Information Notice 1988-95, Inadequate Procurement Requirements Imposed by Licensees on Vendors
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATI6R
WASHINGTON, D.C. 20555
December 8, 1988 NRC INFORMATION NOTICE NO. 88-95:
INADEQUATE PROCUREMENT REQUIREMENTS
IMPOSED BY LICENSEES ON VENDORS
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
This information notice is being provided to alert addressees to potential
problems resulting from inadequate procurement requirements being imposed by
licensees on vendors supplying components under the ASME Code which may result
in the vendor's failure to implement critical portions of 10 CFR Part 50,
Appendix B, Quality Assurance (QA) requirements. It is expected that recipi- ents will review the information for applicability to their facilities and
consider actions, as appropriate, to avoid similar problems. However, sugges- tions contained in this information notice do not constitute NRC requirements;
therefore, no specific action or written response is required.
Description of Circumstances
On August 15-19, 1988, the NRC staff inspected Anchor/Darling Industries, Inc.
(A/DI), Hatfield, PA. The inspection included a review of A/DI's QA program, as it relates to the manufacture of mechanical shock suppressors (snubbers) for
safety-related applications. A/DI is a material supplier and is accredited by
the American Society of Mechanical Engineers (ASME) under a Quality Systems
Certificate.
As such, the quality requirements of the ASME Boiler and Pressure
Vessel Code,Section III, Article NCA-3800, apply.
A/DI's QA manual specifies that only load-bearing parts of the snubber are
subject to the quality requirements of Section III, Division 1, of the ASME
Code.
Subsection NF-2121 of Section III, "Permitted Material Specification,"
specifies that gaskets, seals, bushings, springs, compression spring
end-plates, bearings, retaining rings, washers, wear shoes, hydraulic fluids, etc., are exempt from the requirements of Article NF-2000, 'Material," and as
such do not require a Material Manufacturer's Certificate of Compliance pursu- ant to the provisions of NF-2130. The A/DI QA program does not address the
procurement and QA controls of the ASME Code exempt load-bearing parts. The
inspectors noted that A/DI considers several parts in the direct load path of
the A/DI mechanical snubber to be exempt from QA requirements because of the
NF-2121 exemption. These parts include the ball nut, ball bushing, thrust
881222j
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IN 88-95 December 8, 1988 race, ball bearing, and the load member on the AD-125 model snubber (125,000-
pound rated load). These parts are purchased commercial grade and appear not
to have the benefit of a dedication process or any other quality controls
necessary to assure adequacy of the critical characteristics of the parts.
Therefore, safety-related snubbers produced by A/DI contain direct load path
parts, procured commercially, that may not conform to the original tested
configuration.
In another example, the NRC received a 10 CFR Part 21 report on August 8, 1988 from the Southern California Edison Company regarding a deviation found on
parts in storage at the San Onofre Nuclear Generating Station (SONGS).
The
deviation involved cracks discovered in spare safety valve guide and bearing
assemblies in storage.
SONGS filed the Part 21 report on the basis that
failure of the valve'guide or bearing assembly could affect the operability of
the valve. The parts are utilized in Units 2 and 3 main steam safety valves
and were supplied by Crosby Valve and Gage Company, Wrentham, Massachusetts.
Because the valve guide and bearing assemblies are not pressure boundary parts, the parts were manufactured and supplied as commercial grade.
Crosby did not
consider these components to be critical and did not retain pertinent manufac- turing, procurement, and inspection records.
SONGS has since revised their
purchasing requirements to impose Appendix B or ANSI N45.2 requirements on
safety-related parts excluded from Section III requirements.
Discussion:
It is important that licensees place adequate requirements in procurement
documents to vendors to control the quality of safety-related components, equipment, and services and subsequently verify compliance through periodic
audits of the vendor's QA program.
Licensees are reminded that safety-related
components are to be manufactured under a QA program that meets 10 CFR Part 50
Appendix B requirements.
The NRC has determined that compliance with Section
III of the ASME Boiler and Pressure Vessel Code satisfies Appendix B require- ments for items covered by the Code.
However, this is not sufficient to ensure
that safety-related items exempt from Code requirements comply with Appendix B.
Licensees are reminded that they are responsible for ensuring that their
vendors meet Appendix B requirements for safety-related items.
Considering the
two above-described examples, it appears that past licensee audits of A/DI and
Crosby have not been effective in assuring compliance with regulatory
requirements.
It is important that purchase orders to companies specify compliance with
Appendix B as well as the ASME Code to assure that all parts with safety
functions have adequate quality assurance applied.
These examples further
reinforce the NRC's belief that additional attention is needed to improve the
effectiveness of licensee imposed procurement requirements on vendors to
control the quality of safety-related items.
IN 88-95 December 8, 1988 NRC previously conveyed concerns in Information Notice 88-35, "Inadequate
Licensee Performed Vendor Audits," that licensee audits of vendors may not be
effectively evaluating the vendor's QA program and its implementation, specifi- cally in the area of procurement. The examples discussed in this notice
indicate that licensee audits are not assuring that vendors apply adequate
quality requirements for all parts within an ASME component that have a safety
function.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Robert L. Pettis, Jr., NRR
(301) 492-3214 Attachment:
List of Recently Issued NRC Information Notices
IN 88-95 December 8, 1988 NRC previously conveyed concerns in Information Notice 88-35, "Inadequate
Licensee Performed Vendor Audits," that licensee audits of vendors may not be
effectively evaluating the vendor's QA program and its implementation, specifi- cally in the area of procurement.
The examples discussed in this notice
indicate that licensee audits are not assuring that vendors apply adequate
quality requirements for all parts within an ASME component that have a safety
function.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Robert L. Pettis, Jr., NRR
(301) 492-3214 Attachment:
List of Recently Issued NRC Information Notices
- SEE PREVIOUS CONCURRENCE PAGE.
OFC
- VIB:DRIS:NRR
- VIB:DRIS:NRR :VIB:DRIS:NRR
- TECH EDITOR
- C:VIB:DRIS:NRR:D:DRIS:NRR
______
________________
______________
______________
______________
______________
_____________
NAME
- RLPettis:jeh*
- ETBaker*
- UPotapovs*
- RSanders*
- EWBrach*
- BKGrimes*
DATE
- 10/07/88:mgc
- 10/16/88
- 10/18/88
- 10/18/88
- 11/25/88
- 11/28/88 OFC
- D:DOEA:NRR
- DD/DLPQ:NRR
- C/OGCB:DOEA:NRR:
NAME
- CERossi
- JZwolinski
- CHBerlinger*
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____________
DATE
- 12/ /88
/ :12/;Z/88
- 11/30/88:::
I
IN 88-XX
December XX, 1988 NRC previously conveyed concerns in Information Notice 88-35 that licensee
audits of vendors may not be effectively evaluating the vendor's QA program
and its implementation, specifically in the area of procurement.
The examples
discussed in this notice indicate that licensee audits are not assuring that
vendors apply adequate quality requirements for all parts within an ASME
component that have a safety function.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Robert L. Pettis, Jr., NRR
(301) 492-3214 Attachment:
List of Recently Issued NRC Information Notice
- SEE PREVIOUS CONCURRENCE PAGE.
OFC
- VIB:DRIS:NRR
- VIB:DRIS:NRR :VIB:DRIS:NRR
- TECH EDITOR
- C:VIB:DRIS:NRR:D:
______
________________-
____------------:--------------:
- --------------o5sff- NAME
- RLPettis:jeh*
- ETBaker*
- UPotapovs*
- RSanders*
- EWBrach*
_ _ ---:----------------:--------------: -------------- : -------------- :------------)
DATE
- 10/07/88:mgc
- 10/16/88
- 10/18/88
- 10/18/88
- 11/25/88
- 111Z6/88 OFC
- D:DOEA:NRRo
0bF-i:Hld
______
_____
_____
____
- -y---------4~---~-
~
- --------~--~--
--
NAME
- CERossi
DATE__11/_/8_- -
DATE
11/
/88 *#5/
IN 88-XX
December XX, 1988 NRC previously conveyed concerns in Information Notice 88-35 that licensee
audits of vendors may not be effectively evaluating the vendor's QA program
and its implementation, specifically in the area of procurement. The examples
discussed in this notice indicate that licensee audits are not assuring that
vendors apply adequate quality requirements for all parts within an ASME
component that have a safety function.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operation Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Robert L. Pettis, Jr., NRR
(301) 492-3214 Attachment:
List of Recently Issued NRC Information Notice
- SEE PREVIOUS CONCURRENCE PAGE.
t
OFC
- VIB:DRIS:NRR
- VIB:DRIS:NRR :VIB:DRIS:NRR :TECH EDITOR
- C:VID:DRIS:NRR:D:DRIS:NRR
___
________________
_________-------
_-----
____--
______-_____-----
- -_
_
-____________
NAME :RLPettis:jeh*
- ETBaker*
- UPotapovs*
- RSanders*
- E4Bth
- BKGrimes
DATE :10/07/88:mgc
- 10/16/88
- 10/18/88
- 10/18/88
- 11/tSf88
- 11/
/88 OFC
- D:DOEA:NRR
NAME
- CERossi
DATE :11/
/88
IN 88-35 October
, 1988 No spe
- c action or written response is required by this IN. If yo 1have
any quest
s about this matter, please contact the technical contac
sted
below or the
ional Administrator of the appropriate regional of ce.
Charles E. Rossi, Direc r
Division of Operation
ents Assessment
Office of Nuclear Re tor Regulation
Technical Contact:
Robert L. P tis, Jr., NRR
(301) 492-321 Attachment:
List of Recently Issued NRC Informat
Noti
- SEE PREVIOUS CONCU
E PAGE.
OFC
- VIB:DRIS:NR!XM
I
V :DJ NRR :VIB:DRIS:NRR :TECHD
- E:-B:DRIS
R:D:DRIS:NRR
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- ----
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T&
___
____
NAME
RLPtt eh* : Baer
- UPotaovs
JnAw
- EWBra
- BKGrimes
DATE :10/07/88:mg
- 10/ /88
- 10//88
- 10/iS/88
- 10
/88
- 10/ /88 OFC
D: DOEA: N H
NAME :CERoss
:----
- --------------:--------------
-____
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DATE :101
/
88:::::
IN 88-35 October
, 1988 No specific action or written response is required by this IN. If you have
any questions about this matter, please contact the technical contact listed
below or the Regional Administrator of the appropriate regional office.
Charles E. Rossi, Director
Division of Operation Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Robert L. Pettis, Jr., NRR
(301) 492-3214 Attachment:
List of Recently Issued NRC Information Notice
OFC
- VIB:DRIS:NRR
- VIB:DRIS:NRR :VIB:DRIS:NRR :TECH EDITOR
- C:VIB:DRIS:NRR:D:DRIS:NRR
NAME
.
RLPett
jeh
':ETBaker
- UPotapovs
- EWBrach
- BKGrimes
_____
---
- --------
- -
_-:-___________-____________
-__________
DATE :10/ 7/88:mgc/
- 10/
/88
- 10/ /88
- 10/
/88
- 10/ /88
- 10/ /88 OFC
- D:DOEA:NRR'
NAME :CERossi
DATE :10/ /88