ML20134M892
| ML20134M892 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20134M877 | List: |
| References | |
| FOIA-85-454 NUDOCS 8509040331 | |
| Download: ML20134M892 (13) | |
Text
_
SSINS-6835 IN 85-XX j
UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 March
,-1985 i
IE INFORMATION NOTICE NO. 85-XX:
DEFICIENCIES IN EQUIPMENT QUALIFICATION
~
TESTING AND CERTIFICATION PROCESS Addressees:
All holders of a nuclear power reactor operating license (OL) or construction
. permit (CP).
Purcose:
This information notice is to alert licensees that cuality-related deficiencies in the cualification documentation, review, approval, and certification process j
have been _icentified by the Vendor Program Branch (VPB) of the NRC during its rev-:ew of qualification activities.
NRC obse-vations sugcest tha some verdor cualification activities and practices may not provide a sufficien: basis for qualification certification.
~
It is suggested that recipients review this information for specific and generic applicability to ensure that documentation supporting environmentai qualification of _ safety-related equipment at their facilities is ccmplete.
Sugcestions contained in-this notice do not constitute NRC recuirements; therefcre, no s;eci#ic action or resconse is recuired.
Descristien of Circumstances:
10 CFR 50.49, Regulatory Guide 1.E9 (Revision 1, June 1984), IEEE 5:ds. 322-1974 and 323-1983 eacn recuire auditable infcrmation demonstrating qualification to provice continuing assurance to licensee management and the NRC tr.a ecu c en:
d in use is qualifiec for tne er. tire :eriod during which it is installed ir. the nuclear pcaer plant.
10 CFR 50, Ib: enc'x E, previces cuality ass an:e ecu'-e-merts f or the generation of ali elemer.:s cf cualifica:icn files.
'EEE 5::.
323-197c, Section 8 (enocrsed by Pegulatory Guide 1.89), recuires :na-indivicua' eierer.ts of cualification files be reviewed and approved by the licensee.
Since July '.CE2, the "F5 has actively inspected vender cualification effcc:s for c::::li3nce te Pese NPC 're:uirements.
Inspecticns have been perfc-red at anufacturing facilities, incependent testing laboratories, architect engineers, anc NSSS suppliers.
NRC cbservations a: :he vender level provide examples wr.e-e more ac:ive licer.see participation in the qualificaticn effort shcula have* occurred.
In some cases, 8509040331-850623 PDR FOIA GARDEB5-454 PDR' R-t.
IN 85-XX March
, 1985 Page 2 of 6 certification of' qualification is now difficult to justify because of documen-tation and test practices employed by vendors.
Some examples of NRC findings
(
follow.
l 1.
Inadeouate Reoortino by Vendors of Qualification Procedures and Test Results Several examples of poor reporting of qualification procedures and test results by vendors have been observed.
For example, an Ebasco specification to American Insulated Wire (AIW) Corporation (NRC Inspection 99900399/84-01) required flame test samples to be subjected to simulated aging and irradiation before the fTame test was conducted.
During the NRC inspection, no evidence of aging and/or irradi-ation was available. -AIW ethylene-propylene rubber (EPR) wire tested by Franklin Institute Research Laboratory (FIRL) was reported by FIRL to have been preaged by AIW to a 40-year simulated life before undergoing the FIRL test.
No records demonstrating preaging were available during the NRC audit of AIW.
AIW submitted time versus temperature plots, using the Arrhenius ecuation, on elongation data for AIW EPR insulation.
This data was used to determirle accelerated aging to' simulate 40-year life at E0* C anc 90* C.
When a recuest was made by the NRC for the raw data used to generate.he above, AIK stated this information was supplied by DuPcnt; however, no DuPont letter or engineering data sheet was available during the NRC audit.
During inspections at Rockbestes (NRC Inspecticns 999CO277/E3-01, 52-02, ano 83-04), the NRC discovered evidence of poor reporting practices.
For example, Rockbestos Ccmpany qualification report QR 3803 did not accurately represent the temperature and pressure profile achieved during a cualification test.
Accuracies and calibration ranges for test equipment also were misqucted in the qualification report.
NRC inspections at General Electric (NRC Inspectiens 99900911/84-01 and 84-02) anc Wyie (Norco) (NRC Ins::ection 99900905/E3-02) identifiec reporting deficiencies.
Wyle test plan and the initial GE qualification report listed Brand Rex wiring as test specimens.
In response to NRC inspection activities, GE determined that Eranc Rex wiring was nct included in the qualification test effort.
5:W Cable Systems (NRC Ins::ection 999002E3/83-02) indicated to Stone & Webster that its "cualificatier ;regram is submitted in acccrdance with... IEEE Standarcs
=2E2 '.974 and =323 ~.97 " as well as the Stene & Webste purchase specification.
' ;.ne NRC ins:e:Per cf EIW, it was de ernire: na. d:curen.a-ior #i'es c":
- t include test plans, test precedures, test ecuiprent lis s, calibration recor:
e#e ences, er data to sucport that ctilification cf the identified cable had been ia.*. s #ac*.orily BCC CmDli s hed.
2.
Verder Documentation to Su: cort tr.e '.'ai'c':v c# the Oualificaticn Effor Nc: "tir airec for :ne ir.stailec '_HetimeTi Ciass 1E Ecu.c er.:
Several examples wnere vendors did not maintain dccumentation to su;ccr the validity cf the cualification effort also have been icentified.
Neither Fockbestes Ocmcany nor its. test labcratcry, Franklin Research Center (FEC) (NFC Irspections 99000277/E3-C anc 999CC92'./E2-CE), retained supper-ing test ce:a
IN ES-XX March
, 1985 Page 3 of 6 for 11 FRC final' qualification test reports that recorded testing performed frcm 1969 through 1974.
FRC retains supporting test data for 5 years and then offers it to the customer.
If the customer does not accept this data it is destroyed.
As a result, many FRC final qualification reports could not be audited to determine the technical adequacy of testing as well as the quality assurance controls administered during such testing.
NRC inspections at 81W Cable Systems (NRC Inspection 99900283/83-02) found no documentation to show calibration of test equipment used for qualification test-ing performed in.1976.
These test results were being employed in 1982 to satisfy 4
current purchase specifications.
Test equipment lists also were not available.
Test plans and procedures (per Section 6.3 of IEEE Std. 323-1974) had not been developed, by BIW prior to testing and thus were not retained as part of the j
oualification documentation per IEEE Std. 323-1974, Section 8, requirements.
3.
Qualification Activities by Vendors not Performed under a Ouality Assurance procram Consistent with 10 CFR 50, Accendix B NRC inspe : ions have documented examples of qualification activities by vencors that were not performed under an appropriately controlled quality assurance prograr.
The Rockbestos Ceccany (NRC Inspection 99900277/83-02), BIW Cable Systems (NRC Ins:ecticn 99900253/E3-01), American :nsulated Wire (NRC Irspection 99900399/
Ei-01), anc Anacenda Cable and Wire (90 Inspection 99900230/E3-01) are exan:les wnere testing was not conducted under the control of an appropriate QA program.
NRC Inspection 99900921/83-02 documents examples where Rockbestos imposed no cuality or technical requirements on its test laboratory, FRC.
FRC was not recuired to test in accordance with any established -recuirements except an
" implicit understanding that FRC would apply their highly regarded prcfessional ethics, experience, and skills in the performance of testing."
c.
Inacetua:e Feview, Acor: val, or Certification by Vencors of Qual"ication Test Resuits Inacecuate review, apprcval, or certification by vendors has been noted during NEC inspecticns.
Reckbestes-(NRC Ins;ection 99900277/E3-01) submitted to Eechtel a cualificad en report and a certificate of compliance signed by a Rocktestos pr:fessicnal encineer.
During an audit cf Rock:es:Os, the NRC establishec that Rc:ktes. s' re.iew and a::reval process 'er :"s :aali"catice : :9 Par was inace:; ate.
Discrecancies :steeen :ne "na'.
- .f :af:r e: r: En: :te su:-
ocr:ir.; ca:a were noted.
Test ecui;mer: an:
rs
- ten
- ation <e-e ::ss vec to I
have inade:uate resciuticn te record loss-cf-c :'an:-accicert (LOCA) test cara-re:ers anc fun::icning of tes: s ecimers curin; tre testinc.
Tes: ecui;ren:
as e':ter Ort:erly calibrated ner under :ne c:n:rci of the calibra:icn syste.
3urinc an NRC inspectice at ranMin Research Center (N C :ns:ection 9990092'..'
53-01),thedirectorofnutiearengineeringindica:ec:naterer;ineerhacnc teer. tecnnically qualifiec :: per#:rr ar. appropriate review for a qualifica:icn
- es: ;ian Or. whicn the engineer actec as reviewer.
o o
IN 85-XX March
, 1985 Page 4 of 6 NRC also has noted that vendors sometimes certify that the intent of applicable standards was satisfied rather than certify that vendor qualification efforts fulfill acceptance criteria as stated in applicable standards and specifications.
For example, during NRC inspections at FRC (NRC Inspection 99900921/83-02) regarding Rockbestos cable qualification activities, it was noted that FRC did not certify to meeting all the requirements and failure criteria of IEEE Stds. 323 and 383, but stateo instead that the obiective of the test was "to demonstrate performance of electrical cables for Class 1E service in nuclear power generating stations in accordance with guidelines presented in IEEE Stds. 323-1974 and 383-1974." This is not a certification that the test met any of the recuirements of these standards.
FRC also performed qualification testing of Brand Rex cable (NRC Inspection 99900325/84-01) but did not make a certification statement that the equipment met test criteria / requirements of IEEE Stds. 323-1974 and 3E3-1974.
The FRC certification simply states that this report is a true account of the test conducted and the results obtained.
FRC also has performed qualificati,on testing for AIW (NRC Inspections 99900399/84-01 and 99900921/83-02).
The reports state that IEEE Stds. 323 and 383 will be used as guidelines.
FRC cable qualification 2
reports frecuently do not ecuate Arrhenius aging parameters to design life, service conditions, and qualified life.
BIW Cable Systems performec ceneric and/or research cEVEiccren: [R$D) testin9 of cable for nuclear application (NRC Inspection 999002S2/E3-02) and after successful testing of a product several times, the R&D results are excerpted into a qualification report and certified as meeting applicaole recuirements.
BIW also makes reference to a cualification report fcr GE siliccne cables and argues that its product is similar.
Detailed cascriptions of NRC #indings and results of these inspections are publishec in NUREG-00 0, entitled " Licensee Centractor anc Vencer inspection Status Recort," Volur.es 5, 7, anc B.
This NUREG is published cuar erly by the NRC, and it can be cbtained frcm the National Technical Infermation Service, Springfield, Virginia 22161.
Correspcndence with contractors and vendors relative to tne inspection data contained in NUREG-004G is placed in the NRC Public Occumer: R0cm, 1212 H Street, N.
W., Wasnington, D.C.
20555.
Discussien:
The de'iciencies cescr'ted in this notice resulted f-:r a eview of the venccr's cual'#i:a.i:r ac
'i'-'Es against the acclicaf e :-ocu erent document requirerent or, in the case of cener'c cualification, agains tne ecolicaole'OA criteria.
The exten; :: whicn r.sse ceficiencies may affect the valicity of ecuioment ouali":stice aill depend on plant speci#ic c:rsideraticns.
For exampie, the cualification c: curer:a-ion requirements for ecuipment qualified under DOR Guidelines may nct te as extensive as for ec.ui; rent cualified to the requirements of 10 CFR 50.49.
IN 85-XX March
, 1985 Page 5 of 6 An overall assessment of identified deficiencies suggests that some vendor qualification activities may not adequately support the applicable NRC require-ments and emphasi:es 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.
In accordance with the requirements of Criteria IV, VII, and XVII of 10 CFR 50, Appendix B, licensees are reminded of the following:
(1) licensee (and vendor) procurement documents should clearly identify any certification responsibilities to each vendor and subvendor; (2) licensee audits of vendors should monitor the vendor certification process and ensure that certifications are supported by adequate qualification facilities, cualification documentation, and quality assurance practices; and (3) requirements concerning record retention (duration),
location, storage, preservation, and safekeeping as specified in the equipment specifications, purchase orders, and testing contracts also snould be verified.
Documentation frem vendors and test laboratories fom the basis for me'eting the eouicment cualification recuirements of paragraphs (d), (e), (f) and (j) of i
10 CFR 50.a9.
This documentation may include procurement specifications, test plans, test procedures, test logbooks, cualification test reports, test data, analyses and :crrective action to resolve test ancmalies, test conf'gura:icns anc interfaces, and cuality assurance informaticn.
The.following are areis in which this documentation has been found deficient.
1.
Service reouirements:
Equipment operability and functional requirements curing ncrmai, acticent, and postaccident conditions have not been clearly demonstrated by the qualification test report.
Environmental parameters, mechanical leadings, electrical loadings, and operability time recuirements costulatec fer accident and postaccident conditions nave not beer, ervelcrec 1
by supp;rtir.g ca:a and cocumented in the cualification report.
2.
Testinc consice-at cns:
Aging analyses have not censicered dese rate and sequence (orcer Of raciation and thermal aging) effects and normal environmental parameters along wi;h Operating conditions of the ecuipment being cualified.
.e nake, mecel.umter, perfermance characteristics, design features, in: c;erati:nal rec.:d rements c# the ecuipment being cuai -
" ed are nct s' a
- the es: e :J :re r.:.
Se "irstallec concition" arc "associa:ec ::- a:
- in e #ates"
- # scu : s': :s r; :.al4#iec are nt;
)
similar :c tne ;T n:inc
- nfigura
't-a r.: conrecting interfaces c# ine :es; l
eouipment.
Devia ',cns frcm :nis s'rilarity have nct been justified by the
{
reviewer anc cc ; ertec in tre EC #ile.
l i
3.
Test ancmalies:
All test failures anc ancmslies have nt; :.een cc:vmer.:ed in e.c.ua nfication tes:
e:cr: a.d *as resciu-icr at:/:r cor ective action c each failure and anomaly been svaivated.
Os "#4:a.icn has not been provicec as to why the ;r:pesec resciutien ance Or correct've action describec in the test reper: is applicable to the specific plant.
Just #ication has l
nt; been prcvided as :: why the : rrective action wiii not create a safetv
~
haIsrd to the Opera-i:r tf the piar.:.
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IN 85-XX
+
March 1985 t
Page 6 of 6 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.
While there may be specific j
problems applicable to a particular util.ity, the staff expects that user i
utilities will consider the overall applicability of the above information in j
j' establishing' qualification of safety-related equipment.
No specific &ction or written response is required by this information notice.
If you have any questions regarding.this notice, please contact the Regional Administrator of the appropriate NRC regional office or this office.
I f
Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response
{
Office of Inspection and Enforcement Technical
Contact:
G. T. Hubbard I
(301) 492-9759
}
Attachnent:
List. 0f Eecently Issuec IE Information Notices I
y l
I I
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1 I
m SSINS-6835 K
j IN 85-XX f
I UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 April
, 1985 IE INFORMATI0M NOTICE NO. 85-XX:
bEFICIENCIESINEQUIPMENTQUALIFICATION TESTING AND CERTIFICATION PROCESS t
f Addressees:
All holders of a nuclear power reactor operating license ('0L) or construction permit (CP).
[
Purpose:
4 N-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 NpC during its review of cualification activities.
NRC observations suggest that rece vendor l
cusiificatier activities and practices mcy r.ot provide a suf ficip. basis for ctvalification certification.
It is suggested that recipients review this information for specific and p
generic applicability tc ensure that documentation. supporting cnvironmental W
oualification of safety-related equipment at their facilities is cc:rplete.
Sugcestions contained in this riotice do not corstitute NRC requirements;
~
f there# ore, no specific iction or response is recuired.
rescription of Circumstances:
10 CFC. 50.49, Regulatory Guide 1.59 (Revision 1, June 1984), IEEE Stds. 3'23-1974 anc 323-1983 each require auditable information demonstrating qualification to provide continuing assurance to licensee management and the NRC that eovipment in use is qualified for the entire period during which it is installed in thC i'
nuclear pcwer plant.
10 CFR 50,. Appendix E, provides quality assurancs require-rerts for the gereration of all elements cf oualification files.
IEEE Std. 323-1974, Section 8 (endorsed by Pegula. cry Guide 1.E9), requires that indO.t ual elements of cuslification files be reviewed and arprcvec by the licensee.
S'M e July 1982, the VPB has actively inspecteo vendcr qualification effcrts for.
conpliance to these NRC requirements.
Inspections have been perferred at ir.ufccturirg facilities, independent testing laboratories, architect engineers, fSSS suppliers.
4 n:
l FC observations at the vendor level provide exacoles where mere active licensee participation in the cualification effort should have occurred.
In some cases,.
1
c-IN 85-XX April 1985 Page 2 of 4 certification of Qualification is now difficult to justify because of documen-tation 'and test practices employed by vendors.
Some examples of NRC findings follow.
1.
QualificationIctivitiesnotperformedunderaQAP'rogramconsistentwith 10 CFR 50, Appendix B SeveraHnstances-wereobservedwhen6ualificationtestingof Class IE equipment was conducted without appropriate QA programs
-(PS9 +ae+e ""d M -suppetwe+ificaticrrh.
No QA requirements were imposed on organizations providing safety related services (such as irradiation, calibration, analyses) associated with the qualification process.
2.
Qualification fest Report conclus' ions not supported by test data or test data not available
-The test profiles shown in some Oualification reports were not actually achieved during test. ~
Seneal' reports identified specimens or materials which were c
different from these actually tested.
Some 'fest records which-were--examined showed inadequate sensitivity / resolution of test equipment.
Documentation required by the standards referenced in the test report was not available.
(Test plans, equipment lists, calibration re:ords.)
./
.irne w rai instances, test anomalies were not adequately reported or evaluated.
In--some-eases, iimilarity between test specirens and items to be qualified was not established.
3.
Documentation to support the validity of oualification not maintained for life: ire of the equipment 5,upportingtestdatadestroyedafterEyears.
c 4.
nadecuate review, approval or certification of test results Interfaces / responsibilities of organizatiens involved in the cualification process not clearly defined.
Test reports contain statemants that testing satisfies the e.
" guidelines" or " intent" of standards referenced in the specification.
i-4 m
mm-m
IN 85-XX April 1985 Page 3 of 4 Detailed descriptions of NRC findings and results of these inspections are published in NUREG-0040, entitled " Licensee Contractor and Vendor Inspection Status Report," Volumes 6, 7, and 8.
NRC, and it can be obtained from the National Technical Information Springfield, Virginia. 22161.
Correspondence with contractors and vendors relative to the inspection data contained in NUREG-0040 is placed in the NRC Public Document Room, 1212 H Street, N.
W., Washington, D.C.
20555.
Discussion:
The deficiencies described in this notice resulted from a review of the 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 suggests that some vendqr qualification activities may not adequately support the applicable NRC require-ments and emphasizes the need for increased licensee attention to the adequacy of their vender prncurement control practices for qualification activities, and the definition of responsibilities and interfaces in the qualification process.
equipment qualification requirements of paragraphs (d), (
This documentation may include procurement specifications, test plans, test procedures, test logbooks, qualification test reports, test data, analyses and ccrrective action to resolve test enomalies, test configurations j
and interfaces, and quality assurance information.
The NRC staff considers the above identified deficiencies to be representative exampies of problems with vendors and test laboratories providing qualification services to other vendors and user utilities. While there may be specific problems applicable to a particular utility, the staff expects that user utilities will consider the overall applicability of the above infccmation in establishing qualification of safety-related equipment.
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.IN 85-XX April 1985 g
l Page 4 of 4 l-No specific action or written response ~is required by this information notice.
If you have any questions regarding this notice, please contact the Regional Administrator of, the appropriate NRC regional office or this office.
t L
p l
Edward L. Jordan, Director l
Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical
Contact:
G.'T. Hubbe.rd
- (301) 492-9759
Attachment:
List of Recently Issued IE Information Notices i
l l
l
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-4
7e
- 1 " " -
IN 85-XX-April
, 1985 Page 4 of 4
-No-specific action or written response is required by this information notice.
.If you have.any' questions regarding this notice, please contact the Regional Administrator of the appropriate NRC regional _ office or this office.
Edward L. Jordan,. Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical
Contact:
G. T. Hubbard
- (301) 492-9759'
Attachment:
List. of. Recently -Issued.IE Information Notices P
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SC/VFB:DCA51P BC/VFB:DQASIP-DIR:00AVT PC/DEPER/IE-TECF ED/IE Uc 'epovs:5am CG7ech BKGrimes CLBaer CGable e
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s.
Recent EQ Test Facility Inspection Res,ults The following generic EQ problems were identified during EQ inspections conducted from August 1983 thru Jur:e 1984.
1.
A problem in the area of documentation is the absence of direct certifi-cations or statements that components tested meet the technical requirements of IEEE 323-1971/1974 and daughter standards such as'IEEE 383-1974.
In some cases the certifications have been found false, in that, the vendor h
has certified that components and equipment met all QA and technical require-
--ments when, in fact, they did not meet all requirements.
In other cases the artification statement is written in such a loose manner that it ooes n'. certify that the requirements were met but simply certifies that the final report is a true account of the test conducted and the results obtained.
2.
A problem was identified where there was a lack of sufficient auditable supporting data for qualification reports.
This fact, combined with the fact that tne testing was conducted as research testing not under any ka OA controls raises doubt of the qualification status of the tested items.
The gi:neric question is what it the qualification status of a piece of equipment if there is not sufficient auditable data to support qualification.
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a r.
3.
At two A/E's the problem of how do they assure that their EQ data reviews and evaluations are based on good data when the licensee has not given them the task of performing audits on manufacturers relative to EQ activities.
Based on EQs inspection experience it appears that some addits of manufact-urers are being audited relativ'e to production activities and EQ activities are excluded from the audit process.
This fact is supported by the numerous times that EQS has documented in inspection reports that EQ activities are not under QA controls.
If the A/E's have no way of closing the QA loop, then their evaluations are no better than the data provided by the licensee which may or may not be performing EQ audits.
4.
The generic problem of vendors performing EQ activities without any documented QA control of the activities was observed again in a number of vendors inspected for the first time.
,y D
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