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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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
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