Historical Perspectives on Nuclear Procurement in North America
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1 Historical Perspectives on Nuclear Procurement in North America Marc H. Tannenbaum Technical Leader IAEA Meeting on Procurement Activities and CFSIs September 8, 2014
2 Topical Historical Perspectives Some recently completed procurement-related activities at EPRI Updated CFI guidance Some current procurement-related activities at EPRI 2
3 Genesis of Procurement Engineering Mid 1980 s in the U.S. Many commercial plants were transitioning from construction to supporting operations and maintenance Challenges Industry had little experience procuring replacement items (such as spare parts and consumables) Construction specifications were not effective Need to purchase identical replacements Individual purchase orders to original suppliers New approach to quality and technical requirements Counterfeit and Fraudulent Item concerns emerged Lower financial value resulted in less support from suppliers Regulatory concern and requirements 3
4 Number of Units Supplier Support Number of operational units Number of units planned but not operational Over 60 planned units were cancelled in the mid-1980 s The number of operational units peaked in at 113 Units 4
5 No. of Nuclear Suppliers Impact on Nuclear Suppliers in the U.S Orders for higher cost plant components diminished, causing many suppliers to refocus business away from nuclear Orders increased for lower cost spare and replacement items to support operations and maintenance 5
6 No. of Nuclear Suppliers Impact on supplier application of QA programs meeting 10CFR50, Appendix B requirements provided commercial grade by suppliers without a nuclear QA program Licensees must accept commercial grade items for use provided as safety-related basic components by suppliers with a nuclear QA program Suppliers certify items are acceptable for use An increased number of spare/replacement items furnished as commercial grade items (instead of basic components) Responsibility for accepting items used in nuclear safetyrelated applications shifted from suppliers to each licensee 6
7 1980s USNRC inspections focus more on procurement issues Two US units shut-down for procurement-related issues EPRI Nuclear Construction Issues Group (NCIG) formed Concerns increase regarding lack of engineering EPRI begins work on industry involvement, inadequate guidelines equivalency evaluations, and poor acceptance of CGI s Chernobyl accident (4/86) EPRI NP-5652, 6/88 (Commercial Grade Dedication NRC Generic Letter (3/89) EPRI NP-6406, 12/89 (TERI) NUPIC formed EPRI begins Nuclear Utility Procurement training 7
8 The 1990s Generic Letter (4/91) Pause in NRC inspections Resumption of NRC inspections of licensee procurement programs USNRC IP (4/96) 10CFR21, Rev. 2 (9/95) 10CFR21, Rev. 3 (96) EPRI NP-6629, 5/90 (Procurement & Receipt) EPRI NP-6630, 6/90 (Performance Based Audits) NUMARC Comprehensive Procurement Initiative EPRI NP-6895, 2/91 (Safety Classification) EPRI TR , 3/93 (Use of Other Industry Standards) EPRI Joint Utility Task Group EPRI NP-7218, 6/92 (Sampling for CG Dedication) EPRI TR , 8/93 (Inter-utility Transfer) EPRI TR , 3/94 (Supplement to NP-5652) EPRI TR , 2/96 (Benchmarking) EPRI TR , 1/97 (Packaging, Storage, S&H) EPRI TR R1, 2/97 (Benchmarking) EPRI TR R1, 10/98 (Engineering Change) EPRI TR , 7/98 (Reverse Engineering) EPRI TR R1, 1/99 (Sampling Rev. 1) 8
9 The EPRI TR , 7/00, (CCASSI) NRC IP Routine Inspections of Nuclear Vendors NRC IP Reactive Inspections of Nuclear Vendors NRC IP Inspection of Commercial-Grade Dedication Programs NRC IP NRC Oversight of Third-party Organizations Implementing Quality Assurance Requirements NRC IN (12/07) Supplier Quality Assurance NRC IN (4/08) Counterfeit and Fraudulent EPRI , 4/02, (ISO 9000 Assessment) EPRI , 12/03, (ISO 9000 Gap Analysis) EPRI , 4/02 (CGI from ISO 9000 Suppliers) EPRI , 12/03, (ISO Suppliers Procurement) EPRI , 6/06, (TERI, R1) EPRI , 11/07, (ECO R2) EPRI , 1/04, (Other Industry use-iso 9000) EPRI , 12/07, (Critical Parts) EPRI , 12/07, (Proactive Obsolescence Management) EPRI , 07/08, (Guidance for Managing Procured Item Quality) 9
10 The EPRI , 11/08 (Obsolescence Program Ownership and Development) EPRI , 10/09 (Counterfeit, Fraudulent and Substandard items) NRC IN (2/11) Commercial Grade Dedication Issues Identified during NRC Inspections NRC IP Revision (11/13) Clarification of 10CFR21 including Commercial Grade Dedication NRC White Paper (11/11) An Agency-wide Approach to Counterfeit, Fraudulent and Suspect NEA/CNRA R(2011)9 10/11 OE Report: Counterfeit, Suspect and Fraudulent WANO/INPO PO&C Revision (12/12) Performance and Operating Criteria with Part Quality and Readiness Objectives EPRI /09 (Warehouse & Inventory CBT) EPRI , 12/09 (Obsolescence Program Implementation and Lessons Learned) EPRI /09 (Critical Spare Parts Program) EPRI /10 (Counterfeit and Fraudulent) items self-assessment) EPRI , 10/10 (Counterfeit & Fraud CBT) EPRI , 11/10 (QC Inspection CBT) EPRI , 12/11 (Shelf Life Revision) EPRI , 12/11 (Critical Pump Refurbishment) EPRI , 06/12 (Design & Analysis Software dedication) 10
11 Current NRC IN (2/13) Counterfeit, Fraudulent and Suspect Item Training Offerings NEA/CNRA/R(2012)7 (2/13) Regulatory Oversight of Non-Conforming, Counterfeit, Fraudulent and Suspect NRC IN (03/13) Issues Potentially Affecting Nuclear Facility Fire Safety NRC IP Revision (11/13) Inspection of Commercial Grade Dedication Programs EPRI , 7/13 (Critical Motor Refurbishment and Procurement Checklist) EPRI /13 (Acceptance of Design and Analysis Computer Programs, Rev. 1) EPRI , 7/14 (Counterfeit and Fraudulent R1) EPRI , 09/14 (Commercial Grade Item Dedication Update) 11
12 Technical Procurement Focus areas Commercial Grade Dedication Critical Spares and Obsolescence Quality of Procured Transition from Construction to Spare and Replacement Counterfeit and Fraudulent Technical Evaluation Inventory Management and Readiness 12
13 Commercial Grade Dedication Updated Commercial Grade Dedication, Design and Analysis Computer Program, Auditing Supplier Commercial Grade Dedication Programs, Critical Characteristics for Seismically Sensitive, TR Commercial Grade Dedication Guideline for Sampling in Commercial Grade Dedication, TR R1 Critical Spares and Obsolescence Counterfeit and Fraudulent Supplemental Dedication Guidance, TR Quality of Procured Transition from Construction to Spare and Replacement Technical Evaluation Basic Commercial Grade Dedication Process, NP-5652 Inventory Management and Readiness Digital Devices, , , , TR , TR
14 Counterfeit and Fraudulent CFI, Mitigating the Increasing Risk (Rev. 1, of ), Self-Assessment Checklist, CFSI, Mitigating the Increasing Risk, Critical Spares and Obsolescence Commercial Grade Dedication Counterfeit and Fraudulent Identifying Substandard and Counterfeit, NP Appendix C Transition from Construction to Spare and Replacement Quality of Procured Technical Evaluation Inventory Management and Readiness 14
15 Technical Evaluation Technical Evaluation of Replacement Rev. 1 to NP-6406, Reverse Engineering, TR Commercial Grade Dedication Procurement and Receipt of, NP-6629 Critical Spares and Obsolescence Counterfeit and Fraudulent Transition from Construction to Spare and Replacement Quality of Procured Technical Evaluation Inventory Management and Readiness 15
16 Inventory Management & Readiness Establishing, Maintaining, and Extending Shelf Life, Inventory Optimization, TR Packaging, Shipping, Storage & Handling, TR Commercial Grade Dedication In-Storage Maintenance, NP-6896 Critical Spares and Obsolescence Transition from Construction to Spare and Replacement Counterfeit and Fraudulent Shelf Life of Elastomeric Components, NP Quality of Procured Technical Evaluation Inventory Management and Readiness 16
17 Quality of Procured Critical Motor Refurbishment and Procurement Checklist, Critical Pump Refurbishment and Procurement Checklist, Managing Procured Item Quality, Commercial Grade Dedication Performance-Based Supplier Audits, NP-6630 Critical Spares and Obsolescence Transition from Construction to Spare and Replacement Counterfeit and Fraudulent Procurement and Receipt of, NP-6629 Appendix C, Identifying Quality of Procured Technical Evaluation Inventory Management and Readiness 17
18 Critical Spares and Obsolescence Critical Spare Parts Program Development, Proactive Obsolescence Management Program Implementation, Commercial Grade Dedication Obsolescence Management, Critical Spares and Obsolescence Counterfeit and Fraudulent NP-6629 Appendix C, Identifying Transition from Construction to Spare and Replacement Quality of Procured Technical Evaluation Inventory Management and Readiness 18
19 Recent Research Acceptance of Design and Analysis Computer Programs Updated Counterfeit and Fraudulent Item Mitigation
20 Updated Counterfeit and Fraudulent Item Mitigation EPRI (7/14) PREVENT Establish scope of concern (6.1) DETECT Use of authorized distributors (6.2) Enhanced supplier communication and interface (6.3) Identify at-risk procurements (6.4) Documented Process for Suspect (8.1, 8.2) Education and Training (6.5) Reporting & Sharing Incident Information (8.2.5, 8.3, 9.1) Quarantine (8.2.2) Corrective Action (8.2.4) Disposition (8.2.4) Report/Share (OE) (8.2.6, 9) CONTROL 20 Vigilant inspection (7.1) Source (7.1.1) Receipt (7.1.2) Pre-installation (7.1.3) Positive Identification (7.2) 2013 Electric Power Research Institute Inc. (EPRI) All Rights Reserved.
21 Current Research Digital Equivalency Evaluation Updated Commercial Grade Dedication Guidance Relay Procurement and Acceptance Checklist (Draft) 21
22 Questions? 22
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