved.

. Status: A. TUGC0 provided CMC 2635, Revision 1, to document the installation discrepancy for support number 481.

~

O 8. TuGC0 arevieed CMC 9918. aevision 2 to decument t*e installation discrepancy for support number 408.

C. TUGC0 provided CHC 99308, Revision 0, to document the installation of the incorrect size base angle for sup-port number 649.

D. TUGC0 provided CMC 99309, Revision 0, to document the anchor bolt installation discrepancy for these two j supports.

l L E. TUGC0 provided the CMC's listed below to document the installation of the incorrect member sizes.

Support Number CMC No. Revision I

2992 44519 2 2994 99326 0 3005 96079 1 3017 99327 0 3021 30452 2 6654 90714 6 3 Texas Utilities Generating Company l [((tj g' M Comanche Peak Steam Electric Station 18111111llllll11111111111111ll Independent Assessment Program - All Phases Job No. 84056 s

c .- 3/13/85 F Revision 8 hyIhtlL.d$M@km-M[=1 ii "'9' 2 CABLE TRAY Open Items and Generic Issues F. TUGC0 provided CMC 99307. Revision 0, to document the installation discrepancy for support number 455.

G. TUGC0 is to evaluate the effect of reduced embedment length for supports 2998 and 13080. Cygna is evaluating the action required by SDAR 80-05 for supports installed after its issuance.

7. Support Frame Out-of-Plane Inertial Loads

References:

None Summary: Cygna has not seen any consideration of out-of-plane iner-tial loads for two-way cable tray supports. Such loads must be considered in the design of any base connections or anchorages as well as the design of longitudinal supports.

assuming that a positive connection exists between the tray and the support.

Status: Gibbs & Hill must provide technical justification for ignor-ing out-of-plane inertial support loads.

8. Design of Angle Sections Neglecting Loading Eccentricity

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.025, dated August 21, 1984, questions 3 and 4

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.027, dated August 27, 1984, question 2 1

3. AISC Specification, 7th Edition, Sections 1.15.2

~

and 1.18.2.4 l

4. Gibbs & Hill calculation " Cable tray support type c

SP-7 with brace. Brace eccentricity calcula-tions." Cygna Technical File 84056.11-1.228 i --

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5. Gibbs & Hill calculation " Verify the adequacy of brace L3x3x3/8 of the governing support Case C3 ." Binder SCS-101C, Set 1, Revision 1 dated 11/16/84

6. Gibbs & Hill calculation " Justify the use of two L3-1/2x3-1/2x3/8 angles to take the appropriate load and moment individually in the longitudinal tray supports at the lower brace." Binder SCS- -

101C, Set 2, Revision 6, dated 9/15/84 Summary:

A. Longitudinal cable tray supports typically use angle sections as bracing to resist the longitudinal loads, e.g., SP-7 with brace, L-A1 , L-A4 etc. loads were assumed to produce only axialFor the member stresses. The design,d induce bending stress due to the eccentric end connection was not considered. Neglecting these flexural stresses can result in members which are under designed.

. {+ , For certain longitudinal supports, double angles are required. The design assumes that the angles behave as a composite member. How-ever, no intermittent filler plates are provided as required by AISC specification Section 1.18.2.4. Thus the double angles must be considered to act independently.

'B. Transverse and longitudinal cable tray supports typically use angle sections as in-plane braces to resist transverse loads and provide 4 4 L-A 4, bracing etc. For the points member on the vertical design, loads members, were assumed e.g., 3A , B3 , B to ,produce A on,ly axial stresses. The induced bending stress due to the eccentric end conditions was not considered. Though it is not explicitly stated in the AISC Specification, standard practice (Reference 3 Sheet 3-59) considers the bending stresses due to end connection eccentricity and checks the interaction ratio considering the principal axis sectin modulii.

C. Single longitudinal braces are typically connected to the frame by welding along the legs of the angle. However, the connections are such that at one end of the angle, only one leg is welded. At the angle's other end, the other leg is welded. Such end conditions may lead to failure by twist buckling.

E ~ Texas Utilities Generating Company BN l M Comanche Peak Steam Electric Station 111111:1111I11lll1111111111111 Independent Assessment Program - All Phases Job No. 84056

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( blLlhisitNft i " 2 CABLE TRAY Open Items and Generic Issues Status: A. Gibbs & Hill provided calculations considering end ec-centricity and independent action of each angle in double angle braces (Reference 6) Case L-B4 was assumed to provide enveloping brace loads. Calculations (Refer-ence 4) were also provided for SP-7 with brace, which has a single angle brace. Cygna believes that the approach is acceptable, but further verification may be needed to determine enveloping cases.

B. Gibbs & Hill provided a calculation (Reference 5) which considered eccentric load application for in-plane-bra ces. The brace loads for Case C3 , from the working point deviation study, were assumed enveloping. See Generic Issue 14 for a discussion of the working point deviation study.

C. Cygna is presently evaluating the possibility of twist-buckling on single angle braces.

9. Dynamic Amolification Factors

References:

1. Later Sumary: 1.14 has been established as an appropriate factor. The support aynamic amplification factor (DAF) study was based on continuous, uniformly supported spans. Current CPSES cable tray support design methodology calculates static loads based on tributary length. Any future use of the 1.14 support DAF nust account for the difference between the tributary support reactions and the support reactions based upon continuous cable tray spans. Further, it ney not be appropriate to use a DAF of 1.14 if supports are designed in the future using non-uniform tributary span length loads.

Status: No further work required. .

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3/13/85 Revision 8

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CABLE TRAY Open Items and Generic Issues

10. Reduction in Channel Section Properties Due to Clamp Bolt Holes

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions," 84056.015, dated August 6,1984, Attachment B, question 2

2. Gibbs & Hill letter GTN-69371, dated 8/23/84, Calculation SCS-111C, Set 8, Sheets 34-39 Summary: Cygna asked about the reduction in channel section proper-ties due to clamp bolt holes in Reference 1. Gibbs & Hill provided a response in Reference 2.

The response fails to consider the following items:

a. Cable trays may be placed anywhere in the beam span (for example, see CMC 2646).

O,: b. The resolution did not consider cantilevered supports where one tray is close to the wall and cther trays are further out.

c. The effect of DCA 17838, which provides bolt hole gage tolerances, is not considered.

d. All unused welded and flange pay beholes areinnot present required high momenttoregions.

be plug-(See Note 15 on Gibbs & Hill drawing 2323-S-0901, Revision 4.)

Status: Gibbs & Hill is to provide technical justification for the solutions.

l l

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[eg'(tj l Comanche Peak Steam Electric Station 18:111tllll111111111111llll11 Independent Assessment Program - All Phases Job No. 84056

PRR!M! NARY 55!- CABLE TRAY Open Items and Generic Issues

11. System Concept of Design Affecting the Following Areas:

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.031, dated August 31, 1984, Attachment A, question 2

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams

 ~

(Cygna), dated September 28, 1984 with attached . calculations Summary: The following items must be addressed with regard to the use of the systems concept: A. Eccentricities between support members and load placement which induces additioinal bending and torsion stresses (References 1 and 2). B. Lateral support for buckling consideration (reference Generic Issue

oO 4).

C. Effective tributary spans for longitudinal supports (reference Generic Issue 5). D. Rotation of base connection angles about bolt pattern axis and the f assumption of semi-fixity for weak axis buckling calculations (reference Generic Issue 3). E. Transfer of out-of-plane seismic inertial loads from two-way sup-port frames to longitudinal supports, (reference Generic Issue 7).

     .            Status:                          Item A was evaluated as part of the dynamic analysis by Gibbs & Hill. The status of Items B through E are found under the referenced generic issues.

N M Texas Utilities Generating Company 4d l ] Comanche Independent Peak Steam Electric Assessment Station Program - All Phases l11ll111llll!I1llll1llllll1111 Job No. 84056

t , a 6 CABLE TRAY Open Items and Generic Issues

12. Design Control

References:

1. Gibbs & Hill drawings 2323-El-0601-01-S, 2323-El-0700-01-S, 2323-El-0713-01-S

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.022, dated August 17, 1984, ques-tions 1, 2, and 6

3. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.025, dated August 21, 1984, question 1

                                     Gibbs & Hill > cable tray support design drawings 4.

2323-S-0900 series

    .,                            5. Gibbs & Hill calculations for support numbers 3025, 3028, 2861, Cygna Technical File 84056.11.1.225

6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), " Responses to Cygna Review Questions,"

dated September 4,1984, with attached calcula-tions

7. Gibbs & Hill Calculation Binder SCS-101C, Set 3 Sheets 206, Revision 6

8. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), " Response to Cygna Design Review Ques-tions," dated September 11,'1984, with attached calculations -

9. Gibbs & Hill Calculation Binder SCS-101C, Set 5

10. Gibbs & Hill Drawing 2323-S-0901, Revision 4

11. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support and Electrical Review Questions," 84056.019, dated August 10, 1984, questions 2.1 and 2.2 N N $55 Texas Utilities Generating Company

[(M l j Comanche Peak Steam Electric Station 181ll11111!!!!Il111lll111ll111 Independent Assessment Program - All Phases Job No. 84056

I4L'gll ar 3/13/85 Q ,9 Jf 5 Revision 8 Pkd1  ; Itki Page 17 CABLE 1 RAY Open Iteers and Generic Issues

12. Gibbs & Hill Drawings 2323-El-0601-01-S, 2323-El-0700-01-S, and 2323-El-0713-01-S Susuary:

A. Lack of consideration of the effects of generic CMC's and DCA's on original designs.

1. Support type SP-7 with brace is affected by CMC 6187. The CVC was approved and design reviewed by Gibbs & Hill, New York, but its effects were not considered in the SP-7 with brace general calculations or any generic reviews.

2. The effect of CMC 1970, which specifies the allowable edge distance of anchor bolt holes in base angles, was not con-sidered in the design of the anchor bolts.

B. Criteria violations in individual support specifications on support plans. In the generic design of cable tray supports, limitations on the support dimension and loading are determined for each support type. These limitations are typically stated in the design calcu-lations, but are not shown on the generic support design drawings, (Reference 4). On the support plans (Reference 1) the dimensions for each support are specified in a descriptive block, and the loading is indicated by the supported tray width shown. The tray supports listed below were identified as having loadings l or support geometries which exceeded the design limitations. No justifying documentaion existed for these individual support de-signs prior to the Cygna review.

1. Support Nos. 3025, 3028, 2861. Type D 1

                                                                                 . Drawing 2323-El-0713-01-S calls out these supports as "03 (except beam to be MC6 x 16.3) L = 11'-9", h = 4 -2", and snows a tray width of 78". The FSE-00159 fabrication drawing sheets reflect these

! dimensions. However, the Gibbs & Hill design calcualtions for Type Di supports (2323-S-0901) limits L < 8'-0" and tray width to 48". b N2 M Texas Utilities Generating Company [(@ [ fj Comanche Peak Steam Electric Station 111111111111!!!I11111111111lll Independent Assessment Program - All Phases Job No. 84056

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2. Support No. 2607. Type A . Drawing 2323-El-0601-01-S spe-1 cifies dimension of L = 2'-9" and h = 4'-6" for this sup-port. The design calculations for this support type (S-0901) limits h < 2'-4".

3. Support No. 657, Type A1 . Drawing 2323-El-0601-01 calls out this support as Type Ai, L = 7'-0 , h = 2'-0". The design calculations for this support type limits L < 6'-0".

4. Support No. 734 Detail H, drawing 2323-El-0601-01-S spe-cifies that one beam is to be on MC6x15.1, rotated 90' from normal orientation. The design for this support requires the use of C6x8.2 sections for beams. CMC 00164 requires the use of " heavy duty clamps" for this support, thus intro-ducing longitudinal loads. The design for this support requires the addition of a longitudinal brace if longitu-dinal loads are to be resisted.

5. Support No. 3011 Type SP-6, drawing 2323-El-0713-01-S specifies dimensions of L = 8'-9" and h = 4'-6". The design calculations for this support type limits L < 6'-0".

6. Support Nos. 2992, 2994, 3005, 3017, 3021, 3111, 6654 Type Ag , drawing 2323-El-0713-01-S specifies dimensions of L =

8 -3" and h = 4'-2", and shows a tray width of 78". The design calculations for this support type limits L < 6'-0" and the tray width to 48".

C. Consideration of as-built support conditions in generic reviews which require a case-by-case review.

I

1. The SP-7 weld underrun analysis considered 5/16" fillet welds which were specified on the design drawings. However, the FSE-00159 fabrication drawings specify smaller weld sizes. In addition, the underrun alaysis did not consider the effects of any changes to the supports which were re-ported in CMC's and DCA s.

2. Working point studies (reference Generic Issue 14). l l

                                                                                                    )

NE Texas Utilities Generating Company [(f; Comanche Peak Steam Electric Station 1816111lllllllll11111111lllll1 Independent Assessment Program - All Phases Job No. 84056 l - . , _ . . __ .- _

CABLE TRAY Open Items and Generic Issues D. Inconsistent application of as-built and design information in the evaluation of cable tray supports for Thermolag application.

1. covers is not included in the allowable The spanweight lengthoftable tray (Procedure CP-El-4.0-49).

2. Longitudinal supports are not evaluated for the added weight of fire protection. The fire protection review did not note the lack of any longitudinal supports in the tray run with Detail N.

3. Fire protection evaluations are performed on tray-by-tray basis. The cumulative effect of multiple trays with fire protection on one support any not be considered.

E. Tray span between supports used in original support layout.

1. Reference 9 indicates that cable tray supports are to be designed for 8'-0" spans. Reference 10, Note 13, allows a location tolerance for supports of

• 1/2 Richmond insert spacing parallel to the tray, and that the maximum spacing netween supports shall not exceed 9'-0". Gibbs & Hill design calculations for cable tray supports assume a maximum tributary span of 8'-6", to account for support layout of 8'-0" on center and an erection tolerance of
• 6". Cygna's

. review of Reference 12 noted 14 locations where the as- ! designed tray spans exceeded 8'-0". Cygna's walkdown of , these tray segments discovered five locations where the as-built tray spans exceeded 9'-0" (see Reference 11). This i indicates that the design and installation limitations for support spacings were not followed.

2. The design of longitudinal supports indicates that the l maximum longitudinal tray span is 40'-0". For several supports within Cygna's review, the support plan drawings (Reference 12) provided supports with tributary spans greater than 40'-0" (see Reference 11). In addition, several horizontal tray segments had no longitudinal sup-ports provided (see Reference 11). This indicates that the design limitations were not followed for the location of longitudinal supports.

i ENfd Texas Utilities Generating Company [(@ [ fj Comanche Peak Steam Electric Station Niilililllillllilllilllllillt Independent Assessment Program - All Phases Job No. 84056

                                          )7"     c '"            y                  3/13/85 "y 2      "% '                   "'" " *

{ f'~. dI ll gN l Page 20 CABLE TRAY Open Itemis and Generic Issues F. Use of "For Reference Only" Calculations Cygna has noted several desgin reviews of change notices where the CVC was parked to indicate that new or revised calculations were not required. Attached to the CMC, however, are calculations that are narked "For Reference Only". G. Cygna is concerned about support design calculation retrievability and completeness. H. Lack of Controlled Design Criteria

1. Cygni has noted instances where the field design review group is not utilizing the proper criteria to evaluate support adequacies. The evaluations for fire protection "

compare the actual load to a design load which is based upon

   .                         a 9'-0" tributary tray span. The maximum tributary span assumed in the current design is 8'-6".

h 2. Cygna has asked what supplements to the 7th Edition of AISC Specifications were connitted to in the FSAR. No evidence was found to indicate that proper direction was given to design engineers to utilize the requirements of any supple-ments that were committed to. Status: A. No further discussion required. B. Gibbs & Hill has indicated that the engineer preparing a support layout drawing would be familiar with the design limitations. Based upon judgement he/she could violate these limitations without preparing supporting calcula-tions since the support nap drawings would be subject to design review. For the individual support listed above: (1) Gibbs & Hill provided calculations (Reference 5) evaluating these supports. Support numbers 3025 and 3028 were found acceptable, support number 2861 shows 30% overload of anchor bolts. (2) TUGC0 provided calculations (Reference 6) demon-strating the acceptability of support number 2607. i E E Texas Utilities Generating Company bd l ] Comanche Peak Steam Electric Station 11lltllll11ll1111111111llll1ll Independent Assessment Program - All Phases Job No. 84056

l I J CABLE TRAY Open Items and Generic Issues (3) TUGC0 provided calculations (Reference 6) demon-strating the acceptability of support number 657. (4) Gibbs & Hill /TUGC0 have not provided a response. (5) Gibbs & Hill provided calculation (Reference 7) I demonstrating the acceptability of support number

 -                                                       3011.                                                   ,

(6) TUGC0 provided calculations (Reference 8) demon-strating the acceptability of these supports. C. No further discussion required. , D. Cygna is continuing internal evaluation. Gibbs & Hill has indicated that the engineer preparing a E. support up drawing would be familiar with the span limitations for transverse and longitudinal supports. Based upon engineering judgement, he/she could violate these limitations without preparing supporting calcula-tions since the support map drawings would be subject to design review. For the individual span violations noted above, t

1. Gibbs & Hill /TUGC0 provided calculations qualifying trays and supports for the transverse span viola-tions.

2. Gibbs & Hill /TUGC0 provided calcualtions qualifying

     -                                                    trays and supports for the longitudinal span viola-tions. For tray segments lacking longitudinal sup-ports, the load was applied as additional trans-verse loads on transverse type supports located around a 90' bend from the unsupported tray seg-ment. For one tray run without any existing mecha-nism to resist longitudinal loads, segments T120SBC25 and T1305CA45, the addition of a new longitudinal support was required.

F. Cygna is continuing internal evaluation. G. Cygna is continuing internal evaluation. H. Cvnna k enntinuina internal evaluation. WW25wM Texas Utilities Generating Company ri-(y L s Jk. yAl Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 18111111111111111ll11111lll1ll Job No. 84056

,                                                                               a   2 CABLE TRAY Open Items and Generic Issues

13. Validty of NASTRAN Models

References:

1. Gibbs & Hill Calculation Binder SCS-215C, Sets 2-6

2. Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheets 234-243, Revision 9 ,

3. Gibbs & Hill Calculation Binder DMI-13C, Set 1 Summary: Cygna has questioned the validity of the NASTRAN models used in the Gibbs & Hill generic studies, e.g., working point deviation study (Reference 1) and the qualification of Detail D1 (References 2 and 3?. The models assume a row of supports of one type, all having identical configuration and spans. This will influence the system frequencies and seismic response. Such models may not be representative of actual installation where a mixture of support types and spans are used.

Status: Further discussion is required as part of the model selec-tion for TUGC0's proposed generic study.

14. Working Point Analysis Study

References:

1. Gibbs & Hill Calculation Binder SCS-215C, Sets 2-6

2. Gibbs & Hill Calculation Binder SCS-216C, Sets 1-5 Susuary:

A. Gibbs & Hill's working point study (Re'ferences 1 and 2) lacks consideration of the effects of change documentation and previously approved design deviations. The cut-off elevations were esta-

• blished using assumed 8'-6" spans, enveloping frame dimensions and maximum permissible working point deviations. Frames above the cut-off elevation were analyzed on a case-by-case basis but did not consider the effects of change notices. Since any one of the above assumed parameters may effect the acceptability of the study, the use of QC's check of working point deviations alone to determine field compatability with the scope of the study will be inadequate.

     ?M1MiliC"5 "N               Texas Utilities Generating Company N        k   1. Comanche Peak Steam Electric Station 1111111111lll1111111111111:;11 Independent Assessment Program - All Phases Job No. 34056

ev s n8 h  !. " ' i LLLLminiid 1 CABLE TRAY Open Items and Generic Issues B. The effects of vertical and transverse loads on longitudinal sup-port frames were not considered in the study (reference Generic Issue 5). C. The longitudinal support portion of the study only checked member intera ction. No evaluation was made to ensure that this component governed. D. Modeling Assumptions

1. Instead of modeling a longitudinal support, the tray run ends'were assumed as fixed. The effects of such a tray boundary fixity on system response was not justified.

2. The analysis assumed a single two-foot tray per beam and did not assess the impact of more realistic multiple tray load-ings.

O 3- ccce tricities (rer reece ae eric >>>=e it)-

4. The assumption of tray attachment fixity was not justified.

5. Selection of run configuration (reference Generic Issue 13).

6. The base angle modeling assumed a simply supported beam for two bolt base connections.

7. Excitation in the longitudinal tray direction was not con-l sidered.

Status: Gibbs & Hill /TUGC0 must justify the use of the modeling assumptions and the use of the analyses results for QC inspections. The concerns discussed above should be con-sidered in Gibbs & Hill dynamic analysis of the five selected cable tray systems. EIN Texas Utilities Generating Company [qh l fj Comanche Peak Steam Electric Station 1111111lltlllllllllllllllll111 Independent Assessment Program - All Phases Job No. 84056

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                                                                                                                                                  "'S* 2' 8
                                                            ]IhEuividh'Srh CABLE TRAY Open Items and Generic Issues

15. Reduced Spectral Accelerations

References:

1. Gibbs & Hill calculations, " Analysis of Alte'rnate Detail 1"

2. Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheet 247 Revision 9

3. Gibbs & Hill Calculation Binder SCS-215C, Set 4 Sussuary: Gibbs & Hill used reduced spectral accelerations based on a calculated support / tray system frequency for the qualifica-tion of the supports discussed below.

A. For transverse supports, such as type A4 which was used in analysis of Alternate Detail 1 (Reference 1) a reduced acceleration is used based on a calculated frequency which is beyond the spectral peak.

           -                       The study assumes a tray weight of 35 psf and tray spans of 8'-6".

Use of the results of this study will not be valid in installations where either of the above parameters have been exceeded without considering the effect on frequency. B. Similarly, for longitudinal supports, e.g., type SP-7 with brace (Reference 3) L-Al (Reference 2), etc., the frequency will decrease due to tray weights exceeding 35 psf or longitudinal spans exceed-ing 40'-0". In addition, the frequency calculations for support types L-A 4 , L-B 4 , etc., did not include the effect of the axial frequency of the tray. l Status: Additional discussion between Cygna and Gibbs & Hill. s

16. Non-Conformance with AISC Specifications

References:

1. AISC Specifications for the Design, Fabrication and Erection of Structural Steel for Buildings, 7th Edition l Sunenary: Gibbs & Hill failed to properly consider the requirements of l Reference 1 as discussed below. ,

i E N = = Texas Utilities Generating Company ' [(@j l fal Comanche Peak Steam Electric Station Nilillililllllllllllilllillli Independent Assessment Program - All Phases l Job No. 84056

po r. rn ~ . , 3/13/85 yr d [ j\  ? Revision 8 - Page 25 fd[ . Ih! ri(nii CABLE TRAY Open Items and Generic Issues A. Unbraced length for axial buckling. .

1. Section 1.8.4 requires that kl/r < 200.

2. Examples where kl/r limitations were exceeded.

a. See Generic Item 4.

b. SP-7 and associated supports are checked for buckling assuming that the tray provides a roller restraint at ,

the tray attachment point, therefore k = 1.0. However, since no restraint can be assumed, k = 2 and kl/r > 257 for a 12" tray. B. Unbraced length for lateral tor $1nal buckling.

1. Section 1.5.1.4.6a requires that Equation 1.5-7 be used to calculate the allowable bending stress for channels. In the denominator, "1" is the unbraced length of the compression flange.

h 2. Examples where the specifications were ignored or improperly applied.

a. The working point analyses use 22 ksi without checking Equation 1.5-7. The frame heights are on the order of 144" which yield an allowable flexural stress of 15 ksi.

b. Detail SP-7 and similar supports consider "1" to be the distance to the tray centerline and not to the outside rail where the load is applied. Use of the larger dis-tance will result in lower allowable bending stresses.

C. Reduction in section due to bolt holes in flange per Section 1.10.1 (see Generic Issue 10). D. Lacing of double angle braces (see Generic Issue 4). E. Eccentric connections - Specification Section 1.15.2.

1. This section requires that any axial members not meeting at a point be designed for the eccentricities.

m M m *1m Texas Utilities Generating Company n=m4W he Comanche Peak Steam Electric Station Independent Assessment Program - All Phases littlltillHillitillllllililli ) Job No. 84056 1

h 3/13/85 pi ri Revision 8 M, -

                                                                              .~., t 5 dl                                       Page 26 P,"",ILL b f.g Q a m)iYhs,t                                                  '

UABLt. IKMT Open Items and Generic Issues

2. Examples of designs where this specification section applies are the gusset plates used for single angle braces, espe-cially type SP-7 with brace.

Status: Further discussion with Gibbs & Hill /TUGC0 required for technical justification.

17. Member Substitution

References:

1. Conference Reports dated 1/17/85, 8:15 a.m. and 3:45 p.m., "Walkdown Response Verification,"

Itissinger and Russ participating Suceery: ,

 .              A.        Note 9 on Gibbs & Hill drawing 2323-S-0901, Revision 4, states:
                                         " Structural members shown on drawing nunbers 2323-5-903
   %                                     series ney be substituted by one step heavier shape of the same size."

Cygna interprets this note as allcwing craf t to interchange struc-tural shapes, e.g., an MC for a C or vice versa, as long as the substantial shape is heavier than, but of the same depth as the original members. This would allow the use of substitute sections which have lower section modul11. TUGC0 has stated that they interpret this note as requiring the craft to stay with the same shape, i.e., a C section can only be substituted by a C section (Reference 1). B. Within Cygna's walkdown scope, support number 6654 (sco Ganeric Issue 6) was reviewed and reflected Cygna's concern as discussed above. The design required an MC6x12 and the installed member as a C6x13 which has a sneller section modulus (S = 5.80 in3 for a Cox13 compared to a $ = 6.24 in3 for an MC6x12). For the other supports listed in Generic Issue 6, the required MC6x12's were substituted with C6x8.2's a substitution not permitted by this

• note.

C. Cygna could not locate any documetnation which requires QC or craf t to note where such substitutions were nede. AL MY g a Texas Utilities Generating Company Comanche Peak Steam Electric Station 411lll111111111111111ll!!il111 Independent Assessment Program - All Phases Jcb No. 84056

A 3 F 3/13/85

f. Y)/ Revision 6 (1Qg Page 27 CABLE TRAY Gpen Items ar.d Generic Issues status: TUGCO/Gibbs & Hill to provide justification of such substi-tutions and the requiremnts for documentation,

18. Weld Size Rquirements

References:

1. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                             " Response to NRC Questions," 83090.023, dated

- March 8,1965 ,

2. Conference Report dated 10/27/84, " Cable Tray Conduit Review Scope," Change, Huang et al. parti-cipating

3. Conference Reporet dated 11/13/bt " Cable Tray Conduit Review Questions," Chang, Huang et al.

pe rticipatihg

4. Ccnference Report dated 11/17/84, " Cable Tray

.h Support Design Review - Weld Sizes " Chang, Huang et al. perticipating

5. Conference Report dated 11/30/84, " Cable Tray Weld Details " Kissinger and Russ participating

6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

84056.041, dated February 12, 1985 Summary: Cygna has discovered the following problems with the weld designs of cable tray supports. A. The design drawings are missing the weld details as described in Reference 1, Attachmen?, C. B. Per discussions with Gibbs & Hill /TUGC0 (References 2, 3, 4 and 5) Cygna has noted that the weld sizes shown on the fabrication draw-ings differ from those shown on the design drawings and those that were assumed in Gibbs & Hill calculations. 4*i Texas Utilities Generating Company (( [ ; g , Comanche Peak Steam Electric Station NI;lllillil!llllilllilllillli Independent Assessment Program - All Phases Job No. 84056

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                                                                    !h S/              3/13/85 Revision 8 1

i P ih as s Page 28 CABLE TRAY Open Items and Generic Issues C. Eccentricities were not considered in weld connections.

1. SP-7 with brace and similar connections requires a partial penetration groove weld at the gusset plate / beam connec-tion. The design calculations did not consider the eccen-tric load application from the brace member. The eccentri-city of the brace loads results in a weld stress in excess of 400 ksi.

2. Weld designs for base angle connections never considered the eccentricities of the applied loads from the connecting mem-bers.

D. The weld designs did not consider the thicknesses of the connected pa r ts. Gibbs & Hill's weld designs assumed the development of full weld throat without considering the thickness of the connected member. E. Gibbs 8 Hill assumed an incorrect minimum weld length for the

     ~

beam / hanger base angle connection.

1. Gibbs & Hill assumed a distance of 1-k, where 1 = angle leg

                                ,     width and k = distance from back of angle leg to end of fillet.

2. Because of the radius of the curve at the angle toe, r (approximately equal to one-half the leg thickness), the actual weld length is 1-k-r.

Status: Open pending response to request per Reference 6. 19 Embedded Plates Design _

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions,"

• 88056.041, dated February 12, 1985, Attachment A, question 1

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19,1984, page 11

3. Conference Report dated 9/15/84, " Response to Cygna Cable Tray and Conduit Questions,* Williams, Russ. Horstren et il particioatino osHwm

              ~~ ~

Texas Utilities Generating Company A Cocunche Peak Steam Electric Station Niilitimt!Illilllitillfill! Independent Assessment Program - All Phases Job No. 8405'

PRR!MjMY  !"!'!!" CABLE TRAY Open Items and Generic Issues

4. Conference Report dated 2/27/85, " Quality Control (QC) Inspections," Warner, Williams, et al. ' parti-cipating Summary: Cygna's review of cable tray attachments to embedded plates indicated that the allowables for the embedded plates nay not have included the effects of prying action (Reference 1). Additionally, questions from Cygna's pipe support reviewers and cable tray reviewers on the stiffening re-quirements for embedded plate moment connections elicited conflicting responses from TUGC0 personnel. One response indicated that attachments to embedded plates act as stiffeners for moment connections (Reference 2) while another indicated that any moment attachment must be stiffened or sufficiently analyzed (Reference 3).

Cygna has also noted that cable tray embedded plate designs were not within the tolerances of Gibbs & Hill Specification 2323-5S-30 " Structural Embedments" (Reference 1). Cygna is also evaluating the lack of attributes for embedded plate inspections on the QC Inspection Report forms as well as the verification procedures for attachment proximity criteria (Reference 4). Status: TUGC0/Gibbs & Hill to provide justification for the above items.

20. Tray Clamps

References:

None Sunnary: The cable trays have been assumed to provide bracing to th? tray supports for the following modes of behavior:

• Buckling of the hanger members.
• Lateral torsional buckling of the beam members
• Bracing of the support frame to prevent frame rotation which would result in anchor bolt over-loa d.

kNNg, A[ Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 16111llIIlI!!ll11111111111111 Job No. 84056

q' - 4 a 3/13/85 Revision 8 Pb,LSIDEudj) l [f . Page 30 CABLE TRAY Open Items and Generic Issues Such bracing may occur only if the tray clamps provide suitable compatability conditions. Status: Cygna is currently evaluating the various clamp designs to establish their capability to provide sufficient load trans-fer.

21. Other Loads in the FSAR Combinations

References:

1. CPSES FSAR, Section 3.8.4.3.3

2. Gibbs & Hill Calculation Binder SCS-103C, Set 1, Sheets 14-19

   .                        3.      Gibbs & Hill Calculation Binder SCS-103C, Set 2, Sheet 32 h         Summary:         Cygna is concerned that all applicable loadings, as defined in Reference 1, are considered in the design of cable tray supports. Among these concerns are LOCA loads. Reference 2
;                           provides the calculations for Detail "A" (Gibbs & Hill drawing 2323-El-3500-01-5) which was originally designed for use in containment. Only dead and seismic loads were con-sidered in this design. Similerly, Reference 3 is the design calculation for Detail "C" (Gibbs & Hill drawing 2323-El-0500-04-5). This support was only evaluated for dead and seismic loads.

Status: Discussion with Gibbs & Hill /TUGC0 is required to establish the exact criteria for ignoring other possible support loadings. i EN555B Texas Utilities Generating Company . [eM l M Comanche Peak Steam Electric Station 18111111111!!!ll11111ll11lll11 Independent Assessment Program - All Phases  ! Job No. 84056

                                                                's  a - et s y             3/13/85

[IQj j!ir Revisimi 0 P i,, ISkkk[fglbk l e #9' CONDUIT SUPPORTS Open Items and Generic Issues

1. Controlling Load Case for Design

References:

1. Cygna discussion with TUGC0 and Gibbs & Hill on 10/1/84 regarding anchor bolts and controlling load cases Suurey:

A. Anchor bolts control the design for most. supports. A factor of safety of 4.0 was used for the OBE loading. SSE loads will reduce the factor of safety. B. Catalog com'ponents are designed for OBE loads. The catalog does not allow an increase in allowables for SSE. Status: Discussion with Gibbs & Hill is required. Also see Cable . Tray Generic Item 1. () 2. Amplification Factor of 1.0 Used for Design of Supports

References:

1. Cygna discussion with Gibbs & Hill on 2/5/85 regarding reference calculations for amplification fa ctor

2. Cygna discussion with Gibbs & Hill on 2/6/85 confirming discussion on 2/5/85

3. Gibbs & Hill Calculation' 2323-SCS-100C, Set 4, Sheets 1-11 Summary: Gibbs & Hill has submitted a calculation for justification of the 1.0 amplification factor. That calculation was based on a Class 5 piping damage study.

Status: Reevaluation of the 1.0 amplification factor is required based on results of the cable tray amplification evaluation (see Cable Tray Generic Item 9).  ; i r m-m - Texas Utilities Generating Company r -- [eg'(tjlf[] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases i 11lll1llll11111111111!!111ll11 I Job No. 84056

a 2 t e CONDUIT SUPPORTS l l Open Items and Generic Issues l

3. Combination of Deadweight and fartnquake in SRSS of Loads / Stress

References:

1. Gibbs & Hill Calculation 2323-SCS-109C, Set 1 Sheets 154-163 Susuary: Deadweight is added to the vertical acceleration, then SRSSed with the horizontal acceleration components.

Status: Gibbs & Hill has submitted calculations for the consideration of vector agnitudes of acceleration for the standard combination method and the SRSS method used in their designs. The unconservatism is small and is conditionally acceptable based on cumulative effects (see Item 24). Also see Cable Tray Generic Item 2.

 .      4.       Heasurement of Embedment from Top of Topping

References:

None O Sunnary: Note Sa on Gibbs & Hill Drawing 2323-S-0910, Sheet G-4a allows reduced embedment for certain supports at lower elevations.

• Support types in Cygna scope affected: CSH-18 Series, CST-17.
• Such a reduction is not acceptable for 1/4" and 3/8" Hilti bolts with 2" embedment requirement (these bolts are embedded in topping only).
• Such a reduction may not be acceptable for other sizes depending on the actual acceleration versus the design acceleration.

Status: Technical justification is required for instances allowed by the note. h~ ' Texas Utilities Generating Company dlQ Comanche Peak Steam Electric Station l Independent Assessment Program - All Phases i ll111llll1lll111111lllllllllll Job No. 84056 I

3/13/85 Fi T" A LPt?- Revisimi 0

                                                        /Nl\           !)5K h.i P( Q                      Page 3
                                                        \                 bbk   ($a E5NbulT SUPPDETS Open Items and Generic Issues

5. Bolt Hole Tolerance and Edge Distance Violation (Gibbs & Hill Drawing 2323-5-0910, Sheet G-lb, Note 15)

References:

1. AISC Specifications, 7th Edition, Section 1.16.5, Minimum Edge Distance

2. AISC Specifications, 7th Edition, Section 1.23.4, Riveted and Bolted Construction - Holes Sunmary:

A. The AISC Code does not provide for bolt hole tolerances. AISC bolt holes are 1/16" larger than the bolt size. Gibbs & Hill allows a tolerance varying with bolt size. B. For oversize holes, the AISC code requires that a minimum clear

• distance be maintained. Gibbs & Hill designs do not provide the minimum edge distances as specified in the AISC code.

 .l )                                  Supports in Cygna scope affected:

• CA-5a : Required edge distance = 25/32"; edge distance provided = 3/4" e CSM-42: Required edge distance = 25/32"; edge distance provided = 3/4" Status: Discussion with Gibbs & Hill is required.

6. Other Loads in the FSAR Combinations

References:

1. CPSES FSAR, Section 3.8.4.3.3 l

Summa ry: Cygna is concerned that all applicable loads were not considered in the conduit support designs. Among those concerns are:

• Applicable LOCA loads in containment.
• Design accelerations do not envelop Containment Building and Internal Structure spectra.

I N$U 5 4 Texas Utilities Generating Company [eg'(ej l f,j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 11111lll11lll11llllllll1111lll Job No. 84056

m '; R 3/13/85 7=

• gRter 1. N $ .jID [.4. tri J Revision 0 I P

                                                      . 5-.  {j        d[(yQ                              Page 4 CONDUIT SUPPORTS Open Items and Generic Issues Status:                Discussion with Gibbs & Hill is required to determine if any justification exists. Also see Cable Tray Generic Item 21.

7. Support Self Weight

References:

1. Cygna Generic Conduit Support Review Sunmary: Cygna's review has noted that support self weights were not uniformly considered as discussed below:

A. Only partia.1 support weight was considered.

• Tube ends are neglected (only length to conduit centerline considered).

 .s
  .

• Brace weight for CSM-6b was not considered.

B. Support self weight was neglected. O e CST-3, CST-17 Unistrut supports. Status: Discussion with Gibbs & Hill is required. This item affects the design of anchor bolts. See cumulative effects, Item

24. Also see Cable Tray Generic Item 7.

8. Torsion of Unistrut Members

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "Cygna Study of Unistrut Torsional Ca pa city," 84056.040, dated January 18, 1985

2. Cygna discussion with TUGC0 on 1/8/85 regarding analysis of P1001C3 members under torsional loads

3. Cygna discussion with Gibbs & Hill on 2/21/85 regarding conduit support testing.

4. Cygna visit to CCL test labs on 2/25/85 to witness Unistrut support tests N$IS Texas Utilities Generating Company (eg'y l Q Comanche Peak Steam Electric Station Independent Assessment Program - All Phases l11lllll111111111111!!lll11111 Job No. 84056

                             - .   . . _       = __..___ _-....__.._. _ _ _ _
                                                                       ;             ts-      3/13/85 M(M  i      j r.j  (i r-Revision 0 4

P HE w hl Page 5 CONDUIT SUPPORTS Open Items and Generic Issues Summary: Torsion of Unistrut members is not considered in support designs. Unistrut does not support the use of members for torsional loading. . Status: TUGC0 and Gibbs & Hill are evaluating the effects of torsion in the Unistrut test program. Cygna personnel visited the CCL test labs on 2/25/85 and provided coments on the test scope and procedures: (1) Worst case support configuration e Member lengths and load negnitudes chosen nay not be the critical case. e Member lengths chosen nay not adequately address torsional behavior of the generic support design.

• Documentation is not readily available to evaluate the criteria used in choosing the test configurations.
• Choice of larger diameter conduits for some supports precludes testing of P2558 clamps, since C708-S clamps are required for large conduits.

(2) Direction of loading to test weak link

• Loading of clamps should induce tensile force in bolts. Many tests load the members in bearing instead of nnximizing clamp load.
• For composite Unistrut sections, loading should provide tensile load on spot welds to test the integrity of the section.

TUGC0 is also reanalyzing some supports per AISI methods. More information is required for evaluation of those analyses. EsinWM23 Texas utiitties senerating Company 3'y l Q Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Hillllllllillitilllll!Ill!!!! Job No. 84056

R 0 d . ' lI f..d ky hh b ifki'[} Q l Page 6 I CONDUIT SUPPORTS Open Items and Generic Issues

9. Improper Use of Catalog Components

References:

1. Cygna discussion with TUGC0 and Gibbs & Hill on 9/20/84 regarding AISI versus AISC usage

2. Cygna discussion with TUGC0 on 10/11/84 regarding AISI versus AISC usage

3. Cygna discussion with Unistrut on 1/21/85 regarding P1941 connector plates

4. Cygna discussion with Unistrut on 2/4/85 regarding Unistrut allowbies and use of P1001C3 members

5. Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37

6. Cygna Generic Conduit Support Review Checklists Sunmary:

Implicit increase in allowables for SSE (see Item 1). A. B. AISC derived allowables are used in the design process. These values are generally conservative for bending, but are mostly unconservative for axial allowables, as catalog allowables are based on the AISI code and consider buckling of thin, open sections. Examples:

• CSH-6b: 20 ksi was used for Fa. which is .6 Fy, where Fy = 33 ksi (for all lengths). Catalog values range from 5.77 ksi for a 5' brace to 13.9 ksi for a 2' brace.
• CST-3: AISC tables were used for Fa, where Fy = 36 ksi. See additional coments for CSM-6b above.
• CST-17: AISC tables were used for Fa. with Fy = 36 ksi; then Fa was reduced by 33/36. See additional coments for CSM-6b above.

LAniUM Texas Utilities Generating Company

   %'y T                            fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Millilllitilllllllllllilll!

Job No. 84056

                                  - - - - -              . ~ . . ..     ....   .     ..
                                                                      .      }      g           a CONDUIT SUPPORTS Open items and Generic Issues C.      Use of components in ways not intended by the vendors.

1. No allowables are given for P1001C3 sections. Member pro-perties are given for X-Y axes instead of principal axes.

Discussion with Unistrut indicates that use of P1001C3 is unique with respect to load application and restraint of the member, such that no gt.neric allowables could be given. Unistrut places the burden on the designer to properly consider the capacity of the section for its intended use.

2. The Unistrut catalog shows use of P1325, P1331 P1332 brackets on single members (pinned connection). Gibbs &

Hill uses two brackets on double members (moment connection, but Gibbs & Hill considers them pinned connections for some brackets in CSM-6b, CST-3, and CST-17). Unistrut does not give allowables for this configuration.

3. Gibbs & Hill references a test C-49 to obtain allowables for

 .                                   the double bracket connection in CST-3. The test only h                                     provided tensile loading on the bracket; therefore, only tensile load was compared to the allowable, ignoring shear.

4. P1941 plate connectors are used to connect headers to outriggers in CA-la and CA-2a supports. Tightening of Unistrut bolts to specified torque overstresses the plate (by analysis), causing excessive bowing. Discussion with Unistrut indicates that these connectors are used to construct frames, such that restraint is provided at the other end of the connected member. On CA-la and CA-2a supports, clarification of this problem is required, as there is conflicting information regarding behavior of,the P1941 plates:

a. In Revision 1 of Gibbs & Hill Drawing 2323-S-0910, Sheet CA-la, Note 7 was added to provide P1064 plates if bend-ing of the P1941 plates occurs.

b. In Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37, a discussion of field installation documents that the P1064 plates do not reduce the bowing of the outriggers.

c. Unistrut tests showed no bowing of the outriggers when the P1064 plates were used. Verification of bolt torques for the test is required.

EE5WS Texas Utilities Generating Company M'y 'i y Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 11ll111111111111lll1lll1111lll Job No. 84056

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3/13/85 9 f I l Rpj $ Revision 0

                                              /    p .        ,j et  es                        Page 8 Er b5!iI L$ls{               Qk l                      h CONDUIT SUPPORTS Open Items and Generic Issues

5. C708-S clamps are not designed for three-directional load-ing. Allowables for tensile loading only are given in the Superstrut Catalog.

Summary: Discussion with TUGC0 and Gibbs & Hill is required.

10. Anchor Bolts

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review

                                            ~ Questions," 84056.015, dated August 6,1984, Question A2b regarding CSD-la Sunmary:

A. A prying factor of 1.5 was used in most cases without justifica-tion. The Teledyne method predicts higher factors for CSM-18d and h B. CSM-18f (rectangular plates). The AISC 8th Edition method was used to omit a prying factor for CSD-2 Detail 8 (U-clips). C. No prying factor was used for CST-17. Type 17 (box bracket). D. No prying factor was used for CSD-1, Detail 2 (Z-clips). This detail is addressed in the Unistrut test program. Status: Discussion with TUGC0 and Gibbs & Hill is required. Also see Cable Tray Generic Item 3.

11. Longitudinal Loads on Transverse Supports l

References:

1. Cygna Generic Conduit Support Review Checklists Suwery:

• Clamps provide restraint in three-directions.

e Some transverse supports ney be on the same order of l stiffness as long cantilever multi-directional supports. l l

• Torsion of transverse supports due to transverse loads may induce some longitudinal loads.

i EMMM Texas Utilities Generating Company

   @y l fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases N1111lllll1111lll1111lllll1l1 l                                 Job No. 84056

I

                                                                    . i~ d 36 f g CONDUIT SUPPORTS                                                  '

Open Items and Generic Issues f Status: Technical justification by Gibbs & Hill is required. 1

12. Substitution of Hilti Bolts

References:

None Sunnary: Note 4 on Gibbs & Hill Drawing 2323-S-0910, Sheet G-4a, , allows substitution of all Hilti Kwik and Super Kwik bolts with those of larger size. A reduction in the allowables for larger bolts nay be necessary due to spacing require-ment!, such that the replacement bolts have lower capacity than the original bolts in the design. Examples:

• CSM-18c: 1/2" Hilti Kwik bolts at 5" spacing were used in the original design. If all 1/2" bolts are

 .h
                                                                                              ~

substituted with 3/4" or 1" bolts, the tensile allowable for the replacement bolts will be less than the design tensile allowable (2750 lbs for 3/4" bolts versus 3012 lbs used in the l design).

• CSH-42: 1" Hilti Super Kwik bolts at 7.5" spacing were Type III used in the original design (allowable tension

                                                                  = 12452 lbs, allowable shear = 6884 lbs).           If all 1" bolts are replaced by 1-1/4" bolts of equal embedment, bolt capacity is signifi-cantly reduced (allowble tension = 6405 lbs,
       .                                                          allowable shear = 6221 lbs).                      ,

Status: Technical justification by Gibbs & Hill is required for supports affected by this note. l l l EWi2 Texas Utilities Generating Company 3'[gJ ' 2' f'j Comanche Peak Steam Electric Station l Independent Assessment Program - All Phases 1111lll11111111lll1llll1lllll1 Job No. 84056

8 3/13/85 QU Revision 0 Ph.]u*m'fkf.;}ei1 ni t in >-

                                                     ~

CONDUIT SUPPORTS Open Items and Generic Issues

13. Substitution of Smaller Conduits on CA-Type Supports

References:

1. Cygna discussion with TUGC0 on 3/7/85 regarding conduit support allowables for fire-protected supports Susamry: CA-type supports are designed using ZPA for large conduits and peak acceleration for sell (<2") conduits. For CA-type supports with capacities tabulated on the drawings, substi-tution of saller conduits is allowed unless specifically prohibited on the drawings. Although the deadweight load of the sell conduits must be less than the capacity, the accelerated load of the sell conduits may exceed the accelerated load of the large conduits used for design.

Example: CA-15 was designed for 2 - 3" conduits with deadweight capacity of 156 lbs. Five 1-1/2" conduits can be installed O,' on a CA-15 support, giving higher accelerated loads than designed for:

• Rigid spaa loads (2 - 3"); 343 lbs,109 lbs e Flexible span loads (5 1/2"); 504 lbs, 450 lbs This item possibly affects CA-6, CA-7, CA-12, CA-14 Series, and CA-16a.

Status: Discussion with TUGC0 and Gibbs & Hill is required. TUGC0 is investigating this item with respect to fire-protected supports. , i N3 Texas Utilities Generating Company h l Q Comnche Independent Peak Steam Program Assessment Electric- All Station Phases lilillllililllllllllllilllllli , Job No. 84056 l i.--- - --

3/13/85

                                                                                               $    i ki CONDUIT SUPPORTS Open Items and Generic Issues

14. Use of CA-Type Supports in LS Spans

References:

1. Cygna discussion with TUGC0 on 2/20/85 regarding QC practices

2. Cygna discussion with TUGC0 on 3/7/85 regarding conduit support allowables for fire-protected supports Susunry: CA-type supports are used to support LA spans, which are limited to 6' length. CST-type and CSft-type supports are used to support LS spans, which can be up to 12' for transverse spans and 24' for longitudinal spans. In field installations, when conduits run from walls to equipment in the middle of a room, transition is nede between LA spans and LS spans. Thus, CA type supports may support LS spans. The concerns are discussed below.

For large diameter conduits (>2"), ZPA was used to calculate the accelerated design load. For tite CA-type support with

     ~

an adjacent suspended support (CST- or CSM-type), the peak acceleration should be used to check support capacity, since rigidity of the transitional span can no longer be guaran-teed. There is evidence that decreased support capacity is considered for the fire-protected supports (see CP-EI-4.0-49), since support capacities are given for both LA spans and LS spans. For unprotected lines, there is no indication that this was considered. Status: TUGC0 is investigating the practice for fire protected supports.

15. Stress in Cable Trays for Attached Conduit Supports l

References:

1. Cygna Generic Conduit Support Review Checklists

                                                              '2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1, Sheets 101-104 Susuary:                             This item applies to CSD-16 in the Cygna review scope and to any similar details. Tray spans are ostensibly designed to the capacity of the tray. Addition of conduit supports to the tray rails adds load above that capacity. Therefore, a ISIh* M Texas Utilities Generating Company
                 }'y l p Comanche                                 Peak Steam Electric Station Independent Assessment Program - All Phases Milllllilittilillllllilllllli Job No. 84056

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                                             \     '                                        3/13/85 LQ          y            Revision 0 fi E               ,

rgj i r, y7) y, ylf Page 12 CONDUIT SUPPORTS Open Items and Generic Issues generic stress check for the trays is not possible, and all tray spans with these conduit supports should be indivi . dually checked. Since the design drawing does not preclude the use of this detail on fire protected trays, and since the conduit support designer is responsible for showing adequacy of the tray for the attached detail, a proper check must be nade for all uses of this detail. Status: Cygna has reviewed the Gibbs & Hill calculation for CSD-

16. Cygna's coments require discussion with Gibbs & Hill.

16. Allowable Span Length Increase from Old S-0910 Package

References:

1. Cygna discussion with Gibbs & Hill on 12/27/84 regarding span increase

2. Gibbs & Hill Calculation 2323-SCS-189C, Set 1 Sheets 15-24 Summary: In the revised S-0910 package, LA span lengths were in-creased by a ratio of the refined to the unrefined spectra.

Status: Gibbs & Hill provided a calcuation to show that the above changes are correct and that rigid spans remain rigid (large diameter conduit). This is adequate for support design, since support loads are proportional to span lengths. Evaluation of conduit stress is required, since conduit bending stress is proportional to the square of the span length.

17. Substitution of Next Heavier Structural Member

References:

None Susunry: This item refers to Note 5 on Gibbs & Hill Drawing 2323 0910 Sheet G-la. Since supports are designed to the limit of the Hilti bolts, and in light of the discussion in Item 7.A., generic designs using structural steel are affected but are not checked. Status: Discussion with Gibbs & Hill is required. See cumulative effects, Item 24. _ EEE7fidfB Texas Utilities Generating Company B'y ' ] Comanche Independent Peak Steam Electric Assessment Program Station

                                                                               - All Phases Willilillllllilill llilllilli Job No. 84056

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I "., Revision 0 Pg")d , g(h')}N Q 'gj{ b,! Q 6) Page 13 CONDUIT SUPPORTS Open Items and Generic Issues l

18. Clamp Usage

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions" 84056.015, dated August 6,1984, Question A4 regarding reaming of P2558 clamps

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Conduit Support Walkdown Questions,"

84056.020, dated August 13, 1984, Question 3 regarding deformed clamps

3. Cygna discussion with Unistrut on 7/25/84 regarding reaming of P2558 clamps

4. Cygna discussion with TUGC0 and Gibbs & Hill on 10/9/84 regarding reaming of P2558 clamps O 5. Cygna Walkdown Checklists Sunmary:

A. For small diameter conduits (<2"), clamps may be reamed to accommodate 3/8" Hilti bolts.

1. The minimum edge distance is violated.

2. Hilti washer for 3/8" bolts will not fit on clamps for small diameter conduits (<2"). The washer is an integral part of the bolt, and justification for its omission is required.

B. In the Cygna walkdown, distortion of clamps for the following supports was noted. Support 10 Support Type C12G93528-8 CSM-18f C12002935-3 CA-Sa C12G03126-18 CSM-42 C12G02851-6 CA-5a Ein%fSB Texas Utilities Generating Company rg'{eJ ' f 3 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lillllillillilil ilililll! Job No. 84056

3/13/85 P.'.y,rg,{gpJ bl$jt

                                                                                   ,i. 5 y p tkt Revision 0 Page 14 CONDUIT SUPPORTS Open Items and Generic Issues Status:              A.I.         Gibbs & Hill has provided calculations; Cygna is reviewing the calculations.

A.2. Discussion with Gibbs & Hill is required. B. Discussion with TUGC0 is required.

19. Documentation /QA Deviations Between IR/ CMC /IN-FP

References:

1. Cygna discussion with Gibbs & Hill on 2/18/85 regarding discrepancies between IR and .IN-fps for C12004695 Sumary: For each line, inspection is performed as documented on the IR. All CMCs, supporting calculations, and IN-FP paterials should reflect the IR.

Examples:

• Line C11003395, IRME-18120F, Su ort -1: On the IR the support is listed as CSM-18f, R ision 4. OnCMC6E903, the support is listed as CSM-18b, Revision 14. From the CMC information, the IR is in error.
• Line C12G-05087, IRitE-16817F, Support -4: On the IR, the support is listed as CSM-18C, Revision 13. On CMC 62905, Revision 0, the support is listed as Revision

9. On CMC 62905, Revision 1, the support is listed as Revision 12.

i ! e Line C12004695, IRME-16089F, IN-FP-216, and IN-FP-226: There are discrepancies between the IR and both IN-FP drawings for support types CA-la and CA-2a. There is no structural difference in supports, but. documentation should be consistent. Status: This item is still in the evolutionary stage. Additional issues will be noted as the review progresses. l l ! ENN! find Texas Utilities Generating Company [e{M l Q Comanche Independent PeakAssessment Steam Electric Station Program - All Phases W11lll1111111lll111llllll!I11 Job No. 84056

0 D ?Ili? l h,jf e s n0

                                                        ^
                                                            ., l       i dhk l CONDUIT SUPPORTS Open Items and Generic Issues

20. Nelson Studs

References:

1. Cygna discussion with Gibbs & Hill on 8/7/84 regarding Nelson stud and conduit clamp issues

2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1 Sheets 131-160

 .                                          3. Gibbs & Hill Calculation 2323-SCS-109C, Set 1             '

Sheets 164-184 Summary: A. Allowables. Allowables used by Gibbs & Hill do not conform to allowables given by TRW/ Nelson. B. Pretension of Nelson studs. Gibbs & Hill calculations use pretension force in the Nelson studs to resist applied loads. The pretension force should consider the flexibility of the shim plate and clamp, as distortion and/or re-laxation in these components will decrease the stud preload. C. Bending of Nelson studs. Filler plates with oversized or slotted holes allow the studs to be loaded at the clamp, applying a shear load eccentric to the weld. Transfer of side-load on the clamp is provided through shear and bending of the Nelson stud rather than pure shear considered in the design. D. Stress in shim plates due to stud welds. Gibbs & Hill provided a calculation to address st'ress in shim plates. Status: A. Justification of allowables used for the Nelson studs is required. B. Evaluation of the actual preload and its effect on the stud capacity is required. Ed$~ HSE Texas Utilities Generating Company b'y l f'} Comanche Peak Steam Electric Station 11111lll1111ll1,1llll11llllll1 Independent Assessment Program - All Phases Job No. 84056 1

                                                                           .,.                                    Pa CONDUIT SUPPORTS Open Items and Generic Issues C.               Evaluation of the Nelson studs for the above situation is required.

D. Cygna has reviewed the calculation and requires technical justification of the following issues regarding the yield line analysis:

• Underrun was not included in consideration of the weld.
• The assumed stress distribution in the fillet weld around the plate is not realistic, as it assumes an infinite stress on the bottom of the plate. A more realistic stress distribution shows that the weld can not provide full fixity of the plate. This
• % should be considered in a revised yield line analysis.

() 21. Configuration of Fire Protection on Conduits

References:

1. Cygna discussion with TUGC0 on 10/16/84 regarding configuration of Thermolag fire-protection on conduits Sumery: Gibbs & Hill fire-protection calculations consider a round configuration of Thermolag sterial around conduits. Weight of Thermolag on the spans was calculated based on this con-figuration. Cygna walkdown shows that a square configura-tion was also used in field installation.

Status: Evaluation by Gibbs & Hill of the as-built configuration with respect to the design configuration is required to insure that the design adequately envelops the field condition. Preliminary evaluation by Cygna indicates sell

• unconservatisms in some cases. See Item 24 for cumulative effects.

V5 'd5 Texas Utilities Generating Company g M l p Comanche Peak Steam Electric Station Nililitilillllillllilllilllll Independent Assessment Program - All Phases Job No. 84056

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                                                                                                 ' 9e 27 n0 CONDUIT SUPPORTS Open Items and Generic Issues

22. Span Increase for Fire-Protected Spans

References:

1. Cygna discussion with TUGC0 on 10/16/84 regarding fire-protection on conduits

2. Cygna discussion with TUGC0 on 10/27/84 regarding fire-protection evaluations

3. TUGC0 Instruction CP-EI-4.0-49

4. Gibbs & Hill Drawing 2323-5-0910, LA Series

5. Gibbs & Hill Drawing 2323-5-0910 LS Series

6. Gibbs & Hill Calculation 2323-SCS-1017, Set 1 Susuary: Many allowable spans for fire-protected conduit runs are longer than allowable spans for unprotected runs.

Cygna has reviewed calculations provided by TUGCO. Addi-Q Status: tional discussion with TUGC0 and Gibbs & Hill is required.

23. Loads on Grouted Penetrations

References:

1. None Sunnary: For straight conduit runs embedded in walls and floors, no longitudinal conduit supports are required if there are no bends in the run. For very long conduit runs, the loads on the grouted penetrations nay be large.

i Status: Technical justification for omission of longitudinal sup-ports on embedded runs with respect to performance of the grouted penetrations is required: o Capability of the grout to resist applied loads should be insured.

• Proper documentation and inspection of grouting should be performed to validate analysis of the penetrations for applied loads.

i

       .#-[l:)B Texas Utilities Generating Company og @ l f j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases (1l11111111lll11111111!! lll Job No. 84056

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                                                                                    , g, ? .i )'Qf            3/13/85 Revision 0 3              q          .7s            Page 18 j l1              SL       15 (

CONDuli SUPPORTS Open Items and Generic Issues

24. C_umulative Effect of Generic Items

References:

None Summary: Small unconservatisms can usually be neglected in design. Since most of the conduit supports are designed to neximum capacity, the cumulative effect of many unconservatisms may be significant. The following items ney have cumulative effects on the conduit designs:

a. Combination of dead weight and earthquake loads (Item 3)

b. Support self weight (Item 7)

c. Substitution of heavier structural members (Item 17)

d. Variance in Thermolag cross-section (Item 21)

Status: Discussion with Gibbs & Hill is required. 1 i bwvid3 Texas Utilities Generating Company [{q l fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lilllllllllllllillllilllililli Job No. 84056

3/13/85 3}_ j f Revision 0 P,ftLLdH!hm i "

• MECHANICAL SYSTEMS Open Items and Generic Issues il l

1. Component Cooling Water System Maximum Temperature

References:

1. Cygna Phase 4 Final Report. TR-84056-01, Revision 0, Observation MS-01-01 (not issued)

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO),

84056.010, dated July 30, 1984

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna),

dated August 11, 1984

4. N.H. Williams (Cygna) letter to J.B. George (TUGCO),

84056.023, dated August 21, 1984

5. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna),

dated April 11, 1984

6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna),

dated October 1, 1984 Sumery: Cygna noted discrepancies between the Westinghouse stated maximum Component Cooling Water (CCW) system temperature of 120*F, the CPSES FSAR, Gibbs & Hill calculation 233-16 and Gibbs & Hill calculation 229-14 which indicated neximums of 121.8'F.135'F and 129.7'F, respectively. TUGC0 provided documentation that showed the acceptability of the 135'F maximum temperature. Some of this documentation is dated as late as 9/28/84 indicating that TUGC0 was not aware of the problem prior to the Cygna questions. Status: Cygna Observation MS-01-01 was closed based on documentation provided. However, when design and operating data is revised, all existing system components should be reviewed to ensure that they meet the new operating conditions.

2. CCW Surge Tank Isolation on High Radiation Signal

References:

1. Cygna Phase 4 Final Report TR-84056-01, Revision

0. Observation MS-06-01 (not issued)

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.028, dated August 27, 1984 ERA?E

         ' " " ~
          ~

Texas Utilities Generating Company Comanche Peak Steam Electric Station i( J k A Independent Assessment Program - All Phases 1111!I1111lllll1lll11ll1111111 Job No. 84056

3/13/85 Revision 0 f ""$ - hLJNiha?h }

• MECHANICAL SYSTDtS Open Items and Generic Issues

3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 20, 1984 Summary: The Westinghouse functional design requirements document for the CCW system required that the surge tank be isolated by closing the vent valve on receipt of a high radiation sig-nal. TUGC0/Gibbs & Hill removed this control function from the system radiation monitors to prevent spurious actuation caused by rising system temperature during accidents. Since the change did not address the radiation release effects of the vent rennining open, Cygna requested verification that the release would be acceptable. TUGC0 performed a calculation which verified that the release was within the limits of 10 CFR 100. No generic review was conducted of other radiation monitor control function changes at CPSES.

Status: Cygna Observation MS-06-01 was closed based on the results - of TUGC0 calculation TNE-CA-094 dated September 19, 1984. h 3. Class 5 Piping

References:

1. Cygna Phase 4 Final Report, TR-84056-01, Revision 0, Observation MS-02-01 (not issued)

2. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984

3. L.M. Poppelwell (10GCO) letter to N.H. Williams (Cygna) dated August 11, 1984

4. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.023, dated August 21, 1984

5. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 11, 1984

6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 21, 1984

7. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 25, 1984 Texas Utilities Generating Company g

{(T dI 7@ 7 k A Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Milllillllllllll!!!!!!illllli Job No. 84056

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                                                  '!,     "'"                t~               ' ''

Revision 0 Pf*t.Ta're'!"M~V rih "* 9-MECHANICAL SYSTEMS Open Items and Generic Issues

8. N.H. Williams (Cygna) letter to V. Noonan (USNRC) "Open 1 Items Associated with Walsh/Doyle Allegations," l 84042.022, dated January 18, 1985.

Susamry: The definition of Class 5 piping design and analysis re-quirements are not clearly presented by TUGCO. Per Gibbs & Hill, Class 5 piping is not seismically designed; it is only seismically supported to prevent it from falling on safety related equipment. TUGC0 did provide documentation showing that the specific Class 5 CCW piping that was in Cygna's ' review scope was seismically analyzed and therefore, would remain functional as required. However, Cygna could not determine whether any similar circumstances exist in other piping systems where Class 5 piping ney be required to remain functional during a seismic event. Status: Observation MS-02-01 was closed for the CCW system based on the documentation and analyses provided. Cygna has nut been authorized to investigate the generic implications of this

• issue for other piping systems.

 .O 4          Fire Doors

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984

2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984

! 3. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.023, dated August 21, 1984 1

4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated AJgust 31, 1984 Sunmary: Cygna noted that the double doors between the train A & B nuclear chillers did not have a U.L. fire rating label.

TUGC0 stated that this had been previously noted by them and that the proper door was being installed. TUGC0 could not provide documentation of how the error was noted but did supply copies of a purchase order for the correct door. Reinspection by Cygna verified the proper door was in-stalled. TUGC0 stated that no NCR cr other paper work was

          =._-W1.g Texas Utilities Generating Company                                                          *
                 ~T                  Comanche Peak Steam Electric Station L               6 IAI Independent Assessment Program - All Phases Hillllllllilllllllilillilllli Job No. 84056

I 3/13/85 Revision 0

                                                    ."c 8*ff?

i('i s f , ,1 i' TJ f b 9h Page 4 PP. k ["da k It p tl - RLCHANICAL 3T31tFD Open Items and Generic Issues a initiated since the door is not safety related. The door is required to meet Appendix R requirements and as such should be considered important to safety. Documentation and in-spection trail is in question. Status: Open for internal Cygna discussion.

5. Single Failure - Reactor Coolant Pump Thermal Barrier

References:

1. Cygna Phase 4 Final Report TR-84056-01, Revision 0, Observation MS-02-02 (not issued)

2. Cygna Phase 4 Final Report. TR-84056-01, Revision

0. Potential Finding PFR-01 (not issued)

 *                               3. N.H. Williams (Cygna) letter to J.8. George
  -                                      (TUGCO),84056.010, dated July 30, 1984

4. L.M. Poppelwell (TUGCO) letter to N.H. Williams h (Cygna) dated August 24, 1984 D.H. Wade (TUGCO) letter to N.H. Willians (Cygna),

5. CPPA-40961, dated September 18, 1984

6. D.H.. Wade (TUGCO) letter to N.H. Williams (Cygna),

CPPA-41237, dated October 3,1984

7. N.H. Williams (Cygna) letter to S. Burwell ,

(USNRC),84056.032, dated October 9,1984

8. N.H. Williams (Cygna) letter to S. Burwell (USNRC),84056.035, dated October 22, 1984

9. E.P. Rahe, Jr. (Westinghouse) letter to R.C.

DeYeung (USNRCl, NS-EPR-2938, dated July 13, 1984

10. T.R. Puryear (Westinghouse) letter to J.T.

Merritt, Jr. (TUGCO), WPT-7436, dated July 23, i 1984 , l Cygna expressed a concern that if the single temperature Sumury: controlled isolation valve on the outlet of the reactor coolant puq thermal barrier should fail to close subsequent Texas Utilities Generating Company

       -r~

Comanche Peak Steam Electric Station id a Independent Assessment Program - All Phases N1111111111111111111H1111111 Job No. 84056

3/13/85 Revision 0 I' d'ij ,M Page 5 P*llE83'k7t'. ya b h U"k *f MECHANltAWM tm Open Items and Generic Issues to a rupture of the thermal barrier, then low pressure portions of the CCW system would be over pressurized and reactor coolant could be released outside containment. Westinghouse also notified the NRC and TUGC0 of'a similar problem with CCW systems they designed. TUGC0 informed Cygna that they were filing a 50.55E report with the NRC on this issue and that they would investigate the generic implications of this finding. Cygna submitted two letters on this subject to the NRC and TUGC0 in accordance with our review procedures for a Definite Potential Finding. Cygna has not received any of the TUGC0 documents used to evaluate this issue nor has Cygna performed any additional investiga-s tion or review on this issue. Status: Observation MS-02-02 was upgraded to Potential Finding PFR-01 and closed via the TUGC0 comitment and Cygna's NRC notification. O l t r _ ;~~; V Texas Utilities Generating Company

                   >3 Li L I[ Comanche Peak Steam Electric StationIndependent Assessment Program PW'i l     leililitilllilllillililittlill Job No. 84056 l

[

3/13/85 70 II'. ! &&ED'y Revision 0 m . l( ( * *s ELECTRICAL SYSTEMS Open Itsers and Generic Issues

1. Instrumentation Pressure / Temperature Ratings

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984

2. L.M. Poppelwell (TUGCO) letter to N.H. W1111ans (Cygna) dated August 11, 1984 Sussury: Two instantes were noted by Cygna wntre the pressure tem-perature ratings for it.struments installed in the CCW system were lower than the eximum prer,sure or temperature of system as indicated in Gibbs & Hill analyses. The instru-ments in question were later shown to be qualified for the higher design conditions or protected by interlocks, The generic implications of these oversights were not investi-gated. -

Status: When design and operating data is revised 31) existing i system components should be reviewed to ensure that they ' meet the new operating conditions.

2. table Tray Thermo lag Fire Protection

References:

1. N.H. Williams (Cygna) letter to J.D. George (TUGCO). 24056.010, dated July 30, 1984

2. L.M. Popplewell (1UGCO) letter to N.H. Williams (Cygna) tisted August 11, 1984

3. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.024 dated August 21, 1964 4 L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna ) dated September 4,1984 Sumury: During the Cygna welkdown of July 16-20, 1984, it was notea that cable tray section T130ACA43 was not covered witn thermo lag fire protection mterial. Cygna reinspected the '

area in August / September and the proper noterial was installed. However, the documentation supplied by TUGC0 f or  ; tne removal and reinstallation of the fire lag insulation ' indicates that the work was completed and signets off on 7/14/84. This is prior to the Cygna walkdown. While the f1;< ~~ "1 Texas Utilities Generating Company p Comanche Peak Steam Electric Station L L 6 6 Independent Assessment Program - All Phases N1h11111ll11lll1111111111111 Job No. 84056

1

                                                                              * [a, ? 7. i ~ 7 f   3/13/85 Revision 0 ga j $

P [7tt Er. . . j gE{ II '..$11()g I k!(: s Page 2 ELECTRICAL SYSTEMS Open items and Generic Issues reinspection showed the tray to be properly covered, the documentation is not consistent with the noted sequence of events. Status: Open for internal Cygna discussion only. O l Texas utilities Generating Company L ' "" f..- Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 6 a meillillitillitilittlilllill Job No. 84056

3/13/85 f' h- /j $. ft y {j Revision 0 t.. - 3 d b. u o Page 1 DESIGN CONTROL Open Items and Generic issues

1. . Review and Analysis of Cumulative Effects

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections

2. Cygna Phase 3 Final Report. TR-84042-01, Revision 1, all Sections

3. N. H. Williams (Cygna) . letter to V. Noonan (USNRC), "Open Items Associated with Walsh/Coyle Allegations," 84042.022, dated January 18, 1985

4. N. H. Williams (Cygna) letter to V. Noonan ,

(USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985

5. All Communication Reports and correspondence l written on all Phases of the Independent Assess-ment Program Summary: Given the data available from all four phases of the Cygna <

technical and design control reviews, a cumulative effects evaluation of all observations and potential finding reports is being performed. This review will also focus on the cumulative effects of individually insignificant discre-pancies. Any trends identified which indicate either strengths or weaknesses in the CPSES design / design control program will be evaluated. < Status: Cygna is in the )rocess of extracting raw data from all phases of the IA) performed to date. The results of this review will be included in the Phase 4 Final Report.

2. Adequacy of the Design Process used on CPSES

References:

1. Memorandum and Order (Quality Assurance for Design). Texas Utilities Generating Company, et al., Comanche Peak Steam Electric Station Units 1 and 2, dated December 28, 1983 b MB Texas Utilities Generating Company

[e[Q' M Comanche Peak Steam Electric Station 111111111111.:llllllll11111111 Independent Assessment Program - All Phases Job No. 84056

Pa

                                                    .            11 DESIGN CONTROL Open Itess and Generic Issues

2. CASE's /et ton for Sumary Disposition,

                                      " Allegations Concerning Quality Assurance Program for Design of Piping and Pipe Supports," dated July 3, 1984

3. Cygna Phase 1 and 2 Final Report TR-83090-01 Revision 0, all Sections

4. Cygna Phase 3 Final Report, TR-84042-01, Revision .

1, all Sections

5. N.H. Williams

                                      " Status   of IAP(Cygna)  letter to V. Noonan  (USNRC),

Conclusions," 84056.050, dated January 25, 1985 6, All Comunication Reports and correspondence written on all Phases of the Independent Assessment Program .h Sveary: Based on the Phase 1 through 4 review scopes. Cygna is evaluating the adequacy of the process employed in the design of Comanche Peak Steam Electric Station. This review will also include an assessment of the resulting quality of the final design. I Status: This evaluation is ongoing in conjunction with the cumula-tive effects review. The results of this review will be included in the Phase 4 Final Report.

3. Qualification and Training of Design Engineers

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090 01, Revision 0, all Sections

2. Cygna Phase 3 Final Report TR-84042-01, Revision 1, all Sections

3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 hh5

[eQ , , Texas Utilities Generating Company Comanche Peak Steam Electric Station nelmmmmilimi!stml Independent Assessment Program - All Phases Job No. 84056

3/13/85 l!Y j

            -                                                        p u T git C oltTR ot-Open Items and Generic Issues

4. All Comunication Reports and correspondence written on all Phases of the Irdependent Assessment Program Susunry: Assess the root cause of all discrepancies and observations to determine whether or not a trend exists which indicates any weakness in the training / qualifications of the design engineers.

Status: This issue is being addressed in conjunction with the cumulative effects evaluation. Results will be provided in the Phase 4 Final Report.

4. Control of Design Interfaces

e. ,

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections

() 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections

3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 4 All Comunication Reports and correspondence written on all Phases of the Independent Assessment Program Susamry: Assess the adequacy of the interfaces as a result of trending whicn was performed on Phase 1 through 4 observations. The results of this review will be provided in the Phase 4 Final Report.

Status: This issue is being addressed in conjunction with the . cumulative ef fects evaluation.

5. Adequacy of Procedures

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections I_m, m Texas Utilities Generating Company N'[ , Comanche Peak Steam Electric Station ssessment Program - All Phases lillilililitilliitillilllilill j"of'lend a

3/13/85

                                                                !        $,      f,         Revision 0 P(G?.=g 5

i.5 . . C ) i G (u h' Page 4 DESIGN CONTROL Open Items and Generic Issues

2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections

3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985

4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Summary: The adequacy of and compliance with procedures for the CPSES project is being reviewed as a result of the initial trending of observations in Phases 1 through 4. The results of this review will be provided in the Phase 4 Final Report.

   .          Status:                   This issue is being addressed in conjunction with the cumulative effects evaluation.

G 6. Adequacy of Design Documentation

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections

2. Cygna Phase 3 Final Report, 1R-84042-01, Revision 1, all Sections -

3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985

4. All Comunication Reports and correspondence written on all Phases of the Independent Assessment Program Sunuary: The adequac'y of design documentation is being evaluated as a result of the usage of undocumented assumptions and inadequate references which were identified during the IAP technical reviews. The results of this review will be provided in the Phase 4 Firal Report.

l Status: This issue is being addressed in conjunction with the I cumulative effects evaluation.

(

MM2*N Texas Utilities Generating Company 3'y l y Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 1111111ll11llll!!!!!!!!!!!!!!! Job No. 84056 I

l h ft [h#  ! 3/13/85 ILMhihNni ":;M " DESIGN CONTROL Open Items and Generic Issues

7. Corrective Action as it Pertains to Design Related Issues Identified to Date

Reference:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections

2. Cygna Phase 3 Final Report TR-84042-01, Revision 1, all Sections

3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985

4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Susuary: An evaluation of whether or not the issues identified by

{d Cygna on all phases of the IAP should have been detected by TUGC0 through the corrective action system. The results of this review will be provided in the Phase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. l 8. Document Control ) l

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observations DC-01-01, DC-01-02 and DC-01-03.

2. N.H. Williams (Cygna) letter to S. Burwell (USNRC)

                                             "DCC Satellite Review Results," 83090.013, dated June 30, 1984

3. letter to V. Noonan N. H. Williams (USNRC) (Cygna)P

                                                        " Status      of IA Conclusions," 84056.050, dated January 25, 1985 N53                           Texas Utilities Generating Company qlM              Comanche Peak Steam Electric Station Independent Assessment Program - All Phases N1lll!I11llllll111111llll1111 Job No. 84056

i [ f. 0 E 3/13/85 p p' h fiEh'b t2il!Y 35 7 , b i G t fis'i lTPage ci 9 [6 T[]j f.h h N Revision 0 DESIGN CONTROL Open Items and Generic Issues Sumery: Observations concerning the Document Control Center (DCC) and control of design documents were written in Phase 1 and

2. Reference 2 was issued to document the adequacy of current DCC practices. Assessment is still required to evaluate the effects of technical and design control deficiencies which could be attributed to inadequate controls in the DCC. The results of this review will be provided in the Phase 4 Final Report.

Status: This issue is being addressed in conjunction with the cumulative effects evaluation.

9. Design Change Tracking Grouc

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation DC-01-04.

      .                                 2. N.H. Williams (Cygna) letter to S. Burwell (USNRC)
                                             "DCTG Data Base Review Results," 83090.017, dated November 6, 1984 Sumary:              The Field Design Change and Review Status Log was reviewed ard Observation DC-01-04 was initiated during Phases 1 and

2. The effects of inadequate controls on design changes are being reevaluated to determine any possible effects on the design.

Status: This issue is closed except for input to the cumulative effects review.

10. G8H Design Input References

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation DC-02-01 -

2. N. H. Williams (Cygns) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Summary: A Gibbs & Hill design specification required a different edition of ASME Section III than a computer code (ADLPIPE Version 2c) used for piping calculations.

4 E15EM Texas Utilities Generating Company

        @'y i] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases N1111lll11111111lllll!!Illl Job No. 84056

PlRIMiNARY E?- DESIGN CONTROL Open Items and Generic Issues Status: This Observation is considered closed except for review , l during the cumulative effects review.

11. Inspection Reports

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-01-01,

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                                                                       " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Susanary:                                                                Three inspection reports had been filed in the permanent plant records vault prior to closure.

Status: This Observation is closed except for input to the cumulative effects review. 0 12. TUGC0 Audits

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observations DC-01-02 and DC-01-03

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                                         -                             " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Sumery:                                                               TUGC0 Audit files did not contain corrective action responses for selected audit findings.

Status: These Observations are closed except for input to the cumulative effects review. l 13. Gibbs & Hill Internal Surveillances

References:

1. Cygna Phase 3 Final Report, TR-84042-01 Retision 1, Observation DC-02-01

( E1N7S Texas Utilities Generating Company f g'y l p Comanche Peak Steain Electric Station Independent Assessment Program - All Phases Milill!ililllilillittillilill Job No. 84056

                                                 ..:=:..                 ..   .

6 vs n0 Page 8 DESIGN CONTROL Open Items and Generic Issues i l l

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                       " Status of IAP Conclusions," 84056.050, dated January 25, 1985                                          )

Sunmary: Documentation which verified surveillance activities had been performed for 1973 through 1977 was not imediately obtained. Status: This Observation is closed except for input to the ' cumulative effects review.

14. Gibbs & Hill Management Reviews

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-02

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                       " Status of IAP Conclusions," 84056.050, dated
'-                                                     January 25, 1985 Sunmary:            Gibbs & Hill nanagement Review Evaluation Reports were not available for 1974 through 1976.

Status: This Observation is closed except for input to the cumulative effects review.

15. Gibbs & Hill Audit Corrective Actions

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision

                 -                                     1, Observation DC-02-03

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                        " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Sunmary:            Gibbs & Hill had renumbered an audit finding and not closed the original finding.

Status: This is closed. t EE -- Texas Utilities Generating Company

                   @'y i y Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Illiiiiiiiiiiiiiiiiiiiiiiii Job No. 84056

                                                                             .*,I                3/13/85 i

I,sm.1= f D e b k gf,, $1 g Revision 0 Page 9 I DESIGN CONTROL Open Items and Generic Issues

16. Evaluation of Gibbs & Hill Design Reviewers

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-04

2. N.H. Williams (Cygna) letter to V. Noonan (USNRC),

                                                  " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Summary:                   Gibbs & Hill deisgn reviewers were not evaluated on an annual basis as required.

Status: This Observation is closed except for input to the cumulative effects review. ..s O i En- - Texas Utilities Generating Company 3'(',J'f&j )L Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Niilllilllillllilillillllilli Job No. 84056

r AGENDA

1. Project Organization and Staffing Noonan Project Schedule. Noonan Anticipated Panel Product Noonan -

2. Test Programs Keimig/Sm'ith

3. Electrical / Instrumentation Area Calvo/Marinos

4. Pipe Support Design Fair-

5. Civil Structural .Shao/Jeng Mechanical / Piping- Sh'ao/Hou

6. Status of Data Collection Test Fisher /Materson

    .          Results of TRT meetings'with licensee     Sh'ao/Masterson l

7. Quality Assurance / Quality Control Livermore/ Hale C-5 Panel Schedule and Assignme~nts Panel

                                                                                          ~

8. Hearing Summary Treby.

O I FotA 85'3l3

9

                        ,                      Comanche Peak Contention 5 Panel
      .s Meeting Summary 4

The Contention 5 Panel met on 1/23/85' from 11:00 a.m. to 5:00 p.m. and 1/24/85 from 8:30 a.m. to 5:00 p.m. Attendi.ng were: ) Panel Members Advisors Presenters R. Vollmer, NRR V. Noonan, NRR D. Hunter, RIV . R. Warnick, RIII J. Scinto, ELD H. Livermore, P.II'I A. Herdt, RII C. Poslusny, NRR C. Hale, RIV J. Sniezek, EDO T. Sullivan, NRR B. Griffin, RIV A. Thadoni,~NRR B. Kaplan, EG&G J. Durr, RI*

E.' Jordan, IE A .- Panel Activities P1'anned The Enclosure 1 panel agenda was agreed upon and corrections were made to the 1/16-17/85 meeting summary. The schedule (Enclosure 2) was revised _

l- but the impact of an announcemen't of construction extension by the applicant could not be assessed without further information. s [ Personnel accompanying the panel on the Texas trip are identified below:

 .                               2/5 Site Tour             2'7
                                                            / Meeting with Intervenor/Licenssee V. Noonan                 J Scinto C. Poslusny               V. Noonan T. Sullivan               C. Poslusny S. Burwell                T. Sullivan D. Terao                  S. Burwell

15. 'Phillips A. Vietti M.'Eli

• By telephone conference call

8 The panel discussed preparations for meeting with the intervenors and the applicant. Mr. Jordan-agreed to provide draft opening remarks.(Enclosure 3)perthepanelssuggsstions. The ensuing discussion identified the.need for revising the .cha~ r ter of , the panel. Mr. Sniezek ' agreed to draft a revision ofi the. charter. B. Method of Review The draft questionnaire-for reviewers prepared by Mr. Warnickt was discussed and was found to contain much of the same information as on the proposed data sheet plus a provision for' comments by the reviewer. :The data sheet was modified to provide a space ifor comments therefoie. no separate form is needed. The data sheet continues to evolve and Mr. Fisher was instructed to continue his efforts with a trial and setting up the computer program to sort the data per the 1/16-17/85 meeting sumary. C. Discussion with Intimidation Pan'el l A discussion was held with Jane Axelrad, Jim Lieberman and Jim Gagliardo to coordinate the two panel activities. The Intimidation Panel indicated l they would not be ready for a discussion until 2/13/85 due to the large volume of material involved. The Contention 5 Panel stated that they need l a position on the existence of a climate of intimidation and on its materiality with respect to safety-related activities. i

       . D. Summary of NDE Van Activities (Jordan)

m E. Sumary of Inspection and Enforcement . . B (Hunter) F. Summary of Document Control'

,                                                                          I (Enclosure 4) 1 i

e 4 m O t e 4 9

e

                                                                                   ~ Enclosure 1 1/30/85 AGENDA 5

1. Review 1/23 meeting summary

2. 8:30-10:00 Discussion of'0I Reports with Fortuna f

3. 10:00-10:30 Meet with Eisenhut on revised Charter,'prepara'tions for site trip

4. 10:30-2:30 Discussion of TRT Civil / Structural / Mechan'ical with!Shao

5. 2:30-3:00 Meet with Dircks on revised Charter, discussion of activities

6. 3:00-5:00 Preparations for site meeting

a. Identify plant areas to review

b. Establish regional meeting agenda

c. Review plans for meeting with intervenor and with applicant _

Wde O l l l

I - EnclesurE2L

                                                                        ~
                                                . Conte'ntion 5 Panel Schedule                                                  -
                                                       ~ Panel                January                           February Reviewer        16 17 23 24 30            5 6 7 8 11       13 15 18 22 25 2r Intrtduction to QA/QC issues          (Livermore)

CYGNA presentation iShulman) Devalepment of schedule I; Panel) CAT prssentation (Heishman)~ (Herdt) Read R:ferences (Panel) TRT electrical (Calvo) -(Jordan) RII special inspection (Bemis) (Warnick) TRT prstp/startup test (Keimi ) (Warnick) Brief Denton (Panel - Draft Agenda for Site Meeting (Panel Attend Licensee Meeting TRT QA/QC .(Livermore Warnick). Mechanical Design Issues (Terao,Chen, Fair Vollmer) Coatings (McCracken Jordan) RIV Inspection / Enforcement Sumary (Hunter) (Herdt) RI NDE Van (Ebneter) (Jordan) Discussion of findings (Panel) Document Control (Griffin) (Warnick)~ DI Reports (Fortuna) (5niezek) X (8:30-10:00) - TRT Civil Structural / Mechanical (Shao) Brief Eisenhut/Denton, Dircks (Panel) X (10:00-2:30) Preparation for Meeting (Panel) X (3:(0-5:00) Plant Review fResident) X I;9:00-5:00) RIV discussion (Hunter) X (8:00-5:00)- Untervenor meeting (Ellis) X(8:30-11:00) Applicant Meeting (Spence) X (1:00-6:00) RIV closeout (Hunter) X (8:00-4:00) R view Final TRT SERs Prepare Review Draft (Panel) X--------X Sntimidation Panel . (Gagliardo) (Sniezek) X Discussion of Previous Testimony (Treby) X Coment Final Draft (Panel) X----X Brief Eisenhut/Denton X R:psrt-Issuance o X----X Frrpara ASLB Testimony (Panel) __

                                                                                            .              .~

                                                                                  . Enclosure 3 Opening Statement Contention ~5 Panel Meeting With Intervenors     ,.

Purpose of Meeting The purpose of this meeting is to obtain information from the intervenor

                                                                                         ~

related to Contention 5 by the Hearing Board. This information will be combined with other information collected by the panel to make thk NRC stafLf determination regarding Contention 5. The tex't of ' Contention 5 from tiie Board Order dated is as follows: - Contention 5. The Applicants' failure to adhere to the' quality assurance / quality control provis' ions required by the: construct' ion permits for Comanche Peak, Units; I and 2, and the req'uirements:of Appendix B of 10 CFR~Part 50, an'd the construction practices employed, specifically in regard to concrete work, mortar blocks, ~ steel, ' fracture toughness testing, expansion joints, placement of the i. reactor vessel for Unit 2, welding, inspection and testing, materials used,' craft _ labor qualifications and working' conditions (as they may affect QA/QC)' and training and organization of QA/QC personnel, have raised substantial questions as to the ade'quacy of the construction of the facility. As a ,,_ result, the Commission cannot make the findings required by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche. Peak.- (CFUR 4A-ACORN 14-CASE 19 JOINT Contention) Composition of Contention 5 Panel

     . A panel of senior NRC managers was established by the NRC Executive Director's Office on December 24, 1984 to evaluate Contention 5. The Charter of.the panel and its membership was revised on January 30, 1985. The membership'is. comprised of the following personnel drawn ;from various NRC Offices:

Edward L.' Jordan (Chairperson), Director, Division of Emergency Preparedness and Engineering Response, IE

Richard Vollmer, Deputy Director. IE Allan Herdt, Chief, Engineering Programs Branch, Division of

 .                     Engineering and Operational Programs, RII Robert Warnick, Chief, Projects Branch No. 1. Division of Reactor Projects,RIII              .
 .,                  James Sniezek, Director, Regional Operations and Generic Requirements Staff, ED0 Ashok Thadani,; Reactor Risk Branch, Division of Risk Analyses, NRR ,                        .

I.would also'like to introduce the other NRC representatives present today: 1

     ~

The panel is instructed to work closely with Mr. Vince Noonan, Director of the _ Comanche Peak Project and to report t'o the Deputy Director of Nuclear Reactor Regulation. Support and assistance. is drawn from the NRC staff responsible for conducting reviews, inspections and investigations on this matter. Purpose of Panel The purpose of this panel is to evaluate, in an integrated manner, the information developed by the staff which bears upon quality assurance, quality control and overall.' plant quality. l , A. Make the staff determination regarding 10 CFR 50.57(a) as related to Contention 5. More specifically, 50.57 requires that in order to issue.an operating license a finding must be made that " Construction of the facility has been substantially completed, in conformity with the construction ! permit ind the application as amended, the provisions of the Act, and the. ) rules and regulations of the Connission;"..... ' l l

B. Provide a report to the' Director, NRR reflecting the panel's determination. C. Provide panel testimony before the Comanche Peak Atomic Safety and Licensing Board. Method of Review The panel is considering findings from past and current NRC staff. activities and applicant actions including results of the following! reviews:

1. Region IV inspections

2. CAT inspections

3. OI investigations ,

4. Technical Review Team inspections -

5. Enforcement actions

6. Special Review Team inspection

7. SALP reports

8. Staff anlaysis of CYGNA Report '

9. Staff summary of the Hearing Rec ~rd o

The panel is reviewing material prepared by staff reviews, compiled data, discussions with staff reviewers, the applicant and intervenors an'd a site review. The panel is reviewing and compiling the results of work by others and will refer any new information to the appropriate staff reviewer. Meeting Protocol As discussed earlier by telephone with Mrs. Ellis, the panel requested this l , briefing by the intervenors to emphasize information that should be considered in the panel determinations. The panel will ask questions of the intervenor representatives to clarify the panel member's understanding. This meeting is scheduled from 8:30 to 11:00 am. The-intervenors will also be afforded an opportunity to make a brief comment at the end of the meeting with the applicant this afternoon. In order to use the time effectively, I have asked Mrs. Ellis l to moderate the intervenor discussicns within the meeting time restraints. 1 1

i

                                                                                                                                      \

I remind the participants that the panel is endeavoring to cover the very large volume of information.directly relevant to Contention 5. A separate panel is  :

  ,             reviewing the intimidation issue. That panel will provide a staff determination regarding the existence and' materiality of intimidation to the Contention 5 Panel.                                                         -

Any new information should be directed to Mr. Vince Noonan, the Comanche Peak Project Manager. , An attendance list is being circulated to identify the meeting participants. As you are aware, this meeting is being transcribed and copies will be provided to the parties in the hearing and additional copies will be available at a cost of from . To help establish a clear record, each speaker should identify his or'her self and use a microphone. Mrs. Ellis, it is now am, please begin with your discussion which may run until 10:30. With your agreement, the panel may interrupt your discussion to clarify a discussion ~ point, otherwise we will hold our questions for the last 30 minutes of the meeting. t 4 4 f G

            . ,      ,    r.___  _ _ _ _ _ _ . . . _ _ . _ - - -      ._ . _ -   _ . _ _ . . . ___________________.__.____L      _

   .. .                                                                     Enclosure 4

,. 1/28/85 DRAFT

SUMMARY

OF PRESENTATION ON INVESTIGATION OF DOCUMENT CONTROL ALLEGATIONS > On January 23, 1985, Brooks; Griffin of NRC's Office of : Investigation (OI) met with the Contention 5 Panel 'to discuss the findings of hislinvestigation of 13 document control allegations. OI had initiated the investigation bscause of alleged wrongdoing.' Mr. Griffin began the investigation in January of 1984 and ended it in August of 1984. ;He interviewed two allegers and 45 individuals involved in document control ~. He ob'tained infonnation for the.tiine period of. July 1983 through ' August'1984. Based on his review, Mr.I, Griffin believed nine allegations were s'ubstantiate'd and four allegatio'ns were ino't subst'antiated. .The investigator did not attempt to dptermine if the alleged activities resulted.in

                                                                                              ~

hardware problems. Notwithstanding the substantiated allegations he indicated he did not anticipate any significant enforcement action coming out of the investigation. Although the NRC CAT inspection in January-March 1983 found, :in general, des'ign change controls satisfied FSAR commitments and ANSI standard requirements, the process was difficult and .resulted in large numbers of design changes. Mr. Griffin indicated that in response to the CAT findings, an elaborate and strict system of document controls was established by the licensee. He indicat'ed that the satellite offices were put into service in about July of 1983 and the computer

                                                                              ~
     ,  system for controlling documents was put into service approximate 1y August of 1983.

Most of the plant was constructed when the document control system was less fomal. Mr. Griffin said that many of the things he investigated appeare'd.to be violations of this stricter document control system. The investigator said that the further away from the document control center, the less fonnal the control of the documents

        ' '                                                                                                                      l
          ,                                                                                          1/28/85
                         .                                                                       DRAFT and that both crafts and QC inspectors we're involved in failing to follow the procedures. However, the document clerks were required to follow the computer even if the computer was wrong. There was no procedure to get around this weakness. The workers.were required to check out controlled work packages at                      -

the start of each day;and turn them in at the end of each day. The packages would be updated whenever changes were made. Some of the workers would use or attempt to use "information only" drawings or parts of the packages:rather than the complete controlled drawing package. The investigator believed the document. control supervisors were not aware of; the impact of many of their decisions to circumvent the system. a -W e 6e O s e 4 9 e.-- -, - --,e-+-. - - - - - . - ,<

s

 .          ..                .                    1 Comanche Peak Contention 5 Panel Meeting Summary The Contention 5 Panel met on 1/30/85.from 8:30am to 5:00pm. Attending were:

Panel Members Advisors Prisenters R. Vollmer, IE V. Noonan, NRR R. Fortuna, OI R.' Warnick .RIII C. Poslusny, NRR L. Shao, NRR A. Herdt, RII T. Sullivan, NRR B. Hayes, OI J. Sniezek, EDO A. Thadoni, NRR E. Jordan, IE A. Meeting Agenda

 .-s                             .

r (Enclosure'1) . . B. Panel Activities Planned The panel reviewed final preparations for the Texas Trip on 2/5-8/85.

                       ' C.      Discussion of 0I Investigations
                                .(Enclosure 2)
                                         ~

D.- Discusion of TRT Civil / Structural / Mechanical Review I (Enclosure 3) - l. k

         -,                  --                               e                    -          _ _ _ - - - - ,,     a -- , ,

     .                                                                             Enclosure 1 1/30/85 AGENDA

1. Review 1/23 neeting summary .

2. 8:30-10:00 Discussion of OI Reports with fortuna

3. 10:00-10:30 Meet with Eisenhut on revised Charter, preparations for site trip .

4. 10:30-2:30 Discussiori of TRT Civil / Structural / Mechan'.ical with.Shao

5. 2:30-3:00 Meet with Dircks on revised Charter, discussion of activities

6. 3:00-5:00' Preparations for site meeting

   .           a.        Identify plant areas to review

b. Establish regional meeting agenda '

c. Review plans for meeting with intervenor and with applicant e

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Enclosure 2 01 INVESTIGATIONS On January 30, 1985,'the panel was briefed by Roger Fortuna and Ben Hayes re- . garding the investigations which are open. There are nine open investigations. Attached is a brief synopsis supplied by 01 delineating the thrust of certain of the allegations which establishes the basis for the investigations. OI could not provide an estimated completion date for the open investigations; . however, 01 and NRR/ Region IV have reviewed all the open investigations and; have determined that none of them need resolution prior to licensing. This was confirmed in panel discussions with D. Eisenhut. OI indicated that the allegations'they are pursuing are generally representative of the same types of allegations at other facilities at this stage of the construction process. There appears to be no problems in the working relation-ship between 01 and the staff. d D e e 4

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   '                                                                            January 30, 1985 COMANCHE PEAK                                        '

LISTING OF OPEN CASES AND INQUIRIES IN 01:RIV - DECEMBER 31, 1984 4-84-013 Comanche Peak . Opened Alleged Falsification of Data Cards and Intimidation of Pipe 02/24/84 Fitters . (Allegationmadeduringaninterviewconductediin regards to 4-84-006)

                                           . Investigator: E. B. Griffin ECD: Unknown 4-84-025        Comanche Peak Opened          Alleged Improprieties in the Brown & Root DCC 02/07/84             Investigator:         E. B. Griffin ECD: Unknown 4-84-030         Comanche Peak, Glen Rose. TX Opened          Alleged Improper Upgrading of Material at CPSES 06/07/84    .

Investigator: .E. B. Griffin ECD: Unknown 4-84-039 Comanche Peak

             . Opened           Alleged Intimidatiori of Quality Control Inspector 09/11/84             Investigator: E. B. Griffin ECD: Unknown                                                       ,

4-84-040 Comanche Peak Opened Alleged Falsification of Startup Doctrination Fonn 09/12/84 Investigator: E. B. Griffin ECD: Unknown L 4-84-047 Comanche Peak Opened Alleged Falsification of Test Results 10/09/84 Investigator: E. B. Griffin ECD: Unknown Q4-84-041 Comanche Peak . Opened Alleged Falsification of Fab Shop Papermark 09/13/84 Q4-84-045 Comanche Peak Steam Electric Station Opened Alleged Falsification of Coatings Quality Control. Training 10/04/84 Records Investigator: E. B. Gr iffin ECD: Unknown Q4-34-050 Comanche Peak Steam Electric Station Op;ned Alleged Intimidation of TUGC0 QA Auditors by TUGC0 QC 11/28/84 Management l Investigator: E. B. Griffin ECD: Unknown 1 _

U.S.CruCLEAR EEGULATORY CE>anstagions i _ CmCPC' Rad 35 ' q;;= - ., ' *

      .                                                                   INVESTIGATION STATUS RECORD
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{ cv.. gya P.EC10ll IV 4 'u4-C1. CIR4-54-A-0021 , [ . ,.Lw,un s . or .. l ausgs.10 TJ tutJECT C.IFFIN C0l'ANCHE PEAK STEAli ELECTP.IC STATI0li: status ts cny are. .ars,#ebHLee.eWM A una aun ut unin omr.wd l ei.u anaanAunsaun ur rart. r a a t.r.L  ! February 24, 1984: Durine an interview conducted in regards to 01F0 .

             . investigaticn 4-84-006, an allegatien was rece.ived fro:h the interviewee tisat he
             .al ong with cther piping crew members were intimidated by a Brown & Root, Inc.,

general foreman inte not reporting a falsificatien relt.teC to a lost data " card. ICD: Unknown . e

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                                                                                           ""             COMANCHE PEAR.:          ALLEGED IMPROPRIETIES IN 1P.E
    ^ * ' * ' '

BROW & RDOT DCC _m 3RIFFIN STATUS /$>reety a,te, sanasc. c e enef- iwif 8 n Fcbruary 7,1984, a former Brown &OnRoot, Inc.. (B&R) Docum O S March 23. 1984, the Region IV i mproprieties in the B&R DCC to the NRC Region IV staff. I Fiald Office received a request from the NRC Region IV Regional Administrator f'or an D l i nvestigation into potential wrongdoing as part of the alleger's testimony on the g. DCC the alleger's testimony recently provided to the Department of Labor (00L). F y!j l ICD: Unknown t I. L b r

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        '                                                                          '"    COMANCHE PEAK, GLEN ROSE, TX

- a 6ato'o HERR Alleged Improper Upgradino of Material at CPSES . og ST ATUS (Js.ordr erre. .ad.re..sur e erwf me.cref al l On June 7,1984 this investigation was opened after a former QC inspector alleged the

             ' Fabrication Shop personnel upgrades classes of material to fill an order if material requested was not available. As an example, craf t personnel in the Fabrication Shop will icok for material requested on drawing, and if it cannot be found, they will substitute a similar looking material. The material will be stamped by craft personnel with a number aj that correspcnds to drawings. The alleger stated that this stamp looks different than v;ndor stamps.               ECD: Unknown.                                                                                                                     H
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                                                                           < COMANCHE PEAK:  ALLEGED FALSIFICATIO4 bRIFFIN         .

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svAvo is u+ .  : 5 4Ti/hWJsaiRiidiiGn FORn On August 8,1984, a request was made to the Texas Utilities Generating Cospany for training and indoctrination forms by a NRC Technical Review Team (TRT) member. A [ licensee employee provided the TRT with an Indoctrination Fors. Close examination disclosed the fom to be questionable. Initial inquiry revealed that the original g/ [ fom had been lost and the new form had been recently created. ECO: Unknown y A h I r 84

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• en the stat ,s bleek Eeer tow eear ne' =:t+. the mee faie esd ee*4f one copy to Hemiase9ees.

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COMANCHE PEAK: ALLEGED INTIMIDATION l" . ' U% ^ GRIFFIN s

• TO status ise eu.a d,Me MIAIL.CQNTROL INSPECTOR 10n b ust 1, 1984, during an interview with the Comanche Peak Steam Electric .

               .(C."SLS) Technical Review Team (TRT), a former Brown & Root, Inc. Quality Control
               -1.i;cctor at the CPSES alleged:that in the Spring of 1983 she was pressured by Frc',n & Root Quality Control supervisors to sign off hold points on travelers for
                 "...aiity Centrol inspections that occurred prior to her employment at the CPSES.

T!.e tileger said she subsequently learned that the travelers she had signed were

                       -t for the r.aterial represented by the documentation. Subsequently, during the 7.~irst . eek of Septenber 1984, a representative of the TRT informed the Region IV                                                                                                                                       1 01 Tit 1d Office of the alle'gation. ECD: Linknown                                                                                                                                                                          ;

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                   ..                   Septer.5er 30, 1984 - This investigation has been initiated.
  !                                     Anticipate coc.pletion of this investigation during
 '!                                     October / November 1984 time fr ame. ECD: Unknown

s LA!r: October 31, 1984 - This investigation is in progress.

Anticipate completion of this investigation during

                                         ':ovember/ December 1984 time frame. ECD: L'nknown.                                                                                                                                     ,

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                           *~E:         *:a-r.ber .20, .19*4 - Investigation r                                              ains in r-nsrers.                                              .nticipate co:'.,)]et ion <.'urf ng D+.cc ber 195.'./T.:bruary IVS5 t i:ne f rs'e.                                                                                ECD: 1*ni.newn 4:      rece-ber 31 e 19S4 -                        Insestigatien ricains in pregress. .tnticipate tr .plet ten c'uring A .uary/T+':.rusry 1965 t he f rs:ne.                                                                                     ECD:    Un'nown i

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U.5 Au, iL A A h t C J6 A10 AY COv*.*st:5?A I INVESTIGATION STATUS RECORD o . -

.a .'1e**%5. %.fra en et Le ces4eseg at.esww. sp.f sam ect..a, he ocawed selet w to e asie os at least ew's .T cave l' no c aaer 8'es oeuve? d.rer .; tne 30 de, ee.ee.6 8p'.(df .adesate "he Chenpe' en the status tinoch Keer t%e o..g.nee with the case f 6e eat stad one co.*e to Heada., agers.

o**.co e' sa.eri gat.ons

         . . . A .* s t a gavecome                                     Ospect o .oei.a,..c. .e,                .:. o m ov.6 .cisse                           01 F1 ELD.0FFICE 4-S4-047
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a .Cteetm REGION IV

         . . s.           ,o                                                         . . . ,

l GRIFFIN COMAfiCHE PEAK STEAM ELECTRIC STATION:

    ',,                                                                  sTArus tsoec,& sere ansa, eta 4.r,4y Apj r a c8 a vii ur a Ld a . rstavL 3 I

On Octcber 9,1984, the 01 Field Office Region IV received a document from the liRC

                !J.R Technical Eeview Team (TRT) that alleged wrongdoing. '.This document is from the Cx.inche Peak Steam Electric Station (CPSES) ASLB to the applicant requesting

.t..ers to various questions, one of which addresses falsification.; The document c:rlair.s that on September 21, 1984, the CPSES ASLB received testimony during an j ,'n cA..cra hearing from a fora,er Texas Utilities Generating Company Start-up Testing

                      .; .e e r.        This engineer stated that he had falsified start-up test results and had                                                                             i e . .-; m o s ., . . 6y co n o v a. e n s pu. w r .n w :> ign ing o ye m>pe.t .un r epos t -sooico6 ng
                   '.Et a start-t p test had been ccmpleted successfully, when in fact the test had not                                                                                     f

.t r. cc . ducted. . ECD: Unkncwn d.l.

                                                                                                                                                                                  .uv l                          ,,,,,,.hr... W-i

• TE:. '!:vc.ber 30, 1984 - Due to other higher-priority investiga-ions anticipate e

a __ f' vesti;s.tf on to begin during the' Spring 1965 time frane. ICD: Unknown

• CI:

                              *.ec e-ber 31 e 198?. -                 Due to other higher-priority investigatiens, anticipate j                            1:.venetigation tc begin during the Spring 1985 time frame.                                                      ICD:        Unknevn i

e Document'!!ame: . GABRIEL 824 Requestor's ID:' GABRIEL , 4 Author's Name: Sniezek n

    ,             Document Coments:               -

01-Investigations - _

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