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 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