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{{#Wiki_filter: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
{{#Wiki_filter: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==
==Addressees==
:All nuclear power reactor facilities holding an operating license (OL) or aconstruction permit (CP).
:
All nuclear power reactor facilities
 
holding an operating
 
license (OL) or a construction
 
permit (CP).


==Purpose==
==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.
: 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


==Description of Circumstances==
holding an OL or CP All power reactor facilities
: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
designed by B&W and CE holding an OL or CP All power reactor facilities


===Technical Contact:===
holding an OL or CP; fuel facilities;
James C. Stewart, IE(301) 492-9061Attachments:1. Discrepancies Identified During ConstructionAppraisal Team Inspections2. List of Recently Issued IE Information Notices
and material licensees Lost Iridium-192 Source Resulting


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


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
License CP = Construction


}}
Permit II}}


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

Revision as of 13:21, 31 August 2018

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 L
NRC/IE
To:
References
IN-85-066, NUDOCS 8508050449
Download: ML031180224 (5)
v • d • e


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 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


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