Information Notice No. 85-66: Discrepancies Between As-built Construction Drawings and Equipment Installations

                                                           SSINS No.: 6835 
                                                            IN 85-66       

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                               August 7, 1985

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 
information 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 instrumentation 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 
approximately 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 construction 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 
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Examples of these discrepancies were ungrounded cable shields, missing 
hardware, 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 operating 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 discrepancies between equipment 
installations and as-built drawings were identified by NRC Construction 
Appraisal Team (CAT) inspections at 10 facilities from September 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. 
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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. 


                                   Edward L. Jordan Director 
                                   Division of Emergency Preparedness 
                                     and Engineering 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  
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                                                            Page 1 of 1   

                      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 
significant finding in this area was design change documents written against
superseded 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 identified 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, 
electrical and mechanical equipment was installed to the latest design 
documents, and commensurately that the appropriate inspection was conducted 
to the latest design documents.