Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSINS.: 6835
IN 85-40
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
May 22, 1985
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 qualification 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 documentation and test practices employed by vendors. Some
examples of NRC findings follow.
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IN 85-40
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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.
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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 requirements, 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 L. Jordan, Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contact: G. T. Hubbard, IE
(301) 492-9759
Attachment: List of Recently Issued IE Information Notices
