Information Notice No. 85-39: Auditability of Electrical Equipment Qualification Records at Licensees' Facilities

                                                         SSINS No.: 6835  
                                                          IN 85-39         

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                                May 22, 1985 

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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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 
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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 
understandable 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 replacement, interval 
determination; (4) effects of decreases in insulation resistance on 
equipment performance; (5) evaluations of test anamolies; and (6) 
applicability 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. 


                                   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