Information Notice 1985-66, Discrepancies Between As-Built Construction Drawings and Equipment Installations: Difference between revisions

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{{#Wiki_filter:SSINS No.: 6835 IN 85-66 UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:SSINS No.: 6835 IN 85-66 UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


OFFICE OF INSPECTION
OFFICE OF INSPECTION AND ENFORCEMENT


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


NOTICE NO. 85-66: DISCREPANCIES
DRAWINGS AND EQUIPMENT INSTALLATIONS
 
BETWEEN AS-BUILT CONSTRUCTION
 
DRAWINGS AND EQUIPMENT
 
===INSTALLATIONS===


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


holding an operating
construction permit (CP).
 
license (OL) or a construction
 
permit (CP).


==Purpose==
==Purpose==
: This information
:
This information notice is to alert recipients of a potentially significant


notice is to alert recipients
generic problem regarding as-built construction drawings not correctly or


of a potentially
completely reflecting equipment installations. Modifications of existing


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


generic problem regarding
applicability to their facilities and consider actions, if appropriate, to


as-built construction
preclude a similar problem occurring at their facilities. However, suggestions


drawings not correctly
contained in this information notice do not constitute NRC requirements;
therefore, no specific action or written response is required.


or completely
==Description of Circumstances==
 
:
reflecting
Fermi Unit 2 During routine NRC prelicensing inspections of as-built design and construction
 
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
drawings and specifications at Fermi Nuclear Power Plant Unit 2, from April


outage as part of the TMI required modifications.
1984 to October 1984 several discrepancies in the electrical and instrumenta- tion and control (I&C) installations were discovered, which construction and


Part of the modification
preoperational testing had not identified.


included adding cross bracing and revising supports for the adjacent nitrogen supply line. Although records indicate this work had been done and inspected
In response to the NRC findings at Fermi, the licensee conducted an approxi- mately 100 percent reinspection of electrical and I&C installations. That


it had actually not been performed.
inspection effort resulted in the identification of over 7300 discrepancies and


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


piping spool piece used to isolate the nitrogen supply was not replaced by a rigid piece as required.
left uncorrected, could result in the loss or incorrect function of a


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


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


4 foot length of 1 inch diameter pipe caused a fatigue failure at a high point vent weld resulting
installed components. There were 300 discrepancies that had correct design


in a-20-gallon
documents but incorrect installations that could impair safe operations.


per minute non-isolatable
8508050449


primary coolant leak. This event is similar to previous discrepancies
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


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


between the as-built and as-designed
included wiring installed that was not shown on the applicable drawing, wiring


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
details that differed from the installation drawing, and incorrect cable


Piping Systems." Resolution
numbers on the drawings. There were 5000 additional minor discrepancies which


of the actions requested
would not have impacted or impaired safe plant operations directly such as


by that bulletin has resulted in extensive
incorrect wire tags, equipment layouts that did not match the drawings, and


reanalysis
inconsistencies in wire tagging methods. Extensive actions by the applicant


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


of piping systems in many nuclear power plants.Construction
Rancho Seco


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


===Team Inspections===
during the 1983 refueling outage as part of the TMI required modifications.
A number of problems with construction


activities
Part of the modification included adding cross bracing and revising supports


which may lead to discrepan- cies between equipment
for the adjacent nitrogen supply line. Although records indicate this work had


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


and as-built drawings were identified
removable piping spool piece used to isolate the nitrogen supply was not


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


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


Team (CAT) inspections
resulting in a-20-gallon per minute non-isolatable primary coolant leak. This


at 10 facilities
event is similar to previous discrepancies identified between the as-built and


from Septem-ber 1982 to January 1985.Discussion:
as-designed piping systems at a number of nuclear power plants that led to
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.
issuance of IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-Related


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


and measures to control documents
resulted in extensive reanalysis and/or modifications of piping systems in many


are identified
nuclear power plants.


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.
===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


IN 85-66 August 7, 1985 No specific action or written response is required by this information
NRC Construction Appraisal Team (CAT) inspections at 10 facilities from Septem- ber 1982 to January 1985.


notice.If you have any questions
Discussion:
To assure that an adequate level of safety exists or will exist at all nuclear


about this matter, please contact the Regional Administrator
power plants, it is required that all safety related as-built design and


of the appropriate
construction drawings match the plant hardware. Requirements and measures to


regional office or this office.' wad .Jordan, Director Divisi n of Emergency
control documents are identified in 10 CFR 50, Appendix B; NUREG-0800, Standard


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


Response Office of Inspection
ANSI N.8.7-1976, Section 5.2.15, as applicable.


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


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


Contact: James C. Stewart, IE (301) 492-9061 Attachments:
Administrator of the appropriate regional office or this office.
1. Discrepancies


Identified
' wad .Jordan, Director


===During Construction===
Divisi n of Emergency Preparedness
Appraisal


===Team Inspections===
and  gineering Response
2. List of Recently Issued IE Information


Notices
Office of Inspection and Enforcement


Attachment
===Technical Contact:===


1 IN 85-66 August 7, 1985 Discrepancies
===James C. Stewart, IE===
                    (301) 492-9061 Attachments:
1. Discrepancies Identified During Construction


Identified
Appraisal Team Inspections


During Construction
2. List of Recently Issued IE Information Notices


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


===Team Inspections===
Construction Appraisal Team Inspections
During the Braidwood


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


the NRC team noted a failure to annotate unincorporated
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


design changes on controlled
installed and inspected to other than the latest approved design.


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


The most signif-icant finding in this area was design change documents
Shearon Harris CAT inspection: (1) lack of verification of piping and pipe


written against super-seded revisions
support/restraint location to original design requirements and (2) lack of an


of the approved drawings;
ongoing program to effectively identify and resolve hardware clearance problems
this resulted in a pipe support being installed


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


to other than the latest approved design.Programmatic
that could result in extensive inspection, analyses, and rework efforts very


concerns were noted by the NRC team in two areas during the Shearon Harris CAT inspection:
late in the construction schedule.
(1) lack of verification


of piping and pipe support/restraint
The River Bend CAT inspection noted that numerous cable tray supports did not


location to original design requirements
meet the drawing configurations that were utilized for determining support


and (2) lack of an ongoing program to effectively
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


identify and resolve hardware clearance
missing locknuts, and inadequate lock wiring. These deficiencies indicated


problems early in the construction
both inadequate field quality control (FQC) inspection and alteration of


process. Both of these concerns involve practices that could result in extensive
completed and accepted work by construction personnel.


inspection, analyses, and rework efforts very late in the construction
The Nine Mile Point 2 CAT inspection identified problems in the document


schedule.The River Bend CAT inspection
control program that indicated the crafts and inspectors may not have been


noted that numerous cable tray supports did not meet the drawing configurations
using the latest design documents in the performance of their work. Inspection
 
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
reports often did not reflect the drawing revision to which the installation


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


Adding to the document control problem was the high rate of design change initiation
design change initiation and the inability to maintain and revise construction
 
and the inability
 
to maintain and revise construction


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


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


that over 30 percent of all design change documents
errors or inadequate information provided on previously issued changes.


resulted from errors or inadequate
Furthermore, rather than taking measures to identify the reasons for the high


information
change notice generation rate, a procedural requirement for incorporation of


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


issued changes.Furthermore, rather than taking measures to identify the reasons for the high change notice generation
construction to continue without timely design change update.


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


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


for incorporation
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


of changes in drawings had simply been circumvented
design documents.
 
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
Attachment 2 IN 85-66 August 7, 1985 LIST OF RECENTLY ISSUED


program had not ensured that certain hanger, support, elec-trical and mechanical
IE INFORMATION NOTICES


equipment
Information                                  Date of


was installed
Notice No.      Subject                      Issue    Issued to


to the latest design documents, and commensurately
85-65          Crack Growth In Steam        7/31/85  All PWR facilities


that the appropriate
Generator Girth Welds                  holding an OL or CP


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


was conducted
K-Line Circuit Breakers, With          facilities holding


to the latest design documents.
Deficient Overcurrent Trip            an OL or CP


Attachment
Devices Models OD-4 and 5
  85-63          Potential for Common-Mode    7/25/85  All power reactor


2 IN 85-66 August 7, 1985 LIST OF RECENTLY ISSUED IE INFORMATION
Failure of Standby Gas Treat-         facilities holding


NOTICES Information
ment System on Loss of Off-            an OL or CP


Date of Notice No. Subject Issue Issued to 85-65 85-64 85-63 85-62 Crack Growth In Steam Generator
Site Power


Girth Welds 7/31/85 BBC Brown Boveri Low-Voltage
85-62          Backup Telephone Numbers to  7/23/85 All power reactor


7/26/85 K-Line Circuit Breakers, With Deficient
the NRC Operations Center              facilities holding


Overcurrent
an OL and certain


Trip Devices Models OD-4 and 5 Potential
fuel facilities


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


7/25/85 Failure of Standby Gas Treat-ment System on Loss of Off-Site Power Backup Telephone
Undergoing Thyroid Scans              facilities holding


Numbers to 7/23/85 the NRC Operations
an OL and certain


===Center All PWR facilities===
fuel facilities
holding an OL or CP All power reactor facilities


holding an OL or CP All power reactor facilities
85-60          Defective Negative Pressure  7/17/85  All power reactor


holding an OL or CP All power reactor facilities
Air-Purifying, Fuel Facepiece          facilities holding


holding an OL and certain fuel facilities
Respirators                            an OL or CP


85-61 -Misadministrations
85-59          Valve Stem Corrosion Failures 7/17/85  All power reactor


to Patients 7/22/85 Undergoing
facilities holding


Thyroid Scans All power reactor facilities
an OL or CP


holding an OL and certain fuel facilities
85-58          Failure Of A General Electric 7/17/85  All power reactor


85-60 85-59 85-58 85-57 Defective
Type AK-2-25 Reactor Trip              facilities designed


Negative Pressure 7/17/85 Air-Purifying, Fuel Facepiece Respirators
Breaker                                by B&W and CE holding


Valve Stem Corrosion
an OL or CP


Failures 7/17/85 Failure Of A General Electric 7/17/85 Type AK-2-25 Reactor Trip Breaker All power reactor facilities
85-57          Lost Iridium-192 Source      7/16/85 All power reactor


holding an OL or CP All power reactor facilities
Resulting In The Death Of              facilities holding


holding an OL or CP All power reactor facilities
Eight Persons In Morocco              an OL or CP; fuel


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


holding an OL or CP; fuel facilities;
material licensees
and material licensees Lost Iridium-192 Source Resulting


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


License CP = Construction
CP = Construction Permit


Permit II}}
II}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 03:39, 24 November 2019

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

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 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