Procurement Engineering Standard Purchase Clause

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1 1.0 QUALIFICATION BY TESTING AND ANALYSIS This EQPR is intended to be used when buying limit switches and parts manufactured by Namco Controls (hereinafter Namco) for use in throughout Ontario Power Generation (hereinafter OPG) nuclear sites in safetyrelated applications which require environmental qualification (EQ). OPG Engineer (see the Contract Standard for definition of Engineer ) generally assesses and qualifies electrical equipment for use in applications which require Environmental Qualification (EQ) by conducting qualification tests (or referring to qualification tests performed by others) whereas mechanical items are generally qualified by analysis. Once it has been established that an item is environmental qualified (EQ), it is necessary to ensure that successive purchases of the item shall be equivalent to the qualified item. In order to do so, it is necessary to clearly establish the critical characteristics of the qualified item so that these can be replicated and verified. These critical characteristics may be shown on one or more of a number of different documents including the manufacturer s catalogue, manufacturer s drawing(s), test reports, qualification reports, bill(s) of material, specification(s) etc. So as not to limit the generality of the foregoing list, the document that describes the critical characteristics that need to be replicated shall be referred to herein as the primary controlled document. Namco item shown in the OPG purchase order (P.O.) item description has been assessed and EQ by the OPG Engineer (see the Contract Standard for definition of Engineer ) for use in nuclear safety-related applications at OPG based on the following primary controlled documents: Namco Report QTR-155, R02, dated October Generic Qualification of EA180-Series Limit Switches for use in Nuclear Power Plant Class 1E Applications in Compliance with IEEE Standards , and Namco Report QTR-180, R01, dated December Qualification of EA740 Series Limit Switches for Use in Nuclear Power Plants in Compliance with IEEE Standards , , and Namco Report QTR-140, R01 dated January Generic Qualification of EA740 Series Limit Switches for Use in Nuclear Power Plant Class 1E Applications in Compliance with IEEE Standards , and Namco Report QTR-520, R00, dated October 2002 Qualification of EA740-Series Limit Switches with EC 290-Series Receptacle and Connector/Cable assemblies for Use in Nuclear Power Plant Class 1E Applications in Compliance with IEEE Standards. 125 Test conducted at John Carroll University Seismological Laboratory, Cleveland Ohio, by Dr. Edward J. Walter; June Namco Controls, Seismic Qualification test for Class 1E Equipment to be used in Nuclear-Power Electrical Generating Plants. 2.0 CHANGES IN DESIGN AND SUBSTITUTION OF QUALIFIED MATERIALS EA180 and EA740 Limit Switches Only Changes made to the items that were originally tested and previously assessed and environmentally qualified by OPG are to be tracked. Namco is responsible for advising OPG if there are any changes in form, fit, function, materials, manufacturing processes or testing procedures since the item was purchased, assessed and qualified by OPG, starting with references to documents given in the item description. Some changes, which may appear insignificant and not deem to be reported to the client (since fit, form, and function are met), can invalidate the equipment nuclear performances. Changes to non-metallic components are of particular interest to OPG. This clause applies to purchase orders placed on or after March 20, 2018 Page 1 of 6

2 If any of these changes take place then Namco shall notify OPG Buyer using the Vendor Parts/ Material Substitution Control form N-Form during bidding or the Concession Application form N-Form subsequent to contract award. As an alternative to the preceding paragraph, Namco shall notify OPG Buyer, using the same forms, if for any reason it is unable to provide assurance that there have been no such changes since the item was originally evaluated/ tested for use in a nuclear safety application. OPG Buyer will forward all such notifications to the Design Authority in OPG. The responsible Design Authority shall make all decisions relating to the need to re-evaluate and/or re-test and the item. Although the Design Authority may solicit Namco s input to the decision, the decision of the Design Authority will be final. NAMCO is advised that: This item will be installed in a nuclear safety-related system. That system will be required to operate following a very unlikely but theoretically possible design basis accident. If such an accident occurred the limit switches could be subjected to a harsh environment consisting of radiation, steam, elevated temperature and pressure. It is possible that the design basis accident could occur at a time when the limit switches have already been subjected to many years of normal operation when they are nearing the end of their useful operating life. These limit switches have been rigorously evaluated /tested, and we expect that they will perform their intended safety function following exposure to this harsh environment. OPG Environmental Qualification Assessment (EQA) has established that the item may not perform its intended safety function if there is a substitution of materials, changes in design or changes in manufacturing methods. This is especially true for changes or substitutions of non-metallic components used in the construction of this item. Some non metallic components are known to be subject to degradation in a harsh environment and can deteriorate quickly when exposed to steam, heat, or especially when exposed to high levels of radiation. OPG Engineer accepts that changes in design, sub-suppliers, materials, and manufacturing methods may be necessary as technology and manufacturing processes change with time. It is OPG Engineer s objective to minimize unnecessary changes that would necessitate a reevaluation of the limit switch s ability to perform their intended safety function following a Design Basis Accident as even minor changes may dictate the need to retest or re-qualify the limit switches. In any event, it will certainly dictate the need to evaluate the effect of the change to ensure that the new limit switches will perform the same intended safety function as the limit switches that were previously qualified. 3.0 QUALITY ASSURANCE PROGRAM REQUIREMENTS For the EQ items that Namco manufactures, and supplies to OPG, Namco shall implement and maintain a QA program that provides assurance that Namco tracks material substitutions, design changes, sub-supplier changes, manufacturing and non-destructive testing process changes that may occur during the course of time and that the items meet the design requirements and are equivalent to those originally evaluated and EQ by OPG. In order to provide this assurance Namco QA manual/program shall meet the requirements of CSA CAN3-Z , or CSA N QA Standards, including the requirement for product traceability. Traceability is required by this contract, and therefore in accordance with CSA CAN3-Z299.1/2/3-85 or CSA N299.1/2/3-16 QA standards, Namco shall assign to each product or service or batch a unique identification/unique identifier such as serial number, date code, batch code to distinguish apparently identical products. Namco QA program as audited/accepted by OPG, along with the requirements specified in the P.O., is acceptable to OPG to meet this requirement. Non-conformances with a disposition to Repair or Use-as-is require the concurrence of all responsible parties, and submission to OPG for acceptance. This clause applies to purchase orders placed on or after March 20, 2018 Page 2 of 6

3 All orders should be placed to Namco Controls Corporation Sales Offices in Lancaster SC. Namco Sales Offices is accountable for transmitting all technical and quality requirements, complete and unchanged to manufacturing location. All items shall be traceable to Namco audited manufacturing facility in Elizabethtown, NC, USA Note: Lever arms are to be supplied as commercial items produced under Namco s commercial QA program. 4.0 INSPECTION AND TEST PLAN AND SPECIAL PROCESS PROCEDURE APPROVALS There is no requirement to submit inspection and test plans or special process procedures for approval on this contract. However, OPG reserves the right to review these during QA program audit or contract specific inspections in order to satisfy itself that manufacturing and inspection activities are appropriately planned, authorized and controlled. Namco s certification statement that the items are equivalent to those originally qualified is deemed to satisfy the Engineer s requirement for reviewing and acceptance of critical process procedures and inspection and testing procedures. Namco is advised that: CANDU nuclear power plants are built and operated in accordance with CSA standards. These standards require that OPG ensure that Namco QA program complies with CSA CAN3-Z or CSA N QA Standards. In turn, this standard establishes the default requirement that manufacturers will submit inspection and test plans and special process procedures for approval by the customer before performing the work. This CSA standard also provides that where the item is manufactured for, and shipped from inventory, the manufacturer would not be expected to comply with the default requirement. However, under these circumstances the customer and supplier are to reach agreement on how the supplier will demonstrate that the items were manufactured in accordance with inspection and test plans and special process procedures that have been reviewed and approved before contract award. The CSA standard allows for the use of alternative standards provided that the gaps between standards have been assessed and bridged. In the past, CANDU customers have generally requested that Namco submit copies of inspection and test plans and special process procedures for approval prior to accepting delivery as a means of ensuring that appropriately approved inspection and test plans and special process procedures had been used during manufacture. Although such submissions effectively bridge the gap between CSA CAN3-Z or CSA N QA Standards and 10CFR50 Appendix B with respect to customer approval of these documents, these submissions do not enhance quality of the delivered product because: The item has already been manufactured and will be delivered from Namco s inventory. The item has not yet been manufactured but it is a standard Namco component manufactured in accordance with standard Namco plans and procedures, which cannot in any practical sense be changed for any one customer. As a further consideration, it has been noted that the process of submitting inspection and test plans and special process procedures for customer approval before accepting delivery has the effect increasing costs while delaying delivery several weeks. By waiving the requirement to submit inspection and test plans and special process procedures while retaining the right to review these during audits and inspections, OPG expects to avoid incurring costs and delays associated with the process, while retaining the ability to satisfy ourselves that items and spare parts have been produced in accordance with appropriate plans and procedures. 5.0 PRESSURE RETAINING ITEMS REGISTRATION WITH AUTHORIZED INSPECTION AGENCY This section is N/A This clause applies to purchase orders placed on or after March 20, 2018 Page 3 of 6

4 6.0 CSA / ESA CERTIFICATION When required by the OPG technical/engineering specification referenced in OPG P.O. item description, Namco is responsible for supplying equipment as outlined in sub-rule 4, rule of the Electrical Safety Code issued as regulation or 164/99 under the Electricity Act, 1998, that has been approved, to Canadian standards, by certification organizations as recognized by the Electrical Safety Code. The equipment shall bear the approval label or the organization s certification mark as published by the ESA. For the most updated list of recognized certification and field evaluation marks and certification or field evaluation agency info, visit the electrical product safety section of The item shall bear the certifying agency s approval symbol / sticker, which identifies the item as certified for use in Canada. 7.0 SEISMIC QUALIFICATION REQUIREMENTS Namco is to demonstrate the seismic qualification for the item(s) are in accordance with the OPG design/technical specification referenced in the OPG P.O. item description. Demonstration of the seismic qualification is permitted by physical testing and/or analysis. For repeated orders Namco s Certificate of Conformance statement that the item supplied is equivalent to that originally supplied by Namco (see Section Certification to Accompany Shipment ), is deemed to satisfy the Engineer s requirement for seismic qualification of the item. 8.0 MARKING AND TAGGING OF THE ITEM Wherever possible, each item shall have a corrosion resistant metal tag/nameplate permanently attached with mechanical fasteners (screws, rivets, etc.). Self-adhesive labels and glue are prohibited. The nameplate shall be attached in such a manner that the function of the item is not affected. The nameplate shall contain the following data as a minimum. Namco s name and catalogue number Namco s serial number Voltage Rating If possible, Namco should provide the following data on either the metal tag described above or on an additional tag attached to the item by a stainless steel wire in such a manner that the function of the item is not affected: OPG Catalog ID number CSA symbol or Electrical Safety Authority approval sticker. As an alternative to attaching a nameplate, Namco may permanently mark, etch or scribe the data directly on the item, where size permits. NAMCO presently uses a code stamped in the conduit end of each switch with the following code format "AAAA BB CCCCCC" where: The first four characters (AAAA) represent the date code system; the format is 'week and year'. The center characters (BB) represents the bill of materials revision level, which is a criterion for determining the constituent materials of the limit switch. The last five or six characters (CCCCCC) represent the factory order number. If the switch does not have a code stamped in the conduit end of the housing, the switch cannot be qualified. The above method of marking the item is acceptable to OPG. All markings/tagging shall be clear, unambiguous, and indelible. This clause applies to purchase orders placed on or after March 20, 2018 Page 4 of 6

5 Spare parts do not need to be tagged but shall be shipped in suitable packaging and labeled as outlined in section 9 below. 9.0 PROTECTION FROM DEGRADATION DURING SHIPMENT OR STORAGE All openings of the item shall be suitably plugged or capped to prevent ingress of foreign materials, dust, dirt, etc. Each individual item shall be suitably packaged to prevent damage during shipment. Packaging, complete with desiccant as appropriate, shall also be suitable for safe long term storage, in accordance with ASME NQA Subpart 2.2 Level B or the predecessor industry standard ANSI-N Level B. Individual packaging shall provide protection from ultraviolet (UV) radiation. Heat sealed packaging is preferred. Where the packaging is intended to protect the item from degradation during storage, individual cartons or the packaging should be clearly marked with the following, as a minimum: Namco s name and catalogue number Namco s Serial number Date of manufacture If possible, mark on the package of items and/or spares with following: OPG s P.O. number and P.O. line item number OPG s Catalogue ID number. Date on which the shelf life will expire. Recommended storage conditions and handling instructions A notation that says: Do not remove from package prior to installation/use. A notation that says: This package contains EQ items. The packaging provides shelf life information. Do not discard the packaging until installation in the intended application is complete. If this item is to be returned to stock it must be returned in its original packaging. Namco should include a shelf life statement with every purchase order indicating the shelf life expiry date of each item (Catalog ID Number) on the purchase order. Shelf life for every item should be assigned by Namco under their quality assurance program and in accordance with industry (e.g., EPRI, Mil Spec, etc.) recommended shelf life values for similar components. Shelf life can be determined by using EPRI methodology: EPRI Report NP6408, Guidelines for Establishing, Maintaining and Extending the Shelf Life Capability of Limited Life Items (NCIG-13): Typical Data from EPRI Report: NP6408, App. B, List of Generic Shelf Lives (Partial List) Material Shelf life in years Cross-linked Polyolefin 31 EPDM/EPR 60 Nitrile 14 Nylon 25 Viton 49 Tefzel 60 OPG Receiving Inspector should not accept the item for delivery if the remaining shelf life at the time of delivery is less than 70% of the recommended shelf life without prior written consent CERTIFICATION TO ACCOMPANY SHIPMENT Namco shall supply a certificate, which shall accompany the shipment of the item or spare part. This certificate shall be signed by Namco QA authority and shall certify that: This clause applies to purchase orders placed on or after March 20, 2018 Page 5 of 6

6 The item has been manufactured and supplied in accordance with Namco QA manual (structured to meet the requirements of 10CFR50 Appendix B) as audited/accepted by OPG (refer to Section 3.0). and the supplemental requirements of the OPG P.O. The item supplied and referenced in the Catalog ID description both meets the design requirements and is equivalent to the item originally manufactured by Namco and described in the primary controlled document referenced in OPG P.O. (specifically referencing the document by number, revision, and/or date) (see Sect. 1). Note: If there is a change or substitution of material, design, compounds used in construction, manufacturing method(s) or nondestructive method is proposed or identified, that change shall be reviewed/accepted by the OPG Engineer in writing prior to shipment. Evidence of that acceptance shall accompany the certification statement and the wording of the statement shall be suitably modified to reflect the change and the acceptance. The certificate shall also clearly indicate the following: The manufacturer s name, model and part numbers, as applicable. The serial number(s) OPG s Purchase order number OPG s Catalog ID number. For Namco s lever arms, Namco is to provide a certificate statement indicating the following: Manufacturer s Name (Namco and/or Snap Lock) and Model Numbers. OPG s purchase order. OPG s Catalog ID number. The name and title of QA authority shall appear below the signature, and notification date shall be evident. This clause applies to purchase orders placed on or after March 20, 2018 Page 6 of 6

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