Information Notice 2014-11, Recent Issues Related to the Qualification of Safety-Related Components
| ML14149A520 | |
| Person / Time | |
|---|---|
| Issue date: | 09/19/2014 |
| From: | Marissa Bailey, Michael Cheok, Kokajko L NRC/NMSS/FCSS, Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Popova E, NRR/DPR/PGCB, 415-2876 | |
| References | |
| IN-14-011 | |
| Download: ML14149A520 (8) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555-0001 September 19, 2014 NRC INFORMATION NOTICE 2014-11: RECENT ISSUES RELATED TO THE
QUALIFICATION AND COMMERCIAL GRADE
DEDICATION OF SAFETY-RELATED
COMPONENTS
ADDRESSEES
All holders of and applicants for a specific source material license under Title 10 of the Code of
Federal Regulations (10 CFR) Part 40, Domestic Licensing of Source Material.
All holders of and applicants for a construction permit or an operating license for a nonpower
reactor (research reactor, test reactor, or critical assembly) or a medical isotope production
facility under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, except those that have permanently ceased operations.
All holders of an operating license or construction permit for a nuclear power reactor issued
under 10 CFR Part 50, except those who have permanently ceased operations and have
certified that fuel has been permanently removed from the reactor vessel.
All holders of and applicants for a power reactor early site permit, combined license, standard
design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and
Approvals for Nuclear Power Plants. All applicants for a standard design certification, including
such applicants after initial issuance of a design certification rule.
All contractors and vendors that directly or indirectly supply basic components to U.S. Nuclear
Regulatory Commission (NRC) licensees under 10 CFR Part 50 or 10 CFR Part 52.
All holders of and applicants for a fuel cycle facility license under 10 CFR Part 70, Domestic
Licensing of Special Nuclear Material.
All holders of and applicants for a special nuclear material license authorizing the possession, use, or transport of formula quantities of strategic special nuclear material under
All holders of and applicants for a gaseous diffusion plant certificate of compliance or an
approved compliance plan under 10 CFR Part 76, Certification of Gaseous Diffusion Plants.
PURPOSE
The NRC is issuing this information notice (IN) to inform addressees of issues identified
during NRC vendor inspections with the qualification 1 and commercial grade dedication of
safety-related replacement components. The NRC expects that recipients will review the
information for applicability to their facilities and consider actions, as appropriate, to avoid
similar problems. The NRC acknowledges that many nonreactor facilities (such as those
licensed or certified under 10 CFR Parts 40, 70, or 76) have quality assurance requirements
and terminology that may differ from those applicable to nuclear power plants 2. These licensees
should review the content of the IN for awareness and consider the applicability of the
circumstances described in the IN to ensure the availability and reliability of components that
are relied upon for the safe operation of nonreactor facilities. Suggestions contained in this IN
are not NRC requirements; therefore, no specific action or written response is required.
BACKGROUND
Criterion III, Design Control, of Appendix B of 10 CFR Part 50, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants, requires that measures be established
for the selection of parts and equipment essential to the safety-related functions of structures, systems, and components. Criterion III also requires that measures be established for verifying
the adequacy of the design, such as by the performance of design reviews, by the use of
alternate or simplified calculation methods, or by the performance of a suitable testing program.
Vendors and contractors that supply safety-related components to licensees adhere to this
requirement, when imposed on them by NRC licensees.
The NRC also has more specific requirements related to the qualification of certain classes of
safety-related equipment. Vendors and contractors that supply safety-related components to
licensees adhere to these requirements, when imposed on them by NRC licensees. These
requirements include, but are not limited to:
- 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety
for Nuclear Power Plants, which states that each item of electric equipment important
to safety must be qualified by one of the following methods:
(1) Testing an identical item of equipment under identical
1 Qualification, as used in this notice, includes all testing and analysis required by NRC
regulations as necessary to demonstrate that equipment and components can be relied upon
to perform their intended safety function under all design basis conditions. Equipment
qualification includes testing and analysis in areas such as functional, environmental, seismic, and radio electromagnetic/frequency interference (EMI/RFI).
2 With regard to facilities licensed or certified under 10 CFR Parts 40, 70, or 76, (1) Appendix B to
10 CFR Part 50 applies only to facilities that engage in plutonium processing and fuel fabrication
under 10 CFR Part 70, and (2) terms such as items relied on for safety are used in lieu of
safety-related. conditions or under similar conditions with a supporting
analysis to show that the equipment to be qualified is
acceptable.
(2) Testing a similar item of equipment with a supporting
analysis to show that the equipment to be qualified is
acceptable.
(3) Experience with identical or similar equipment under similar
conditions with a supporting analysis to show that the
equipment to be qualified is acceptable.
(4) Analysis in combination with partial type test data that
supports the analytical assumptions and conclusions.
- Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, General Design Criterion 2, Design Bases for Protection Against Natural Phenomena, which states in part, Structures, systems, and components important to safety shall be
designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform
their safety functions.
- Appendix A to 10 CFR Part 100, Seismic and Geologic Siting Criteria for Nuclear
Power Plants, Paragraph VI, Application to Engineering Design, which states in part:
The engineering method used to insure that the required safety
functions are maintained during and after the vibratory ground
motion associated with the Safe Shutdown Earthquake shall
involve the use of either a suitable dynamic analysis or a
suitable qualification test to demonstrate that structures, systems, and components can withstand the seismic and other
concurrent loads, except where it can be demonstrated that the
use of an equivalent static load method provides adequate
conservatism.
Industry standards that apply to the design and qualification of safety-related equipment include:
- ASME Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in
Nuclear Power Plants.
- Electrical Power Research Institute, Critical Characteristics for Acceptance of
Seismically Sensitive Items (CCASSI), Product ID TR-112579, dated March 19, 2007.
- Institute of Electrical and Electronics Engineers (IEEE) Std. 323-1974, IEEE Standard
for Qualifying Class IE Equipment for Nuclear Power Generating Stations.
- IEEE Std. 344-1975, IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations.
NRC guidance documents that apply to the design and qualification of safety-related equipment
include:
- IN 2014-04, Potential for Teflon Material Degradation in Containment Penetrations, Mechanical Seals and Other Components.
- Regulatory Guide (RG) 1.29, Seismic Design Classification, dated March 2007.
- RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety
for Nuclear Power Plants, dated June 1984.
- RG 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and
Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, dated September 2009.
- RG 1.180, Guidelines for Evaluating Electromagnetic and Radio-Frequency
Interference in Safety-Related Instrumentation and Control Systems, dated
October 2003.
- RG 1.209, Guidelines for Environmental Qualification of Safety-Related
Computer-Based Instrumentation and Control Systems in Nuclear Power Plants, dated
March 2007.
To ensure compliance with the above regulations, industry standards, and regulatory guidance, licensees require that their vendors and contractors provide reasonable assurance that the
supplied safety-related equipment meets system performance requirements. To accomplish
these objectives, vendors perform testing and analyses that form the basis for the equipment
qualification.
DESCRIPTION OF CIRCUMSTANCES
During recent vendor inspections, the NRC identified deficiencies in certain aspects of vendors
qualification and commercial grade dedication programs. The following examples associated
with the qualification and dedication of safety-related equipment were identified during recent
NRC vendor inspections. In response to the NRC-identified issues, the vendors entered the
issues into their corrective action programs3 and took appropriate corrective measures.
1. On June 8, 2012, an NRC vendor inspection identified that Nuclear Logistics, Inc. had
not established sufficient design controls for EMI/RFI qualification testing of
safety-related pressure and flow transmitters. Additional information appears in NRC
3 The details regarding the identified issues and the associated vendor responses can be found on
the NRCs public Web site at http://www.nrc.gov/reactors/new-reactors/oversight/quality- assurance/vendor-insp/insp-reports.html. Vendor Inspection Report 99901298/2012-201, dated July 3, 2012, on the NRCs public
Web site in the Agencywide Documents Access and Management System (ADAMS)
under Accession No. ML12179A375.
2. On May 18, 2012, an NRC vendor inspection identified that Kinectrics had not taken
sufficient actions to verify the applicability of previous testing to their supply of circuit
breakers to be used in safety-related applications. Additional information appears in
NRC Vendor Inspection Report 9901415/2012-201, dated July 2, 2012, on the NRCs
public Web site in ADAMS under Accession No. ML12179A413.
3. On March 7, 2013, an NRC vendor inspection identified that Scientech, a subsidiary of
the Curtiss-Wright Flow Control Company, had not taken sufficient actions to verify that
previous seismic qualification testing remained valid for production modules that
contained seismically sensitive relays for use in safety-related applications. Additional
information appears in NRC Vendor Inspection Report 99901320/2013-201, dated
April 5, 2013, on the NRCs public Web site in ADAMS under Accession
No. ML13093A071.
4. On March 21, 2013, an NRC inspection identified that Meggitt Safety Systems, Inc. had
not established sufficient design control parameters for the electrical testing of relays.
Additional information appears in NRC Vendor Inspection Report 99901421/2013-201, dated May 7, 2013, on the NRCs public Web site in ADAMS under Accession
No. ML13119A278.
5. On August 23, 2013, an NRC inspection identified that Argo Turboserve Corporation
Nuclear-NY had not established appropriate measures for controlling material changes
for environmentally qualified replicate interface boxes. Additional information appears
in NRC Vendor Inspection Report 99901429/2013-201, dated October 7, 2013, on the
NRCs public Web site in ADAMS under Accession No. ML13267A284.
DISCUSSION
This IN provides examples where vendors had not implemented sufficient controls to verify that
safety-related equipment supplied for use in nuclear power plants was qualified to meet its
design requirements. In these examples, the vendors were unable to provide reasonable
assurance that the supplied equipment would operate on demand and would meet its
performance requirements for the designed life of the components and under the full range of
operating conditions, up to and including design-basis accident conditions.
During recent inspections, the NRC identified issues with the implementation of processes
used by vendors to qualify components to perform their safety functions. The NRC had
identified issues both at original equipment manufacturers (OEMs) and at non-OEM or third- party suppliers. In some examples, the NRC staff identified issues associated with the
applicability of the past qualification testing to the recently supplied components.
With regard to components supplied by OEMs, the NRC identified instances where the OEM
had not maintained sufficient design controls for the specific components, as necessary to establish the validity of past qualification testing to the components currently being supplied.
This includes controls to evaluate changes to the material, design, or manufacturing of
applicable components.
For replacement components no longer available from an OEM, non-OEM suppliers often
procure components as commercial grade items (CGIs) and then dedicate the components to
perform their intended safety functions as part of a commercial grade dedication (CGD)
process 4. The dedication process includes verification of the components critical
characteristics, including functional, environmental, seismic, and EMI/RFI capability as well as
other applicable qualification requirements specific to the components application. In some
instances, the verification process credits testing or analysis that was performed previously for
similar components. The NRC has identified examples where this previous qualification testing
and analysis was improperly applied, as similarity between the previously tested and the
currently supplied components was not established. This is of particular concern for commercial
grade items, as changes made by a commercial OEM could impact the components
qualification and could go undetected.
The NRC has provided guidance for the implementation of acceptable processes for the
qualification of components to perform their safety functions in various documents, as listed in
the
BACKGROUND
section of this IN. For example, the NRC staff accepted ASME Standard
QME-1-2007 in RG 1.100 (revision 3) for the qualification of mechanical equipment used in
nuclear power plants with applicable conditions. The process described in ASME QME-1-2007 as accepted in RG 1.100 (revision 3) may be applied to mechanical equipment to be used in a
nuclear power plant regardless of the equipments origin as a safety-related component or a
CGI. As discussed in this IN, inadequate implementation of the CGD process might result in
4 As defined in 10 CFR 21.3:
Dedication. (1) When applied to nuclear power plants licensed pursuant to
10 CFR Part 30, 40, 50, 60, dedication is an acceptance process
undertaken to provide reasonable assurance that a commercial grade
item to be used as a basic component will perform its intended safety
function and, in this respect, is deemed equivalent to an item designed
and manufactured under a 10 CFR Part 50, appendix B, quality
assurance program. This assurance is achieved by identifying the
critical characteristics of the item and verifying their acceptability by
inspections, tests, or analyses performed by the purchaser or third-party
dedicating entity after delivery, supplemented as necessary by one or
more of the following: commercial grade surveys; product inspections or
witness at holdpoints at the manufacturer's facility, and analysis of
historical records for acceptable performance. In all cases, the
dedication process must be conducted in accordance with the applicable
provisions of 10 CFR Part 50, appendix B. The process is considered
complete when the item is designated for use as a basic component.
(2) When applied to facilities and activities licensed pursuant to 10 CFR
Parts 30, 40, 50 (other than nuclear power plants), 60, 61, 63, 70, 71, or
72, dedication occurs after receipt when that item is designated for use
as a basic component. CGIs not being properly qualified to perform their safety functions. Particular attention to this
potential concern is necessary when an item will be qualified by an entity other than the OEM
where potential changes to the component design might impact its qualification. Therefore, care must be taken to ensure that replacement components are qualified to perform their safety
functions prior to installation in a nuclear power plant.
The references mentioned in the background section of this IN could assist vendors and
contractors with the development and selection of important critical characteristics on
qualification testing.
The NRC expects that recipients will review the information, links, and references provided in
this IN for applicability and consider actions, as appropriate, for their facilities to avoid similar
problems. However, no specific action or written response to the NRC is required for this IN.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below.
/RA/ A. Valentin for /RA/ M. Khanna for
Michael C. Cheok, Director Lawrence E. Kokajko, Director
Division of Construction Inspection Division of Policy and Rulemaking
and Operational Programs Office of Nuclear Reactor Regulation
Office of New Reactors
/RA/
Marissa G. Bailey, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Annie Ramirez, NRO
301-415-6780
E-mail: Annie.Ramirez@nrc.gov
301-415-2977 E-mail: Jeffrey.Jacobson@nrc.gov
Note: NRC generic communications may be found on the NRCs public
Web site, http://www.nrc.gov, under NRC Library/Document Collections.
OFFICE NRO/DCIP/EVIB NRO/DCIP/EVIB QTE NRO/DCIP/EVIB NRR/DE/EPNB
NAME ARamirez* JJacobson* Tech Ed* RRasmussen* DAlley*
DATE 08/05/14 07/24/14 08/01/14 08/14/14 08/26/14 OFFICE NRR/DIRS/IOEB NRR/DLR NRR/DPR/PGCB NRR/DPR/PGCB NRR/DPR/PGCB
NAME HChernoff (DGarmon MMarshall* APopova* TMensah* CHawes
DATE 08/27/14 08/25/14 08/27/14 08/27/14 08/28/14 OFFICE NRR/DPR/PGCB NMSS/FCSS NRO/DCIP NRR/DPR/PGCB NRR/DPR
NAME SStuchell MBailey MCheok AMohseni LKokajko(MKhanna
DATE 08/28/14 09/05/14 09/09/14 (TI
09/19/14 f ) f09/19/14
)