ML20198C616
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o 1.
Allegation Category: QA/QC 1, Design Process 2.
Allegation Number: AQ-21, AQ-22 and AQ-119 3.
Characterization:
It is alleged that vendor certified drawings (VCDs) for ASME-code component supports have numerous errors in weld sizes and location (AQ-22), that original vendor documentation was not controlled (AQ-21), and that VCDs have been revised to reflect the as-built condition of the plant (AQ-119).
4.
Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed three procedures (Reference 1) related to the control, review, and verification of the fabrication, installation, and inspection of ASME component supports. This review and the TRT's subsequent discussions with Brown & Root (B&R) personnel provided an understanding of the vendor docu-ment control system for the Comanche. Peak project. The TRT learned that vendor documents (principally those for pipe supports) were processed as described below.
Vendor pipe support design drawings were developed by support vendors, such as Nuclear Power Service, Inc. (NPSI) and ITT Grinnel, from the Gibbs & Hill (G&H) design information package (including piping analysis summary, support loads, location, type, attachments, and interference) furnished to the pipe support vendor by G&H.
Vendor pipe support design activities were governed by G&H design specification MS-46A.
The vendor prepared a support design drawing in accordance with purchase order requirements. These requirements included G&H piping composites, piping layout drawings, and pipe routing drawings.
(The TRT evaluation of G&H design verification is contained in QA/QC Category 1, allegations AQ-15andAQ-89.) This drawing was then transferred to B&R site construc-tion, where it was modified to conform to the site document control system (usually by renumbering it). B&R then replaced the vendor's identifica-tion block with their own corporate identification block, but preserved the fact that the drawing came from a particular vendor.
The support was fabricated (if not prefabricated) and installed, and the as-built drawing was vendor-certified by a documented independent design review. When this review was completed, the drawing was stamped " Vendor Certified Drawing,"
the applicable drawing revision was noted, and the vendor representative signed and dated the stamped drawing. This process is in accordance with procedure CP-EI-4.5-4, which requires that vendor certification of support drawings be accomplished after the as-built stress analysis is completed to assure compatibility between final stress analysis and final support design.
In addition to the independent design verification required by Appendix B to 10 CFR Part 50, a review was required to ensure compatibility between the final stress analysis and the final support design.
The TRT found no instance where this process was not followed (AQ-22).
During fabrication and installation of supports, however, various condi-tions may arise that require modification of the original vendor drawing.
Modifications may result from conditions such as interferences encountered during installations, changes resulting from inprocess and final inspection, and engineering design changes directly or indirectly related to a par-ticular support.
Regardless of the reason for a change affecting a vendor drawing, its source, or the number of times the vendor has previously 8605230022 860512 0-39 PDR FOIA CARDEG5-89 PDR L.
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I certified the drawing, both the Final Safety Analysis Report (FSAR) l_
commitment and NRC requirements require vendor personnel to recertify their own drawings ( AQ-22, AQ-119).
l The Texas Utility Electric Company (TUEC) vendor document control system is consistent with their FSAR commitments and the applicable NRC require-ments. The TRT verified the implementation of this process in their re-view of vendor drawings, which included associated change documents, all drawing and change revisions, bases for changes and revisions, nonconfor-mance reports (NCRs), and the certification packages for each VCD. The TRT
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reviewed the processing of one drawing which had been identified by the alleger as being improperly processed.
This drawing was processed through
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vendor drawing control as follows (AQ-21).
ITT Grinnell transmitted an ASME Class 2 drawing (CS-1-240-007-A-22, Revi-sion 0) to B&R. B&R placed their corporate identification on the drawing, placed four weld identification numbers on the welds, and reissued the draw-ing as BRH CS-1-240-007-A42R, Revision 0, on January 25, 1980.
Revision 1 to the drawing was issued on August 11, 1981, to correct errors on the drawing, reorient the pipe hanger, modify the support plate dimensions, and delete the weld identification numbers which were not required.
Revision 2 to the drawing, issued on March 26, 1982, voided component modi-fication card (CMC) 32938(2), revised the design load conditions, and pre-sented the as-built design of the support. Revision 3, issued November 9, l
1982, identified several changes in orientation, weld sizes, and location, and was the first revision to be vendor-certified by onsite ITT Grinnell I
personnel. Revision 4 was also vendor-certified and was issued on July 30, 1983, to disposition an NCR (M-76715) which identified a weld as under-sized. The NCR was dispositioned by deleting the weld as a requirement because it was not necessary for structural integrity. The TRT reviewed the vendor certification calculations supporting the disposition of this.
NCR, performed alternate calculations, and also came to the conclusion 4
that the weld was not required for structural integrity. The current VCD for this support (Revision 5) was issued on October 2,1983, and provides orientation changes and the resulting dimensional changes.
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Based on the review of 26 hanger drawings and associated piping drawings, hanger location drawings, and vendor certification packages, the TRT found that the involved process described above is typical of that used for most support drawings and that it is similar to processes established at other sites.
Changes to VCDs and discrepancies between drawings and installed i
conditions potentially can occur at any time; however, the as-built con-dition must be in cor.formance with the applicable VCD. As a measure of the effectiveness of conformance of VCDs to the as-built condition, the TRT selected 10 supports (Reference 8) for physical verification against the applicable VCD. Physical measurements made by the TRT included dimen-sions, weld sizes, and location. Two of the 10 supports exhibited weld problems, undercut and overgrinding of the base metal.
Such weld problems required repairs but did not require any changes to VCDs. The details of this as-built evaluation and the broader as-built subject are presented in QA/QC Category 8, AQ-50.
The revision of any design document invalidates the design verification of that document and requires reverification by the organization responsible 0-40
for the original design. (Refer to 10 CFR 50, Appendix B, Criterion III.)
The TRT determined that both principal support vendors (ITT Grinnell and NPSI) have staffs onsite to conduct design verification of changes to their own drawings and to recertify these drawings when required.
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Conclusion and Staff Positions:
Based on the review described above, the TRT concludes that these allegations are substantiated to the extent that supports were installed before the drawings were vendor certified (AQ-119),
VCDs had numerous errors (dimensions, material orientation, etc) but were revised to reflect as-built conditions (AQ-22), and supports were revised af ter the drawings were vendor certified.
The TRT also found that original vendor documentation (drawings) were converted to B&R drawings by applying a B&R corporate si. icker and by changing the document numbers to be consis-tent with the onsite numbering system (AQ-21).
However, none of these practices described above violated site procedures or NRC requirements.
(See also QA/QC Category 8, allegation AQ-50.)
In a meeting with the alleger on November 27, 1984, the TRT presented the results of the assessment and the TRT's conclusions for allegations AQ-21 and AQ-119.
There were no major items of disagreement, and no new concerns or allegations were identified.
The alleger of AQ-22 could not be located, thus no contact has been made.
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Attachments:
None.
Reference Documents:
1.
Procedures:
(a) QI-QAP-11.1-28, " Fabrication, Installation, Inspection of ASME Component Supports, Class 1, 2, and 3."
(b)
CP-E1.4.5-4, " Technical Services Engineering Instruction for Pipe Hanger Desi.gn Review and Certification," Revision 7.
(c) CP-CPM 6.9G, " Documentation for ASME Welding, Fabrication, and Installation Activities."
2.
B&R Piping Drawings.
3.
Seven B&R Hanger Location Drawings.
4.
B&R hanger drawings (26 drawings); selected design change documents.
5.
Three vendor certification packages.
6 NCR No. M-76735.
7.
MS-46A, Gibbs & Hill Design Specification " Nuclear Safety Class Pipe l
Hangers and Supports."
8.
The following B&R hanger drawings were verified as-built:
AF-1-001-702-S33R(R2)
AF-1-001-701-S33R(R4)
AF-1-001-014-S33R( R3)
AF-1-035-024-S33A(RS)
AF-1-059-003-S33R(R4)
AF-1-035-011-A33R(R8)
AF-1-037-002-533 R( R8) 0-41
RC-1-901-700-C82R(R2)
RC-1-901-703-C82R(RI)
AF-1-001-001-533R(R8).
9.
Depositions: AQ-21; A-49 Statement, dated May 1, 1984.
10.
Interviews: AQ-119: A-5 on May 18, 1984, pp. 19-21.
AQ-21, and 119: A-5 on August 1, 1984, pp. 56-63 and A5 on November 27, 1984, pp. 86-92, 11.
Reports:
(a) AQ-21: A-5 Letter of March 7, 1984, item 11.
TUGC0 Brief to ASLD, Item 12.
(b) AQ-22: A-6, 01 Report Q4-83-009, dated April 8, 1983.
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This statement prepared by:
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6 ~/-8f R. W. Bonnenberg, TRT Date Technical Reviewer Reviewed by:
Y h..Livermore ~
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>Ari.b u a r Date Groep Leader Approved by:
V. Noonan Date Project Director 0-42
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