Information Notice 1985-40, Deficiencies in Equipment Qualification Testing and Certification Process: Difference between revisions

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{{#Wiki_filter:SSINS No.: 6835 IN 85-40 UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:SSINS No.: 6835 IN 85-40


COMMISSION
===UNITED STATES===
NUCLEAR REGULATORY COMMISSION


OFFICE OF INSPECTION
===OFFICE OF INSPECTION AND ENFORCEMENT===
WASHINGTON, D.C.


===AND ENFORCEMENT===
20555
WASHINGTON, D.C. 20555 May 22, 1985 IE INFORMATION


NOTICE NO. 85-40: DEFICIENCIES
===May 22, 1985===
IE INFORMATION NOTICE NO. 85-40:  


IN EQUIPMENT
===DEFICIENCIES IN EQUIPMENT QUALIFICATION===
 
TESTING AND CERTIFICATION PROCESS
===QUALIFICATION===
TESTING AND CERTIFICATION
 
PROCESS


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


permit (CP).
permit (CP).


==Purpose==
==Purpose==
: This information
:
 
This information notice is to alert licensees that quality-related deficiencies
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
in the qualification documentation, review, approval, and certification process


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


environmental
review of qualification activities.


qualification
===NRC observations suggest that some vendor===
qualification activities and practices may not provide a sufficient basis for


of safety-related
qualification certification.


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


at their facilities
applicability to ensure that documentation supporting environmental qualification


is complete.
of safety-related equipment at their facilities is complete.


Suggestions
Suggestions


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


in this notice do not constitute
specific action or response is required.


NRC requirements;
==Description of Circumstances==
therefore, no specific action or response is required.Description
:
10 CFR 50.49, Regulatory Guide 1.89 (Revision 1, June 1984), and IEEE Standards


of Circumstances:
323-1974 and 323-1983 each require auditable information demonstrating qualifi- cation to provide continuing assurance to licensee management and the NRC that
10 CFR 50.49, Regulatory


Guide 1.89 (Revision
equipment in use is qualified for the entire period during which it is installed


1, June 1984), and IEEE Standards 323-1974 and 323-1983 each require auditable
in the nuclear power plant.


information
10 CFR 50, Appendix B, provides quality assurance


demonstrating
requirements for the generation of all elements of qualification files.


qualifi-cation to provide continuing
IEEE


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


to licensee management
individual elements of qualification files be reviewed and approved by the


and the NRC that equipment
licensee. Since July 1982, the VPB has actively inspected vendor qualification


in use is qualified
efforts for compliance to these NRC requirements.


for the entire period during which it is installed in the nuclear power plant. 10 CFR 50, Appendix B, provides quality assurance requirements
===Inspections have been performed===
at manufacturing facilities, independent testing laboratories, architect-engineers, and nuclear steam supply system (NSSS) vendors.


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


of all elements of qualification
participation in the qualification effort should have occurred.


files. IEEE Standard 323-1974, Section 8 (endorsed
In some cases, certification of qualification is now difficult to justify because of documen- tation and test practices employed by vendors.


by Regulatory
===Some examples of NRC findings===
follow.


Guide 1.89), requires that individual
8505200600


elements of qualification
IN 85-40
May 22, 1985 1. Qualification activities not performed under a QA program consistent with


files be reviewed and approved by the licensee.
10 C 5, Appenx


Since July 1982, the VPB has actively inspected
I


vendor qualification
o


efforts for compliance
Qualification testing of Class lE equipment was conducted without


to these NRC requirements.
appropriate QA programs.


Inspections
o


have been performed at manufacturing
No QA requirements were imposed on organizations providing safety- related services (such as irradiation, calibration, and analyses)
associated with the qualification process.


facilities, independent
2. Qualification test report conclusions not supported by test data or


testing laboratories, architect-engineers, and nuclear steam supply system (NSSS) vendors.NRC observations
test data not availab e


at the vendor level provide examples where more active licensee participation
o


in the qualification
Test profiles shown in qualification reports were not actually achieved


effort should have occurred.
during test.


In some cases, certification
o


of qualification
Reports identified specimens or materials that were different from


is now difficult
those actually tested.


to justify because of documen-tation and test practices
o


employed by vendors. Some examples of NRC findings follow.8505200600
Test records showed inadequate sensitivity/resolution of test equipment.
IN 85-40 May 22, 1985 1. Qualification


activities
o


not performed
Documentation required by the standards referenced in the test report


under a QA program consistent
was not available (test plans, equipment lists, and calibration records).


with 10 C 5, Appenx I o Qualification
°
Test anomalies werenot adequately reported or evaluated.


testing of Class lE equipment
o


was conducted
Similarity between test specimens and items to be qualified was not


without appropriate
established.


QA programs.o No QA requirements
3. Documentation to support the validity of


were imposed on organizations
qualification not maintained


providing
for lifetime of the equipment


safety-related services (such as irradiation, calibration, and analyses)associated
o


with the qualification
Supporting test data were destroyed after five years.


process.2. Qualification
4. Inadequate review, approval, or certification of test results


test report conclusions
o


not supported
Interfaces/responsibilities of organizations involved in the


by test data or test data not availab e o Test profiles shown in qualification
qualification process were not clearly defined.


reports were not actually achieved during test.o Reports identified
o


specimens
Test reports contained statements that testing satisfied the


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


that were different
Detailed descriptions of NRC findings and results of these inspections are


from those actually tested.o Test records showed inadequate
published in NUREG-0040, "Licensee Contractor and Vendor Inspection Status


sensitivity/resolution
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


of test equipment.
Printing Office, Post Office Box 37082, Washington, D.C.


o Documentation
20013-7982.


required by the standards
IN 85-40
May 22, 1985 Correspondence with contractors and vendors relative to the inspection data


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


in the test report was not available (test plans, equipment
20555.


lists, and calibration
Discussion:
The deficiencies described in this notice resulted from the review of a vendor's


records).° Test anomalies
qualification activities against the applicable procurement document requirement


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


reported or evaluated.
An overall assessment of identified deficiencies (1) suggests that some vendor


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


between test specimens
of their vendor procurement control practices for qualification activities and


and items to be qualified
the definition of responsibilities and interfaces in the qualification process.


was not established.
Documentation from vendors and test laboratories form the basis for meeting the


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


to support the validity of qualification
This documentation may include procurement specifications, test plans, test procedures, test logbooks, qualification test reports, test data, analyses


not maintained
and corrective action to resolve test anomalies, test configurations and


for lifetime of the equipment o Supporting
interfaces, and quality assurance information.


test data were destroyed
The NRC staff considers the above-identified deficiencies to be representative


after five years.4. Inadequate
examples of problems with vendors and test laboratories providing qualification


review, approval, or certification
services to other vendors and user utilities. Although there may be specific


of test results o Interfaces/responsibilities
problems applicable to a particular utility, the staff expects that user


of organizations
utilities will consider the overall applicability of the above information in


involved in the qualification
establishing qualification of safety-related equipment.


process were not clearly defined.o Test reports contained
No specific action or written response is required by this notice.


statements
If you have


that testing satisfied
any questions regarding this notice, please contact the Regional Administrator


the"guidelines" or "intent" of standards
of the appropriate NRC regional office or this office.


referenced
ar l. orian, Director


in the specification.
===Divis n of Emergency Preparedness===
and ngineering Response


Detailed descriptions
===Office of Inspection and Enforcement===


of NRC findings and results of these inspections
===Technical Contact:===


are published
===G. T. Hubbard, IE===
(301) 492-9759 Attachment:


in NUREG-0040, "Licensee
===List of Recently Issued IE Information Notices===


Contractor
===Attachment 1===
IN 85-40


and Vendor Inspection
===May 22, 1985===
LIST OF RECENTLY ISSUED


Status Report," Volumes 6, 7, and 8. This report is published
===IE INFORMATION NOTICES===
Information


quarterly
Date of


by the NRC, and it can be obtained from the Superintendent
Notice No.


of Documents, U.S. Government
Subject


Printing Office, Post Office Box 37082, Washington, D.C. 20013-7982.
Issue


IN 85-40 May 22, 1985 Correspondence
Issued to


with contractors
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


and vendors relative to the inspection
5/22/85


data contained
===Equipment Qualification===
 
Records At Licensees'
in NUREG-0040
Facilities
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
Loose Parts Obstruct Control 5/21/85


regarding
===Rod Drive Mechanism===
Chemical Cleaning Of Steam


this notice, please contact the Regional Administrator
5/14/85


of the appropriate
===Generator At Milestone 2===
Seal Table Leaks At PWRs


NRC regional office or this office.ar l. orian, Director Divis n of Emergency
5/14/85 Motor-Operated Valve Failures 5/14/85


===Preparedness===
===Due To Hammering Effect===
and ngineering
Malfunction Of A Dry-Storage, 5/9/85


Response Office of Inspection
===Panoramic, Gamma Exposure===
Irradiator


and Enforcement
Inadequate Material


Technical
5/8/85


Contact: G. T. Hubbard, IE (301) 492-9759 Attachment:
===Procurement Controls On===
List of Recently Issued IE Information
The Part Of Licensees And


Notices
Vendors


Attachment
Failure Of Air Check Valves


1 IN 85-40 May 22, 1985 LIST OF RECENTLY ISSUED IE INFORMATION
4/30/85 To Seat
 
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
Heat Tracing Contributes To


At Milestone
4/30/85


2 Seal Table Leaks At PWRs 5/14/85 Motor-Operated
===Corrosion Failure Of Stainless===
Steel Piping


Valve Failures 5/14/85 Due To Hammering
Deficiencies In Ferro-
4/24/85


Effect Malfunction
===Resonant Transformers===
All power reactor


Of A Dry-Storage, 5/9/85 Panoramic, Gamma Exposure Irradiator
facilities holding


Inadequate
an OL or CP


Material 5/8/85 Procurement
===All PWR facilities===
designed by B&W


Controls On The Part Of Licensees
holding an OL or CP


And Vendors Failure Of Air Check Valves 4/30/85 To Seat Heat Tracing Contributes
===All pressure water===
reactor facilities


To 4/30/85 Corrosion
holding an OL or CP


Failure Of Stainless Steel Piping Deficiencies
===All power reactor===
facilities holding


In Ferro- 4/24/85 Resonant Transformers
an OL or CP


All power reactor facilities
===All power reactor===
facilities holding


holding an OL or CP All PWR facilities
an OL or CP


designed by B&W holding an OL or CP All pressure water reactor facilities
===All licensees===
possessing gamma


holding an OL or CP All power reactor facilities
irradiators


holding an OL or CP All power reactor facilities
===All power reactor===
facilities holding


holding an OL or CP All licensees possessing
an OL or CP


gamma irradiators
===All power reactor===
facilities holding


All power reactor facilities
an OL or CP


holding an OL or CP All power reactor facilities
===All power reactor===
facilities holding


holding an OL or CP All power reactor facilities
an OL or CP


holding an OL or CP All power reactor facilities
===All power reactor===
facilities holding


holding an OL or CP DL = Operating
an OL or CP


License CP = Construction
DL = Operating License


Permit}}
CP = Construction Permit}}


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

Latest revision as of 10:24, 16 January 2025

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)
v • d • e


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

Office of Inspection and Enforcement

Technical Contact:

G. T. Hubbard, IE

(301) 492-9759 Attachment:

List of Recently Issued IE Information Notices

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


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