Information Notice 1985-66, Discrepancies Between As-Built Construction Drawings and Equipment Installations: Difference between revisions
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==Description of Circumstances== | ==Description of Circumstances== | ||
:Fermi Unit 2During routine NRC prelicensing inspections of as-built design and constructiondrawings and specifications at Fermi Nuclear Power Plant Unit 2, from April1984 to October 1984 several discrepancies in the electrical and instrumenta-tion and control (I&C) installations were discovered, which construction andpreoperational 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. Thatinspection effort resulted in the identification of over 7300 discrepancies anderrors between as-built field configurations and associated design and con-struction drawings and specifications. There were 154 discrepancies which, ifleft uncorrected, could result in the loss or incorrect function of asafety-related component or system. Examples of these discrepancies werewiring errors, unidentified jumpers, wrong tubing connections, and wronginstalled components. There were 300 discrepancies that had correct designdocuments but incorrect installations that could impair safe operations.8508050449 IN 85-66August 7, 1985 Examples of these discrepancies were ungrounded cable shields, missing hard-ware, and wrong nameplates. There were 1900 discrepancies which had correctas-built hardware but deficient drawings. Examples of these discrepanciesincluded wiring installed that was not shown on the applicable drawing, wiringdetails that differed from the installation drawing, and incorrect cablenumbers on the drawings. There were 5000 additional minor discrepancies whichwould not have impacted or impaired safe plant operations directly such asincorrect wire tags, equipment layouts that did not match the drawings, andinconsistencies in wire tagging methods. Extensive actions by the applicantwere necessary to correct the most significant discrepancies before an operat-ing license was issued by the NRC.Rancho SecoA reactor coolant system high point vent line addition was made at Rancho Secoduring the 1983 refueling outage as part of the TMI required modifications.Part of the modification included adding cross bracing and revising supportsfor the adjacent nitrogen supply line. Although records indicate this work hadbeen done and inspected it had actually not been performed. In addition, aremovable piping spool piece used to isolate the nitrogen supply was notreplaced by a rigid piece as required. The resulting unsupported 4 foot lengthof 1 inch diameter pipe caused a fatigue failure at a high point vent weldresulting in a-20-gallon per minute non-isolatable primary coolant leak. Thisevent is similar to previous discrepancies identified between the as-built andas-designed piping systems at a number of nuclear power plants that led toissuance of IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-RelatedPiping Systems." Resolution of the actions requested by that bulletin hasresulted in extensive reanalysis and/or modifications of piping systems in manynuclear power plants.Construction Appraisal Team InspectionsA number of problems with construction activities which may lead to discrepan-cies between equipment installations and as-built drawings were identified byNRC 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 nuclearpower plants, it is required that all safety related as-built design andconstruction drawings match the plant hardware. Requirements and measures tocontrol documents are identified in 10 CFR 50, Appendix B; NUREG-0800, StandardReview Plan, Rev. 2 of Section 17.1; ANSI N45.2-1977, Section 7; andANSI N.8.7-1976, Section 5.2.15, as | :Fermi Unit 2During routine NRC prelicensing inspections of as-built design and constructiondrawings and specifications at Fermi Nuclear Power Plant Unit 2, from April1984 to October 1984 several discrepancies in the electrical and instrumenta-tion and control (I&C) installations were discovered, which construction andpreoperational 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. Thatinspection effort resulted in the identification of over 7300 discrepancies anderrors between as-built field configurations and associated design and con-struction drawings and specifications. There were 154 discrepancies which, ifleft uncorrected, could result in the loss or incorrect function of asafety-related component or system. Examples of these discrepancies werewiring errors, unidentified jumpers, wrong tubing connections, and wronginstalled components. There were 300 discrepancies that had correct designdocuments but incorrect installations that could impair safe operations.8508050449 IN 85-66August 7, 1985 Examples of these discrepancies were ungrounded cable shields, missing hard-ware, and wrong nameplates. There were 1900 discrepancies which had correctas-built hardware but deficient drawings. Examples of these discrepanciesincluded wiring installed that was not shown on the applicable drawing, wiringdetails that differed from the installation drawing, and incorrect cablenumbers on the drawings. There were 5000 additional minor discrepancies whichwould not have impacted or impaired safe plant operations directly such asincorrect wire tags, equipment layouts that did not match the drawings, andinconsistencies in wire tagging methods. Extensive actions by the applicantwere necessary to correct the most significant discrepancies before an operat-ing license was issued by the NRC.Rancho SecoA reactor coolant system high point vent line addition was made at Rancho Secoduring the 1983 refueling outage as part of the TMI required modifications.Part of the modification included adding cross bracing and revising supportsfor the adjacent nitrogen supply line. Although records indicate this work hadbeen done and inspected it had actually not been performed. In addition, aremovable piping spool piece used to isolate the nitrogen supply was notreplaced by a rigid piece as required. The resulting unsupported 4 foot lengthof 1 inch diameter pipe caused a fatigue failure at a high point vent weldresulting in a-20-gallon per minute non-isolatable primary coolant leak. Thisevent is similar to previous discrepancies identified between the as-built andas-designed piping systems at a number of nuclear power plants that led toissuance of IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-RelatedPiping Systems." Resolution of the actions requested by that bulletin hasresulted in extensive reanalysis and/or modifications of piping systems in manynuclear power plants.Construction Appraisal Team InspectionsA number of problems with construction activities which may lead to discrepan-cies between equipment installations and as-built drawings were identified byNRC 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 nuclearpower plants, it is required that all safety related as-built design andconstruction drawings match the plant hardware. Requirements and measures tocontrol documents are identified in 10 CFR 50, Appendix B; NUREG-0800, StandardReview Plan, Rev. 2 of Section 17.1; ANSI N45.2-1977, Section 7; andANSI N.8.7-1976, Section 5.2.15, as applicable. | ||
IN 85-66August 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 RegionalAdministrator of the appropriate regional office or this office.' wad .Jordan, DirectorDivisi n of Emergency Preparednessand gineering ResponseOffice of Inspection and Enforcement | |||
===Technical Contact:=== | ===Technical Contact:=== | ||
James C. Stewart, IE(301) 492- | James C. Stewart, IE(301) 492-9061Attachments:1. Discrepancies Identified During ConstructionAppraisal Team Inspections2. List of Recently Issued IE Information Notices | ||
Attachment 1IN 85-66August 7, 1985 Discrepancies Identified DuringConstruction Appraisal Team InspectionsDuring the Braidwood CAT inspection the NRC team noted a failure to annotateunincorporated 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 beinginstalled and inspected to other than the latest approved design.Programmatic concerns were noted by the NRC team in two areas during theShearon Harris CAT inspection: (1) lack of verification of piping and pipesupport/restraint location to original design requirements and (2) lack of anongoing program to effectively identify and resolve hardware clearance problemsearly in the construction process. Both of these concerns involve practicesthat could result in extensive inspection, analyses, and rework efforts verylate in the construction schedule.The River Bend CAT inspection noted that numerous cable tray supports did notmeet the drawing configurations that were utilized for determining supportloading. 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 ormissing locknuts, and inadequate lock wiring. These deficiencies indicatedboth inadequate field quality control (FQC) inspection and alteration ofcompleted and accepted work by construction personnel.The Nine Mile Point 2 CAT inspection identified problems in the documentcontrol program that indicated the crafts and inspectors may not have beenusing the latest design documents in the performance of their work. Inspectionreports often did not reflect the drawing revision to which the installationwas inspected. Adding to the document control problem was the high rate ofdesign change initiation and the inability to maintain and revise constructiondrawings in a timely manner to reflect such changes. The NRC CAT inspectorsidentified that over 30 percent of all design change documents resulted fromerrors or inadequate information provided on previously issued changes.Furthermore, rather than taking measures to identify the reasons for the highchange notice generation rate, a procedural requirement for incorporation ofchanges in drawings had simply been circumvented by the licensee to allowconstruction to continue without timely design change update.The results of the Comanche Peak CAT inspection indicated a breakdown infabrication, installation, and inspection in the HVAC area. The licensee'squality 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 latestdesign documents. | |||
Attachment 2IN 85-66August 7, 1985LIST OF RECENTLY ISSUEDIE INFORMATION NOTICESInformation Date ofNotice No. Subject Issue Issued to85-6585-6485-6385-62Crack Growth In SteamGenerator Girth Welds7/31/85BBC Brown Boveri Low-Voltage 7/26/85K-Line Circuit Breakers, WithDeficient Overcurrent TripDevices Models OD-4 and 5Potential for Common-Mode 7/25/85Failure of Standby Gas Treat-ment System on Loss of Off-Site PowerBackup Telephone Numbers to 7/23/85the NRC Operations CenterAll PWR facilitiesholding an OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL and certainfuel facilities85-61 -Misadministrations to Patients 7/22/85Undergoing Thyroid ScansAll power reactorfacilities holdingan OL and certainfuel facilities85-6085-5985-5885-57Defective Negative Pressure 7/17/85Air-Purifying, Fuel FacepieceRespiratorsValve Stem Corrosion Failures 7/17/85Failure Of A General Electric 7/17/85Type AK-2-25 Reactor TripBreakerAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities designedby B&W and CE holdingan OL or CPAll power reactorfacilities holdingan OL or CP; fuelfacilities; andmaterial licenseesLost Iridium-192 SourceResulting In The Death OfEight Persons In Morocco7/16/85OL = Operating LicenseCP = Construction PermitII | |||
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{{Information notice-Nav}} | {{Information notice-Nav}} | ||
Revision as of 19:01, 6 April 2018
SSINS No.: 6835IN 85-66UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENTWASHINGTON, D.C. 20555August 7, 1985IE INFORMATION NOTICE NO. 85-66: DISCREPANCIES BETWEEN AS-BUILT CONSTRUCTIONDRAWINGS AND EQUIPMENT INSTALLATIONS
Addressees
- All nuclear power reactor facilities holding an operating license (OL) or aconstruction permit (CP).
Purpose
- This information notice is to alert recipients of a potentially significantgeneric problem regarding as-built construction drawings not correctly orcompletely reflecting equipment installations. Modifications of existinginstallations also may be susceptible to the problems discussed in this infor-mation notice. It is expected that recipients will review the information forapplicability to their facilities and consider actions, if appropriate, topreclude a similar problem occurring at their facilities. However, suggestionscontained in this information notice do not constitute NRC requirements;therefore, no specific action or written response is required.
Description of Circumstances
- Fermi Unit 2During routine NRC prelicensing inspections of as-built design and constructiondrawings and specifications at Fermi Nuclear Power Plant Unit 2, from April1984 to October 1984 several discrepancies in the electrical and instrumenta-tion and control (I&C) installations were discovered, which construction andpreoperational 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. Thatinspection effort resulted in the identification of over 7300 discrepancies anderrors between as-built field configurations and associated design and con-struction drawings and specifications. There were 154 discrepancies which, ifleft uncorrected, could result in the loss or incorrect function of asafety-related component or system. Examples of these discrepancies werewiring errors, unidentified jumpers, wrong tubing connections, and wronginstalled components. There were 300 discrepancies that had correct designdocuments but incorrect installations that could impair safe operations.8508050449 IN 85-66August 7, 1985 Examples of these discrepancies were ungrounded cable shields, missing hard-ware, and wrong nameplates. There were 1900 discrepancies which had correctas-built hardware but deficient drawings. Examples of these discrepanciesincluded wiring installed that was not shown on the applicable drawing, wiringdetails that differed from the installation drawing, and incorrect cablenumbers on the drawings. There were 5000 additional minor discrepancies whichwould not have impacted or impaired safe plant operations directly such asincorrect wire tags, equipment layouts that did not match the drawings, andinconsistencies in wire tagging methods. Extensive actions by the applicantwere necessary to correct the most significant discrepancies before an operat-ing license was issued by the NRC.Rancho SecoA reactor coolant system high point vent line addition was made at Rancho Secoduring the 1983 refueling outage as part of the TMI required modifications.Part of the modification included adding cross bracing and revising supportsfor the adjacent nitrogen supply line. Although records indicate this work hadbeen done and inspected it had actually not been performed. In addition, aremovable piping spool piece used to isolate the nitrogen supply was notreplaced by a rigid piece as required. The resulting unsupported 4 foot lengthof 1 inch diameter pipe caused a fatigue failure at a high point vent weldresulting in a-20-gallon per minute non-isolatable primary coolant leak. Thisevent is similar to previous discrepancies identified between the as-built andas-designed piping systems at a number of nuclear power plants that led toissuance of IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-RelatedPiping Systems." Resolution of the actions requested by that bulletin hasresulted in extensive reanalysis and/or modifications of piping systems in manynuclear power plants.Construction Appraisal Team InspectionsA number of problems with construction activities which may lead to discrepan-cies between equipment installations and as-built drawings were identified byNRC 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 nuclearpower plants, it is required that all safety related as-built design andconstruction drawings match the plant hardware. Requirements and measures tocontrol documents are identified in 10 CFR 50, Appendix B; NUREG-0800, StandardReview Plan, Rev. 2 of Section 17.1; ANSI N45.2-1977, Section 7; andANSI N.8.7-1976, Section 5.2.15, as applicable.
IN 85-66August 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 RegionalAdministrator of the appropriate regional office or this office.' wad .Jordan, DirectorDivisi n of Emergency Preparednessand gineering ResponseOffice of Inspection and Enforcement
Technical Contact:
James C. Stewart, IE(301) 492-9061Attachments:1. Discrepancies Identified During ConstructionAppraisal Team Inspections2. List of Recently Issued IE Information Notices
Attachment 1IN 85-66August 7, 1985 Discrepancies Identified DuringConstruction Appraisal Team InspectionsDuring the Braidwood CAT inspection the NRC team noted a failure to annotateunincorporated 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 beinginstalled and inspected to other than the latest approved design.Programmatic concerns were noted by the NRC team in two areas during theShearon Harris CAT inspection: (1) lack of verification of piping and pipesupport/restraint location to original design requirements and (2) lack of anongoing program to effectively identify and resolve hardware clearance problemsearly in the construction process. Both of these concerns involve practicesthat could result in extensive inspection, analyses, and rework efforts verylate in the construction schedule.The River Bend CAT inspection noted that numerous cable tray supports did notmeet the drawing configurations that were utilized for determining supportloading. 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 ormissing locknuts, and inadequate lock wiring. These deficiencies indicatedboth inadequate field quality control (FQC) inspection and alteration ofcompleted and accepted work by construction personnel.The Nine Mile Point 2 CAT inspection identified problems in the documentcontrol program that indicated the crafts and inspectors may not have beenusing the latest design documents in the performance of their work. Inspectionreports often did not reflect the drawing revision to which the installationwas inspected. Adding to the document control problem was the high rate ofdesign change initiation and the inability to maintain and revise constructiondrawings in a timely manner to reflect such changes. The NRC CAT inspectorsidentified that over 30 percent of all design change documents resulted fromerrors or inadequate information provided on previously issued changes.Furthermore, rather than taking measures to identify the reasons for the highchange notice generation rate, a procedural requirement for incorporation ofchanges in drawings had simply been circumvented by the licensee to allowconstruction to continue without timely design change update.The results of the Comanche Peak CAT inspection indicated a breakdown infabrication, installation, and inspection in the HVAC area. The licensee'squality 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 latestdesign documents.
Attachment 2IN 85-66August 7, 1985LIST OF RECENTLY ISSUEDIE INFORMATION NOTICESInformation Date ofNotice No. Subject Issue Issued to85-6585-6485-6385-62Crack Growth In SteamGenerator Girth Welds7/31/85BBC Brown Boveri Low-Voltage 7/26/85K-Line Circuit Breakers, WithDeficient Overcurrent TripDevices Models OD-4 and 5Potential for Common-Mode 7/25/85Failure of Standby Gas Treat-ment System on Loss of Off-Site PowerBackup Telephone Numbers to 7/23/85the NRC Operations CenterAll PWR facilitiesholding an OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL and certainfuel facilities85-61 -Misadministrations to Patients 7/22/85Undergoing Thyroid ScansAll power reactorfacilities holdingan OL and certainfuel facilities85-6085-5985-5885-57Defective Negative Pressure 7/17/85Air-Purifying, Fuel FacepieceRespiratorsValve Stem Corrosion Failures 7/17/85Failure Of A General Electric 7/17/85Type AK-2-25 Reactor TripBreakerAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities designedby B&W and CE holdingan OL or CPAll power reactorfacilities holdingan OL or CP; fuelfacilities; andmaterial licenseesLost Iridium-192 SourceResulting In The Death OfEight Persons In Morocco7/16/85OL = Operating LicenseCP = Construction PermitII