United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 85-40: Deficiencies in Equipment Qualification Testing and Certification Process

                                                          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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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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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 
Page Last Reviewed/Updated Tuesday, November 12, 2013