ML20203N975

Nuclear Safety Review Staff Investigation Rept I-86-194-SQN, Employee Concern XX-85-120-006, Hanger Drawings Made & Design Completed After Hanger Fabrication & Installation, on 860210-28

ML20203N975
Person / Time
Site:	Sequoyah
Issue date:	03/04/1986
From:	Catlin J, Kincaid J, Stevens W TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20203N908	List: ML20203N905 ML20203N911 ML20203N922 ML20203N940 ML20203N950 ML20203N964 ML20203N975 ML20203N986
References
I-86-194-SQN, NUDOCS 8605060246
Download: ML20203N975 (6)

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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT No. I-86-194-SQN I

EMPLOYEE CONCERN: XI-85-120-006 SdBJECT:

MANGER DRAWINGS MADE AND DESIGN COMPLETED AFTER HANGER FABRICATION AND INSTALLATION DATES OF INVESTIGATION: FEBRUARY 10-29, 1986

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I. BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by the Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as XX-85-120-006, stated:

Sequoyah - Hanger crews were instructed (supervisor known) to go ahond and build hangers without drawings, and engineering would draw the hanger up later. Many of these hangers were subsequently rejected and reworked. Construction department concern. CI has no further information.

II. scope A. The scope of the investigation was determined from the stated concern of record. A call to QTC confirmed that hanger crews were told to fabricate and install pipe hangers without design drawings and without engineering control.

B. Construction specifications and procedures for installation of hangers and control of drawings were reviewed.

C. Interviews woro conducted with craft foremen and field engineers.

III.

SUMMARY

OF FINDINGS A. Related Concerns '

l. XX-85-120-002 - This concern was investigated and reported in NSRS Report No. I-85-925-SQN. This concern has been changed to read the same as the subject concern due to the further clarification by QTC.

2. The following concerns have not been assigned or investigated to date but appear to be closely related. Essentially, fitters are told to build hangers then document them af terward.

EX-85-058-001 EX-85-085-001 EX-85-105-002 EX-85-104-002 EX-85-121-004

3. WI-85-091-006 - This concern was written on Watts Bar Nuclear Plant (WBN) by the same individual who wrote the subject concern on Sequoyah Nuclear plant (SQN).

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B. Requirements and Cornitments

1. Code of Federal Regulation, 10CFR50, Appendix B, Critorion VI,

" Document Control," requires a quality assurance (QA) program that controls the design proccsc, drawings, and procedures. It recognizes that field changes may be necessary, but requires that they also must follow these controls and design review.

2. TVA Topical Report TVA-TR75-1 R8, which is the upper-tier QA '

program for TVA, defines measures to be taken by the various organizations to meet the requirements above.

3. Nuclear Quality Assurance Manual (NQAM), Part V Section 6.1 (ID-QAP-6.1), dated December 31, 1984, " Configuration Drawing control," defines the respcnsibilities of the Office of Engineering (CE), Office of Construction (OC), and Office of Nuclear Power (NUC PR) concerning the control of drawings from the time of equipment transfer to NUC PR through operation of the unit (s). This proceduro requires certain drauings, needed for operation and maintenance of the plant, to be under configuration control and be designated "as-constructed drawings," which depicts the as-built configuration of the plant.

4. SNP Construction Proceduro No. P-10 R20 dated April 2,1981,

" Control of Quality Assurance Dccuments," defines how the control of drawings was handled at SQN construction site. This document assigned responsibility to the engineering units to ensure that drawings under their cognizance were as-constructed at equipment transfer to operations. This document defines "As-Constructed Drawing as: "Those drawings that reflect the actual physical and/or functional configuration of a component, system, or structuro at some specific point of time."

5. SNP Standard Operating Proceduro No. 308 R5 dated April 18, 1980, " Configuration Control," established guidelines for the implementation of configuration control during construction.

This document provided a system (Drawing Information System) to track the appropriato construction status as it related to all engineering drawings and approved manufacturcrc' drawings. The constructicn status codes of interest for this investigation, were:

AC - Aa-Constructed (As-Built) - Built as marked on drawings (may include field changes, incomplete work, temporary features, etc.).

AD - As-Designed - Built as designed with no changes.

(Approved drawing revision with no open field changes, etc.).

This document defines "As-Constructed Drawing" as: "A drawing that reflects the actual physical and/or functional as-built i configuration including field changes, incomploto items, missing items, or temporary features of a component, system, or structure at come specific point of time."

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prior to transfer to operations, the construction cognizant engineerir.g unit was responsible for assuring that the drawing was properly statused and marked up with the latest configura-tion To meet the configuration control requirements, any approved field change that did not appear on a drawing or any other condition that reficcted the as-constructed configuration had to be added to the drawing prior to transfer of a system.

6. SNP Construction procedure No. P-30 R5 dated May 26, 1981,

" Fabrication and Installation of Seismic Supports," established guidelines for the fabrication and installation of supports during construction. This procedure assigned responsibility to the cognisant engineering unit to:

a. Obtain resolution to any problems encountered during fabrication and erection of supports,

b. Initiate and coordinate Field Change Requests, Support Variances, and Support Modification Requests.

c. Fnsure that all supports are fabricated and installed in accordance with the requirements of this procedure and engineering drawings and specifications.

This procedure required all engineered supports, typical supports for pipe larger than two inches in diameter, and duct supports to be located and installed in accordance with OE-approved drawings and any applicable approved Field Change Requests or Support Modification Requests. The procedure allowed typical supports for two-inch and smaller pipe, lighting and conduit supports, and instrumentation supports to be installed in accordance with an approved drawing or be field run with the assistance of the responsible system engineer. Any changes to a support design drawing which fell within the support fabrication and installation tolerances given in this procedure did not require a drawing revision and could be considered "as-designed."

For all drawings which were designated as required to operate and maintain the plant (Systems Configuration Control Drawing List), the responsible construction engineering unit had to ensure that all changes were included on the as-constructed drawing.

Procedure P-30 recognized that changes may be required to supports and specified the method to document and obtain approval.

C. Findings

1. The investigator determined through interviews that pipe hangers had been installed without drawings and that engineering later drew up the hangers and provided the appropriate piping analysis and support design calculations. The hangers were then 3

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inspected per the issued drawings. Interviewed personnel stated that the hangers were installed as temporary hangers using QA materials and crafted to meet anticipated design requirements.

This practico was conducted by craft foremen with the intention of getting design qualification at a later dato.

2. The practico of installing temporary / hangers which woro crafted to meet anticipated design requirements was performed at SQN and WBU during a time period when issued hanger designs did not allow location variations. The practice was also used during time periods when hanger crews were idled becauco design drawings had not been issued on schedule. The practice reflected the poor design control which existed at the time.

The practico provided a marginally acceptable alternative to a poorly conceived design / construction process. Although the practice demonstrated initiative by the craft, it is backwards to normal design procedures and makes status tracking difficult.

3. A workable design process was later adopted which included moving a full complement of engineering personnel to the site.

There was then no reason to continue the practice identified by the Concerned Individual (CI). There is no evidence that it is being practiced at present. The potential harmful consequences of the inadequato design / construction process used in the past have been mitigated by configuration reinspections performed under IIRC IEB 79-14. All extra hangers, missing hangers, and nonconforming hangers have been identified and evaluated by engineering.

IV. CONCLUSIONo AND REcotCIENDATIONS A. Conclusion The concern of record was substantiated. The root cause of the concern had been corrected and the consequences mitigated by reinspections performed under NRC IEB 79-14. There was no evidence that hangers are currently being installed without drawings or engineering control.

B. Recommendation None 4

DOCUMENTS REVIEWED IN INVESTIGATION I-86-194-SQN AND REFERENCES

1. SNP Construction Procedure No. P-10 R20. " Control of Quality Assurance Documents," dated April 2, 1981

2. SNP Construction Procedure No. P-30 RS, " Fabrication and Installation of Seismic Supports," dated May 26, 1981

3. SNP Construction Procedure No M-20 R3, " Pipe Support Installation and Documentation," dated December 15, 1975 4 General Construction Specification No. 43 R8, " Support and Installation of Piping Systems in Category I Structures," dated August 8, 1985

5. SNP Standard Operating Procedure No. 308 RS, " Configuration Control" dated April 18, 1980

6. NQAM, Part V, Section 6.1 (ID-QAP-6.1), " Configuration Drawing Control "

dated December 31, 1984

7. SNP Administrative Instruction AI-25 (Part I) Ril, " Drawing Control Af ter Unit Licensing," dated October 25, 1985

8. Code of Federal Regulation,10CFR50, Appendix B Critorion VI, " Document Control" 5

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