Information Notice 1985-66, Discrepancies Between As-Built Construction Drawings and Equipment Installations

Discrepancies Between As-Built Construction Drawings and Equipment Installations

ML031180224
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	08/07/1985
From:	Jordan E NRC/IE
To:
References
IN-85-066, NUDOCS 8508050449
Download: ML031180224 (5)

SSINS No.: 6835 IN 85-66 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 August 7, 1985 IE INFORMATION NOTICE NO. 85-66: DISCREPANCIES BETWEEN AS-BUILT CONSTRUCTION

DRAWINGS AND EQUIPMENT INSTALLATIONS

Addressees

All nuclear power reactor facilities holding an operating license (OL) or a

construction permit (CP).

Purpose

This information notice is to alert recipients of a potentially significant

generic problem regarding as-built construction drawings not correctly or

completely reflecting equipment installations. Modifications of existing

installations also may be susceptible to the problems discussed in this infor- mation notice. It is expected that recipients will review the information for

applicability to their facilities and consider actions, if appropriate, to

preclude a similar problem occurring at their facilities. However, suggestions

contained in this information notice do not constitute NRC requirements;

therefore, no specific action or written response is required.

Description of Circumstances

Fermi Unit 2 During routine NRC prelicensing inspections of as-built design and construction

drawings and specifications at Fermi Nuclear Power Plant Unit 2, from April

1984 to October 1984 several discrepancies in the electrical and instrumenta- tion and control (I&C) installations were discovered, which construction and

preoperational testing had not identified.

In response to the NRC findings at Fermi, the licensee conducted an approxi- mately 100 percent reinspection of electrical and I&C installations. That

inspection effort resulted in the identification of over 7300 discrepancies and

errors between as-built field configurations and associated design and con- struction drawings and specifications. There were 154 discrepancies which, if

left uncorrected, could result in the loss or incorrect function of a

safety-related component or system. Examples of these discrepancies were

wiring errors, unidentified jumpers, wrong tubing connections, and wrong

installed components. There were 300 discrepancies that had correct design

documents but incorrect installations that could impair safe operations.

8508050449

IN 85-66 August 7, 1985 Examples of these discrepancies were ungrounded cable shields, missing hard- ware, and wrong nameplates. There were 1900 discrepancies which had correct

as-built hardware but deficient drawings. Examples of these discrepancies

included wiring installed that was not shown on the applicable drawing, wiring

details that differed from the installation drawing, and incorrect cable

numbers on the drawings. There were 5000 additional minor discrepancies which

would not have impacted or impaired safe plant operations directly such as

incorrect wire tags, equipment layouts that did not match the drawings, and

inconsistencies in wire tagging methods. Extensive actions by the applicant

were necessary to correct the most significant discrepancies before an operat- ing license was issued by the NRC.

Rancho Seco

A reactor coolant system high point vent line addition was made at Rancho Seco

during the 1983 refueling outage as part of the TMI required modifications.

Part of the modification included adding cross bracing and revising supports

for the adjacent nitrogen supply line. Although records indicate this work had

been done and inspected it had actually not been performed. In addition, a

removable piping spool piece used to isolate the nitrogen supply was not

replaced by a rigid piece as required. The resulting unsupported 4 foot length

of 1 inch diameter pipe caused a fatigue failure at a high point vent weld

resulting in a-20-gallon per minute non-isolatable primary coolant leak. This

event is similar to previous discrepancies identified between the as-built and

as-designed piping systems at a number of nuclear power plants that led to

issuance of IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-Related

Piping Systems." Resolution of the actions requested by that bulletin has

resulted in extensive reanalysis and/or modifications of piping systems in many

nuclear power plants.

Construction Appraisal Team Inspections

A number of problems with construction activities which may lead to discrepan- cies between equipment installations and as-built drawings were identified by

NRC Construction Appraisal Team (CAT) inspections at 10 facilities from Septem- ber 1982 to January 1985.

Discussion:

To assure that an adequate level of safety exists or will exist at all nuclear

power plants, it is required that all safety related as-built design and

construction drawings match the plant hardware. Requirements and measures to

control documents are identified in 10 CFR 50, Appendix B; NUREG-0800, Standard

Review Plan, Rev. 2 of Section 17.1; ANSI N45.2-1977, Section 7; and

ANSI N.8.7-1976, Section 5.2.15, as applicable.

IN 85-66 August 7, 1985 No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the Regional

Administrator of the appropriate regional office or this office.

' wad .Jordan, Director

Divisi n of Emergency Preparedness

and gineering Response

Office of Inspection and Enforcement

James C. Stewart, IE

(301) 492-9061 Attachments:

1. Discrepancies Identified During Construction

Appraisal Team Inspections

2. List of Recently Issued IE Information Notices

Attachment 1 IN 85-66 August 7, 1985 Discrepancies Identified During

Construction Appraisal Team Inspections

During the Braidwood CAT inspection the NRC team noted a failure to annotate

unincorporated design changes on controlled design documents. The most signif- icant finding in this area was design change documents written against super- seded revisions of the approved drawings; this resulted in a pipe support being

installed and inspected to other than the latest approved design.

Programmatic concerns were noted by the NRC team in two areas during the

Shearon Harris CAT inspection: (1) lack of verification of piping and pipe

support/restraint location to original design requirements and (2) lack of an

ongoing program to effectively identify and resolve hardware clearance problems

early in the construction process. Both of these concerns involve practices

that could result in extensive inspection, analyses, and rework efforts very

late in the construction schedule.

The River Bend CAT inspection noted that numerous cable tray supports did not

meet the drawing configurations that were utilized for determining support

loading. The applicant failed to consider the generic implications of identi- fied deficiencies. Improper or inadequate fastener locking was identified, including unbent or missing cotter pins, no staking of threads, loose or

missing locknuts, and inadequate lock wiring. These deficiencies indicated

both inadequate field quality control (FQC) inspection and alteration of

completed and accepted work by construction personnel.

The Nine Mile Point 2 CAT inspection identified problems in the document

control program that indicated the crafts and inspectors may not have been

using the latest design documents in the performance of their work. Inspection

reports often did not reflect the drawing revision to which the installation

was inspected. Adding to the document control problem was the high rate of

design change initiation and the inability to maintain and revise construction

drawings in a timely manner to reflect such changes. The NRC CAT inspectors

identified that over 30 percent of all design change documents resulted from

errors or inadequate information provided on previously issued changes.

Furthermore, rather than taking measures to identify the reasons for the high

change notice generation rate, a procedural requirement for incorporation of

changes in drawings had simply been circumvented by the licensee to allow

construction to continue without timely design change update.

The results of the Comanche Peak CAT inspection indicated a breakdown in

fabrication, installation, and inspection in the HVAC area. The licensee's

quality assurance program had not ensured that certain hanger, support, elec- trical and mechanical equipment was installed to the latest design documents, and commensurately that the appropriate inspection was conducted to the latest

design documents.

Attachment 2 IN 85-66 August 7, 1985 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

85-65 Crack Growth In Steam 7/31/85 All PWR facilities

Generator Girth Welds holding an OL or CP

85-64 BBC Brown Boveri Low-Voltage 7/26/85 All power reactor

K-Line Circuit Breakers, With facilities holding

Deficient Overcurrent Trip an OL or CP

Devices Models OD-4 and 5

85-63 Potential for Common-Mode 7/25/85 All power reactor

Failure of Standby Gas Treat- facilities holding

ment System on Loss of Off- an OL or CP

Site Power

85-62 Backup Telephone Numbers to 7/23/85 All power reactor

the NRC Operations Center facilities holding

an OL and certain

fuel facilities

85-61 - Misadministrations to Patients 7/22/85 All power reactor

Undergoing Thyroid Scans facilities holding

an OL and certain

fuel facilities

85-60 Defective Negative Pressure 7/17/85 All power reactor

Air-Purifying, Fuel Facepiece facilities holding

Respirators an OL or CP

85-59 Valve Stem Corrosion Failures 7/17/85 All power reactor

facilities holding

an OL or CP

85-58 Failure Of A General Electric 7/17/85 All power reactor

Type AK-2-25 Reactor Trip facilities designed

Breaker by B&W and CE holding

an OL or CP

85-57 Lost Iridium-192 Source 7/16/85 All power reactor

Resulting In The Death Of facilities holding

Eight Persons In Morocco an OL or CP; fuel

facilities; and

material licensees

OL = Operating License

CP = Construction Permit

II