ML20198D103

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Partially Withheld Assessment of Allegation AQ-111 to Category Qa/Qc 2, Document Control Re Misuse of Brown & Root Hanger Location Drawings & Use of Unapproved Drawings to Locate & Install Hangers
ML20198D103
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V, Winczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230138
Download: ML20198D103 (4)
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1. Allegation Category: QA/QC 2, Document Control
2. Allegation Number: AQ-111
3. Characterization: It is alleged that a group of Brown & Root (B&R) hanger location (BRHL) drawings was misused that drafters of these drawings were directed to perform tasks for which they were not qualified, and that un-approved hanger location drawings were released to the field and were used by-the craft personnel to locate and install hangers.
4. Assessment.of Safety Significance: In assessing this allegation, the NRC Technical Review Team (TRT) reviewed procedures governing design document control (as applied to hanger drawings), hanger locatio'n drawings, and

.as-built piping verification for conformance to ASME Code,10 CFR Part 50, Appendix B, and ANSI N45.2 requirements (References 1 through 5). The TRT determined that the procedures complied with these requirements.

BRHL drawings were developed in response to the as-built verification. pro-gram for nuclear plants under construction and in operation (as outlined in NRC IE Bulletin 79-14). The verification program entailed inspecting plant hardware in its as-built condition, comparing it to design documenta-tion for compliance, and verifying that the seismic analysis conformed to the actual as-built config,uration of safety-related hardware and systems.

Based upon interviews with B&R personnel, the TRT learned that B&R generated BRHL drawings to expedite the performance of the seismic stress analysis of piping hangers by consolidating hanger as-built location data. Without these drawings, the process of inputting hanger-location data into the seismic stress analysis not only would have been time consuming, but would have required: (1) identifying hangers related to_a piping isometric; (2) retrieving individual hanger drawings; (3) obtaining the location data; and (4) inputting the data into the analysis model to verify adequacy of the hanger design. Therefore, B&R engineering and quality control per-sonnel devised a process, the BRHL drawings, by which the as-built verifi-cation of hanger locations could be accomplished while consolidating loca-tion data. Although there was not a specific detailed procedure for developing BRHL drawings, the general procedure, CP-EI-4.0-22, prescribed the methods for development, revision, approval, and distribution of the BRHL drawing.

The initial BRHL drawings were generated by modifying piping isometric drawings. At first, hangers identified on the BRHL drawings did not have dimensional data and were shown in relationship to pipe fittings and to components. Quality control (QC) inspectors used the drawings to account for installed hangers. Later, QC inspectors took actual as-built location measurements and revised the BRHL drawings accordingly. Subsequently, these dimensions were used as input to the seismic stress analysis verifi-cation program.

As part of the as-built program, the TRT inspected the physical locations

.of 42 hangers and found that all 42 were within the drawing tolerance permitted. Included in this inspection were six hangers identified on a h52g 860512 0-79 GARDE 85-e9 pg s

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l drawing which the alleger had checked and initialed. (The physical in-spection technique used and results obtained are addressed in QA/QC Category 8, allegation AQ-50.)

B&R procedure CP-EI-4.0-22, Revision 7, " Design Document Control by TRMD,"

established the requirement that drafting personnel be qualified by educa-tion and/or experience to perform assigned tasks. This procedure also provided technical guidance for the preparation and updating of drawings, including BRHL drawings, by classification. Details of the job descrip-tion, qualifications, and education requirements for drafters were des-cribed in the B&R wage and salary manual.

Based upon a review of the initial and subsequent revisions for selected BRHL drawings, the TRT found that the drawings were prepared, updated, checked, and approved in accordance with procedural diree: tion. The TRT also assessed records documenting personnel qualification, experience, and education for those who drafted, checked, and approved the :ampled drawings for adequacy. Each individual's qualifications, experience, and education were found to be in compliance with the B&R wage and salary manual's job classification requirements for drafters.

5. Conclusion and Staff Position: Based upon this assessment, the TRT con-cludes that allegations regarding the misuse of BRHL drawings and inade-quate qualification of drafters cannot be substantiated. Accordingly, this allegation has no generic implications.

The source of this concern was not an alleger; therefore, no exit inter-view was conducted.

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7. Attachments: None.

Reference Documents:

1. ASME Code Section III, " Nuclear Power Plant Components."
2. 10 CFR 50, Appendix B, "QA Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
3. ANSI N 45.2, "QA Program Requirements for Nuclear Facilities."
4. Brown & Root ASME QA Manual.
5. Brown & Root Procedures:

(a) CP-EI-4.0-22, Rev. O, " Design Document Control by TSMD."

(b)- CP-EI-4.0-22, Rev.1, " Design Document Control by TSMD."

(c) CP-EI-4.5-1, Rev.1, " General Program for As-Built Piping Program."

(d) CP-EI-4.5-10, " General Program for As-Built Piping Program."

(e) Brown & Root Drafting Guide No. 5, Rev. O.

6. Culton Limited Appearance 9/16/82 - Transcript 5551 through 5555 and 5556 through 5559.
7. NRC Inspection Report 50-445/83-03 and 50-446/83-01.
8. IE Bulletin No. 79-14, " Seismic Analysis for Safety-Related Piping System."
9. Brown & Root Wage and Salary Manual, " Drafter Job Descriptions."

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8. This statement prepared by:

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V. Wenczel,4RT

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Technical Reviewer Reviewed by: %g g _7, g {

H. Livermore, Date Group Leader Approved by:

V. Noonan. <

Date Project Director e'

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