HomeMy WebLinkAbout851159.tiff SINS No. : 6835
IN-85-40
UNITED STATES 1 enl1nT tRIPItt
NUCLEAR REGULATORY COMMISSION Li j [�'J
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555 MAY2 919gg
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.
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May 22, 1985
Page 2 of 3
1. Qualification activities not performed under a QA program consistent with
10 CFR 50, Appendix B
o Qualification testing of Class 1E 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 available
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).
o Test anomalies were not 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
Page 3 of 3
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.
`Edward . Jordan, 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 Auditability of Electrical 5/22/85 All power reactor
Equipment Qualification facilities holding
Records At Licensees' an OL or CP
Facilities
85-38 Loose Parts Obstruct Control 5/21/85 All PWR facilities
Rod Drive Mechanism designed by B&W
holding an OL or CP
85-37 Chemical Cleaning Of Steam 5/14/85 All pressure water
Generator At Milestone 2 reactor facilities
holding an OL or CP
84-55 Seal Table Leaks At PWRs 5/14/85 All power reactor
Sup. 1 facilities holding
an OL or CP
85-20 Motor-Operated Valve Failures 5/14/85 All power reactor
Sup. 1 Due To Hammering Effect facilities holding
an OL or CP
85-36 Malfunction Of A Dry-Storage, 5/9/85 All licensees
Panoramic, Gamma Exposure possessing gamma
Irradiator irradiators
84-52 Inadequate Material 5/8/85 All power reactor
Sup. 1 Procurement Controls On facilities holding
The Part Of Licensees And an OL or CP
Vendors
85-35 Failure Of Air Check Valves 4/30/85 All power reactor
To Seat facilities holding
an OL or CP
85-34 Heat Tracing Contributes To 4/30/85 All power reactor
Corrosion Failure Of Stainless facilities holding
Steel Piping an OL or CP
84-84 Deficiencies In Ferro- 4/24/85 All power reactor
Rev. 1 Resonant Transformers facilities holding
an OL or CP
OL = Operating License
CP = Construction Permit
SSINS No. : 6835
IN 85-39
UNITED NUCLEAR REGULATORYTCOMMISSION 1 ES WELD COt�li9 Cr .'I" j"
OFFICE OF INSPECTION AND ENFORCEMENT 11l fn ' ry ',
WASHINGTON, D.C. 20555 ill r � �
MAY 2 91985 1
May 22, 1985
GitEE[_EY. COQ
o.
IE INFORMATION NOTICE NO. 85-39: AUDITABILITY OF ELECTRICAL EQUIPMENT
QUALIFICATION RECORDS AT LICENSEES'
FACILITIES
Addressees:
All holders of a nuclear power reactor operating license (OL) or a construction
permit (CP).
Purpose:
This information notice is being issued to alert licensees of deficiencies in
the implementation of 10 CFR 50.49 requirements at operating facilities. These
deficiencies were identified during recent NRC inspections and relate to the
review and approval of qualification documents by licensees and auditability of
qualification files.
It is suggested that recipients review this notice for generic applicability
to ensure that their equipment files contain adequate and auditable documentation
to support environmental qualification requirements. Suggestions contained in
this notice do not constitute NRC requirements; therefore, no specific action or
response is required.
Description of Circumstances:
On May 23, 1980, the NRC issued Memorandum and Order CLI-80-21 specifying that
all holders of a nuclear power reactor OL or CP must meet the requirements set
forth in Division of Operating Reactors (DOR) guidelines and NUREG-0588.
In mid-1981, the NRC issued Safety Evaluation Reports (SERs) on environmental
qualification of safety-related electrical equipment to licensees of all
operating plants. Where additional qualification information was required,
licensees were directed to respond to the NRC within 90 days of receipt of the
SER. With technical support from the Franklin Research Center (FRC), the NRC
staff reviewed licensees' submittals and published the results in Technical
Evaluation Reports (TERs). These TERs became part of the new SERs for each of
the 71 operating plants that the staff reviewed. Subsequently, licensees
responded with commitments to correct specific deficiencies identified in the
TERs and schedules of completion dates to meet the qualification deadline
required by 10 CFR 50.49.
8505200590
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IN 85-39
May 22, 1985
Page 2 of 3
The staff has conducted a number of inspections at licensees' facilities to
review licensee implementation of 10 CFR 50.49 requirements and to verify that
TER corrective action commitments are being properly implemented. These
inspections have identified deficiencies in the contents and auditability of
document files used to support equipment qualification. Specific examples
follow:
1. Equipment qualification (EQ) files contained no indication that the
documentation contained in these files had been reviewed by the licensee
or that the licensee had determined the equipment to be qualified.
2. Handwritten material used to support qualification was not signed or
dated and showed no indication that this material had been verified or
approved.
3. The required postaccident operating time for equipment was not correlated
to qualified life as established in the test report.
4. The qualification of replacement equipment was not upgraded as required
by 10 CFR 50.49. Qualification of some replacement equipment was based
on previously allowed DOR guidelines that stated "equipment is considered
qualified for main steam line break (MSLB) environmental conditions if it
was qualified for a loss-of-coolant accident (LOCA) environment in plants
with automatic spray systems not subject to disabling single component
failures. " This basis of qualification is not acceptable without
additional justification for replacement equipment was procured and
installed after February 22, 1983.
5. The applicability of generic communications such as vendor technical letters,
Part 21 reports, and NRC information notices and bulletins affecting
qualification and performance of specific equipment were not considered
in establishing and maintaining the qualified status of the equipment.
6. Certain documents used to support qualification (procurement documents,
test reports, certificates of conformance, vendor correspondence, etc. )
were not contained in the files nor did the files reference where these
documents could be found.
7. Some reports discussed test anomalies and modifications to equipment during
testing but the licensee had not provided evaluations or analyses to assess
the applicability of this information to the qualification of the installed
equipment.
Discussion:
Licensees and permit holders are responsible for the adequacy and completeness
of documents and for the EQ review process used to support the qualification of
safety-related equipment at their facilities. Paragraph (j) of 10 CFR 50.49
states that a record of qualification, including documentation in paragraph (d)
of the regulation, must be maintained in an auditable form for the entire period
IN 85-39
May 22, 1985
Page 3 of 3
during which the covered item is installed in the nuclear power plant or is
stored for future use. Section 3 of IEEE-323-1971 and 1974 defines auditable
data as information that is documented and organized so as to be readily under-
standable and traceable to permit independent verification of inferences or
conclusions based on the information.
An EQ test report, in and of itself, does not completely support a determination
that equipment is qualified. In order to ensure that plant-specific requirements
are adequately considered, the following types of additional information may be
needed: (1) required postaccident operating time compared to the duration of
time the equipment has been demonstrated to be qualified; (2) similarity of tested
equipment to that installed in the plant (e.g. , insulation class, materials of
components of the equipment, and tested configuration); (3) evaluations of the
adequacy of test conditions, aging calculations for qualified life, and replace-
ment interval determination; (4) effects of decreases in insulation resistance
on equipment performance; (5) evaluations of test anamolies; and (6) applicabi-
lity of EQ problems reported in IE information notices and bulletins and their
resolution.
No specific action or written response is required by this notice. If you have
any questions concerning this notice, please contact the Regional Administrator
of the appropriate NRC regional office or this office.
EdwarV J- ordan, Director
Divis' 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 85-39
May 22, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-38 Loose Parts Obstruct Control 5/21/85 All PWR facilities
Rod Drive Mechanism designed by B&W
holding an OL or CP
85-37 Chemical Cleaning Of Steam 5/14/85 All pressure water
Generator At Milestone 2 reactor facilities
holding an OL or CP
84-55 Seal Table Leaks At PWRs 5/14/85 All power reactor
Sup. 1 facilities holding
an OL or CP
85-20 Motor-Operated Valve Failures 5/14/85 All power reactor
Sup. 1 Due To Hammering Effect facilities holding
an OL or CP
85-36 Malfunction Of A Dry-Storage, 5/9/85 All licensees
Panoramic, Gamma Exposure possessing gamma
Irradiator irradiators
84-52 Inadequate Material 5/8/85 All power reactor
Sup. 1 Procurement Controls On facilities holding
The Part Of Licensees And an OL or CP
Vendors
85-35 Failure Of Air Check Valves 4/30/85 All power reactor
To Seat facilities holding
an OL or CP
85-34 Heat Tracing Contributes To 4/30/85 All power reactor
Corrosion Failure Of Stainless facilities holding
Steel Piping an OL or CP
84-84 Deficiencies In Ferro- 4/24/85 All power reactor
Rev. 1 Resonant Transformers facilities holding
an OL or CP
85-33 Undersized Nozzle-To-Shell 4/22/85 All power reactor
Welded Joints In Tanks And facilities holding
Heat Exchangers Constructed an OL or CP
Under The Rules Of The ASME
Boiler And Pressure Vessel
Code
OL = Operating License
CP = Construction Permit
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