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

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

Technical

Contact: 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 85-64 85-63 85-62 Crack Growth In Steam Generator

Girth Welds 7/31/85 BBC Brown Boveri Low-Voltage

7/26/85 K-Line Circuit Breakers, With Deficient

Overcurrent

Trip Devices Models OD-4 and 5 Potential

for Common-Mode

7/25/85 Failure of Standby Gas Treat-ment System on Loss of Off-Site Power Backup Telephone

Numbers to 7/23/85 the NRC Operations

Center All PWR facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL and certain fuel facilities

85-61 -Misadministrations

to Patients 7/22/85 Undergoing

Thyroid Scans All power reactor facilities

holding an OL and certain fuel facilities

85-60 85-59 85-58 85-57 Defective

Negative Pressure 7/17/85 Air-Purifying, Fuel Facepiece Respirators

Valve Stem Corrosion

Failures 7/17/85 Failure Of A General Electric 7/17/85 Type AK-2-25 Reactor Trip Breaker All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

designed by B&W and CE holding an OL or CP All power reactor facilities

holding an OL or CP; fuel facilities;

and material licensees Lost Iridium-192 Source Resulting

In The Death Of Eight Persons In Morocco 7/16/85 OL = Operating

License CP = Construction

Permit II