Information Notice No. 84-44: Environmental Qualification Testing of Rockbestos Cables

                                                             SSINS NO: 6835 
                                                             IN 84-44      

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

                                June 8, 1984

Information Notice No. NO 84-44:    ENVIRONMENTAL QUALIFICATION TESTING OF 
                                   ROCKBESTOS CABLES 

Addressees: 

All holders of a nuclear power reactor operating license (OL) or 
construction permit (CP). 

Purpose: 

This information notice is provided to inform licensees and construction 
permit holders of potential generic problems regarding Rockbestos 
environmental qualification (EQ) testing of Class 1E electrical cables. 
Addressees are expected to review the information for applicability to their
facilities. No specific action or response is required. 

Description of Circumstances: 

The NRC has performed a number of inspections of the QA programs established
at several environmental testing facilities. This effort was started in late
August 1982 to assess the facilities' establishment and implementation of a 
QA program based on the requirements of 10 CFR Part 50, Appendix B. Several 
such inspections were recently conducted at the Rockbestos Company in New 
Haven, Connecticut. The NRC inspection team reviewed qualification related 
documents such as EQ reports, associated supporting items including test 
plans, test procedures, test instruments, test log books, related raw data 
and QA documents. The inspections revealed several QA nonconformances and 
related testing/documentation problems. Details of these nonconformances and
inspection findings are documented in the following NRC Inspection Reports: 
99900277/83-01, 99900277/83-02, and 99900277/83-04. Listed below are some of
the QA nonconformances and related testing/documentation problems which may 
affect the qualification of Rockbestos cables that are installed at 
licensees' facilities: 

1.   The Rockbestos Company did not impose quality assurance/test control 
     requirements on an outside test organization which performed testing 
     (LOCA/ HELB) during the period of 1969-1979. 

2.   The Rockbestos Company did not establish and implement a QA program in 
     accordance with 10 CFR Part 50, Appendix B requirements to control 
     Rockbestos EQ testing; i.e., the EQ program was controlled by a 
     Rockbestos engineering organization which was not under a QA program 
     until 1983. 
.

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                                                               June 8, 1984 
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3.   As a result of inadequate QA controls, testing and the required 
     documentation were not properly controlled. Several discrepancies 
     between final qualification reports and supporting test data were 
     found. 

4.   Rockbestos' QA and engineering organizations did not impose QA and 
     technical requirements/acceptance criteria on organizations that 
     performed qualification testing for Rockbestos between 1969 and 1979. 
     Furthermore, no supporting test data for these tests were available for
     audit at Rockbestos or subtier test organizations. 

5.   Test equipment and instrumentation were observed to have inadequate 
     resolution to record LOCA test parameters and functioning of test 
     specimen during testing. 

6.   Test equipment was not properly calibrated or under the control of the 
     calibration system. An internal Rockbestos audit dated May 10, 1983, 
     documented these generic deficiencies in their calibration system. 

7.   Test plans, acceptance criteria, and test procedures for certain 
     qualification tests were not made available during the NRC audits. 

8.   A number of test deficiencies, deviations, and other anomalies were not
     documented and evaluated in the test reports. 

Discussion: 

The results of the NRC inspections show that several deficiencies were 
present in the Rockbestos Company qualification programs in effect at time 
of the audit. Individually, some deficiencies could be adequately 
reconciled, but taken collectively, the nature and number of deficiencies 
identified would not adequately demonstrate that acceptable qualification 
had been established. It appears that the validity of some of the Rockbestos
qualification reports is in doubt, however, the NRC staff has concluded at 
this time that no immediate safety problem exists in the use of Rockbestos 
cables. The NRC staff considers that it is the responsibility of the user 
utilities to review the information provided above and take applicable 
corrective action to ensure the qualification of Rockbestos cables installed
in their plants. The following possible courses of corrective action should 
be considered: 

     a)   Perform a valid qualification test of the installed Rockbestos 
          cables. 

     b)   Obtain documentation from other available qualification tests 
          already performed and determine its applicability to the installed
          cables. 
.

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                                                               June 8, 1984 
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     c)   Perform analyses of existing qualification reports applicable to 
          the installed cables to ensure that the documentation relied upon 
          to demonstrate environmental qualification supports such a 
          conclusion. 

The NRC staff considers this review to be part of the on-going activities 
that the licensees are currently undertaking to resolve other environmental 
qualification deficiencies to meet the deadline and requirements set forth 
in the EQ final rule, 10 CFR 50.49. 

Questions regarding details of, and resolutions to the NRC inspection 
findings described above should be directed either to the equipment 
manufacturer, or the cognizant design/test agency. If you have questions 
regarding this information notice, 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:  R. G. LaGrange, NRR
                    (301) 492-8208

                    N. B. Le, IE
                    (301) 492-9673

Attachment:
List of Recently Issued IE Information Notices