United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 88-95: Inadequate Procurement Requirements Imposed by Licensees on Vendors

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                      OFFICE OF NUCLEAR REACTOR REGULATION
                             WASHINGTON, D.C.  20555

                                December 8, 1988


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 mechani-cal snubber to be exempt from QA requirements because of the 
NF-2121 exemption.  These parts include the ball nut, ball bushing, thrust 




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                                                            December 8, 1988 
                                                            Page 2 of 3 


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 
manufacturing, 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. 
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                                                            December 8, 1988 
                                                            Page 3 of 3 


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, 
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 Notices
.                                                            Attachment 
                                                            IN 88-95 
                                                            December 8, 1988 
                                                            Page 1 of 1

                             LIST OF RECENTLY ISSUED
                             NRC INFORMATION NOTICES
_____________________________________________________________________________
Information                                  Date of 
Notice No._____Subject_______________________Issuance_______Issued to________

88-94          Potentially Undersized        12/2/88        All holders of OLs
               Valve Actuators                              or CPs for nuclear
                                                            power reactors. 

88-93          Teletherapy Events            12/2/88        All NRC medical 
                                                            licensees. 

88-92          Potential for Spent Fuel      11/22/88       All holders of OLs
               Pool Draindown                               or CPs for nuclear
                                                            power reactors. 

88-91          Improper Administration       11/22/88       All holders of OLs
               and Control of                               or CPs for nuclear
               Psychological Tests                          power reactors and
                                                            all fuel cycle 
                                                            facility licensees 
                                                            who possess, use, 
                                                            import, export, or 
                                                            transport formula 
                                                            quantities of 
                                                            strategic special 
                                                            nuclear material. 

88-90          Unauthorized Removal of       11/22/88       All NRC licensees 
               Industrial Nuclear Gauges                    authorized to 
                                                            possess, use, 
                                                            manufacture, or 
                                                            distribute 
                                                            industrial nuclear 
                                                            gauges. 

88-89          Degradation of Kapton         11/21/88       All holders of OLs 
               Electrical Insulation                        or CPs for nuclear
                                                            power reactors. 

88-88          Degradation of Westinghouse   11/16/88       All holders of OLs
               ARD Relays                                   or CPs for nuclear
                                                            power reactors. 

88-87          Pump Wear and Foreign         11/16/88       All holders of OLs
               Objects in Plant Piping                      or CPs for nuclear
               Systems                                      power reactors. 

86-106,        Feedwater Line Break          11/10/88       All holders of OLs
Supp. 3                                                     or CPs for nuclear
                                                            power reactors. 
_____________________________________________________________________________
OL = Operating License
CP = Construction Permit 
Page Last Reviewed/Updated Tuesday, November 12, 2013