Information Notice 1985-40, Deficiencies in Equipment Qualification Testing and Certification Process

Deficiencies in Equipment Qualification Testing and Certification Process

ML031180380
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, 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, Humboldt Bay, 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, Crane
Issue date:	05/22/1985
From:	Jordan E NRC/IE
To:
References
IN-85-040, NUDOCS 8505200600
Download: ML031180380 (4)

SSINS No.: 6835 IN 85-40

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C.

20555

May 22, 1985

IE INFORMATION NOTICE NO. 85-40:

DEFICIENCIES IN EQUIPMENT QUALIFICATION

TESTING AND CERTIFICATION PROCESS

Addressees

All holders of a nuclear power reactor operating license (OL) or a construction

permit (CP).

Purpose

This information notice is to alert licensees that quality-related deficiencies

in the qualification documentation, review, approval, and certification process

have been identified by the Vendor Program Branch (VPB) of the NRC during its

review of qualification activities.

NRC observations suggest that some vendor

qualification activities and practices may not provide a sufficient basis for

qualification certification.

It is suggested that recipients review this information for specific and generic

applicability to ensure that documentation supporting environmental qualification

of safety-related equipment at their facilities is complete.

Suggestions

contained in this notice do not constitute NRC requirements; therefore, no

specific action or response is required.

Description of Circumstances

10 CFR 50.49, Regulatory Guide 1.89 (Revision 1, June 1984), and IEEE Standards

323-1974 and 323-1983 each require auditable information demonstrating qualifi- cation to provide continuing assurance to licensee management and the NRC that

equipment in use is qualified for the entire period during which it is installed

in the nuclear power plant.

10 CFR 50, Appendix B, provides quality assurance

requirements for the generation of all elements of qualification files.

IEEE

Standard 323-1974, Section 8 (endorsed by Regulatory Guide 1.89), requires that

individual elements of qualification files be reviewed and approved by the

licensee. Since July 1982, the VPB has actively inspected vendor qualification

efforts for compliance to these NRC requirements.

Inspections have been performed

at manufacturing facilities, independent testing laboratories, architect-engineers, and nuclear steam supply system (NSSS) vendors.

NRC observations at the vendor level provide examples where more active licensee

participation in the qualification effort should have occurred.

In some cases, certification of qualification is now difficult to justify because of documen- tation and test practices employed by vendors.

Some examples of NRC findings

follow.

8505200600

IN 85-40

May 22, 1985 1. Qualification activities not performed under a QA program consistent with

10 C 5, Appenx

I

o

Qualification testing of Class lE equipment was conducted without

appropriate QA programs.

o

No QA requirements were imposed on organizations providing safety- related services (such as irradiation, calibration, and analyses)

associated with the qualification process.

2. Qualification test report conclusions not supported by test data or

test data not availab e

o

Test profiles shown in qualification reports were not actually achieved

during test.

o

Reports identified specimens or materials that were different from

those actually tested.

o

Test records showed inadequate sensitivity/resolution of test equipment.

o

Documentation required by the standards referenced in the test report

was not available (test plans, equipment lists, and calibration records).

°

Test anomalies werenot adequately reported or evaluated.

o

Similarity between test specimens and items to be qualified was not

established.

3. Documentation to support the validity of

qualification not maintained

for lifetime of the equipment

o

Supporting test data were destroyed after five years.

4. Inadequate review, approval, or certification of test results

o

Interfaces/responsibilities of organizations involved in the

qualification process were not clearly defined.

o

Test reports contained statements that testing satisfied the

"guidelines" or "intent" of standards referenced in the specification.

Detailed descriptions of NRC findings and results of these inspections are

published in NUREG-0040, "Licensee Contractor and Vendor Inspection Status

Report," Volumes 6, 7, and 8. This report is published quarterly by the NRC,

and it can be obtained from the Superintendent of Documents, U.S. Government

Printing Office, Post Office Box 37082, Washington, D.C.

20013-7982.

IN 85-40

May 22, 1985 Correspondence with contractors and vendors relative to the inspection data

contained in NUREG-0040 is placed in the NRC Public Document Room, 1717 H Street, N. W., Washington, D.C.

20555.

Discussion:

The deficiencies described in this notice resulted from the review of a vendor's

qualification activities against the applicable procurement document requirement

or, in the case of generic qualification, against the applicable QA criteria.

An overall assessment of identified deficiencies (1) suggests that some vendor

qualification activities may not adequately support the applicable NRC require- ments, and (2) emphasizes the need for increased licensee attention to the adequacy

of their vendor procurement control practices for qualification activities and

the definition of responsibilities and interfaces in the qualification process.

Documentation from vendors and test laboratories form the basis for meeting the

equipment qualification requirements of paragraphs (d), (e), (f) and (j) of 10 CFR 50.49.

This documentation may include procurement specifications, test plans, test procedures, test logbooks, qualification test reports, test data, analyses

and corrective action to resolve test anomalies, test configurations and

interfaces, and quality assurance information.

The NRC staff considers the above-identified deficiencies to be representative

examples of problems with vendors and test laboratories providing qualification

services to other vendors and user utilities. Although there may be specific

problems applicable to a particular utility, the staff expects that user

utilities will consider the overall applicability of the above information in

establishing qualification of safety-related equipment.

No specific action or written response is required by this notice.

If you have

any questions regarding this notice, please contact the Regional Administrator

of the appropriate NRC regional office or this office.

ar l. orian, Director

Divis n of Emergency Preparedness

and ngineering Response

G. T. Hubbard, IE

(301) 492-9759 Attachment:

Attachment 1

IN 85-40

May 22, 1985

LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information

Date of

Notice No.

Subject

Issue

Issued to

85-39

85-38

85-37

84-55 Sup. 1

85-20

Sup. 1

85-36

84-52 Sup. 1

85-35

85-34

84-84 Rev. 1 Auditability of Electrical

5/22/85

Equipment Qualification

Records At Licensees'

Facilities

Loose Parts Obstruct Control 5/21/85

Rod Drive Mechanism

Chemical Cleaning Of Steam

5/14/85

Generator At Milestone 2

Seal Table Leaks At PWRs

5/14/85 Motor-Operated Valve Failures 5/14/85

Due To Hammering Effect

Malfunction Of A Dry-Storage, 5/9/85

Panoramic, Gamma Exposure

Irradiator

Inadequate Material

5/8/85

Procurement Controls On

The Part Of Licensees And

Vendors

Failure Of Air Check Valves

4/30/85 To Seat

Heat Tracing Contributes To

4/30/85

Corrosion Failure Of Stainless

Steel Piping

Deficiencies In Ferro-

4/24/85

Resonant Transformers

All power reactor

facilities holding

an OL or CP

All PWR facilities

designed by B&W

holding an OL or CP

All pressure water

reactor 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 licensees

possessing gamma

irradiators

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 or CP

All power reactor

facilities holding

an OL or CP

DL = Operating License

CP = Construction Permit