control of suspect/counterfeit items
TRANSCRIPT
24590-RAPR-F00001 Rev 15 (Revised 7/23/2019) Page 1 of 27 Ref: 24590-WTP-GPP-RAPR-PR-1001
Hanford Tank Waste Treatment and Immobilization Plant
Document Owner
BNI-WTP Applicability Project Phase Organization Use Level of Use
Project Wide All Cross-Functional Information
Care, Custody, and Control N/A
Procedure
24590-WTP-GPP-RAQA-QA-0003 Revision 5
Control of Suspect/Counterfeit Items
Effective Date: 06/25/2020
Requirement Area: Quality Assurance
Position Print Name Signature Date
RA SME Dan Hart
RAM Rajwant Jolly
BNI-WTP Quality Mike Fortier
06/24/2020
24-JUN-2020
06/24/2020
Issued byRPP-WTP PDC
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Contents
1.0 PURPOSE ............................................................................................................ 5
2.0 SCOPE ................................................................................................................. 5
3.0 ROLES AND RESPONSIBILITIES ...................................................................... 5 3.1 BNI-WTP MANAGER OF QUALITY .......................................................... 5 3.2 BNI-WTP AND WTCC ORGANIZATION MANAGERS .............................. 5 3.3 MANAGER OF ENGINEERING AND DESIGN AUTHORITY .................... 5 3.4 ASSET MANAGEMENT ............................................................................ 5 3.5 MANAGER OF PROCUREMENT AND SUBCONTRACTS ....................... 6 3.6 SUBCONTRACT/PROCUREMENT INTERFACE ..................................... 6 3.7 CONTRUCTION MANAGER ..................................................................... 6 3.8 WTCC QUALITY MANAGER ..................................................................... 6 3.9 BNI-WTP/WTCC EVALUATION TEAM ..................................................... 6 3.10 SUSPECT/COUNTERFEIT ITEMS COORDINATOR ................................ 6 3.11 SUPPLIER QUALITY ................................................................................. 7 3.12 S/CI IDENTIFIER (BNI-WTP/WTCC EMPLOYEE/ONSITE
SUBCONTRACTOR/SUPPLIER) .............................................................. 7
4.0 PRECAUTIONS AND LIMITATIONS ................................................................... 7
5.0 PREREQUISITES ................................................................................................ 7
6.0 PROCEDURE ....................................................................................................... 8 6.1 GENERAL .................................................................................................. 8 6.2 IDENTIFICATION OF QUESTIONABLE ITEMS BY WTP EMPLOYEE .. 12 6.3 IDENTIFICATION OF QUESTIONABLE ITEMS BY
SUBCONTRACTOR/SUPPLIER ............................................................. 16 6.4 S/CI RETENTION PROCESS .................................................................. 19 6.5 EXTERNAL S/CI NOTIFICATIONS AND REVIEW PROCESS ............... 19 6.6 EXTERNAL DI NOTIFICATIONS AND REVIEW PROCESS ................... 19
7.0 ACCEPTANCE CRITERIA ................................................................................. 20
8.0 TRAINING .......................................................................................................... 20
9.0 RECORDS.......................................................................................................... 20
10.0 REFERENCES ................................................................................................... 20 10.1 INTERFACING REFERENCES ............................................................... 20 10.2 DEVELOPMENTAL REFERENCES ........................................................ 21 10.3 FORM REFERENCES ............................................................................. 21
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Attachments ATTACHMENT 1 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS ................ 22 ATTACHMENT 2 S/CI INDICATORS ........................................................................ 23 ATTACHMENT 3 WTP EMPLOYEE FLOWCHART ................................................. 26 ATTACHMENT 4 SUBCONTRACTOR/SUPPLIER FLOWCHART .......................... 27
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REVISION – SUMMARY Justification: Section/Step Revision Type* Description
Throughout Major This revision incorporates NCR program ownership updated to WTCC Quality Manager. Updated procedure references to 24590-WTP-GPP-RAQS-NC-0001, and 24590-WTP-GPP-RAQS-NC-0002. Updated to reflect current project links. Updated formatting.
1.0 Added a statement to describe process for external notifications of S/CI and defective items
3.7 Changed role from Manager of Construction to WTCC Quality Manager
6.1.1 Changed CAMP to Contractor Assurance.
6.1.5 Moved Trend Analysis to S/CI Coordinator.
6.2.5, 6.3.7 Describe dispositioning S/CI
6.5 New section to describe process for responding to external S/CI notifications
6.6 New section to describe process for responding to external DI notifications
Attachment 3, Attachment 4
Updated to reflect dispositioning of S/CI
Attachment 5 Removed requirement references
* Major, Minor, or Expedited
REQUIRED REVIEWERS
☒ Asset Management (WTP CPMS Doc Review)
☒ BNI- WTP Quality (WTP Quality Document Review Mailbox)
☒ Document Administration – Procedures (WTP PI Document Review)
☒ Safety & Health (WTCC Safety and Health)
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1.0 PURPOSE
This procedure describes the requirements and administrative controls for identifying, documenting, analyzing, dispositioning, reporting, controlling, and disposing of suspect/counterfeit items (S/CIs). This procedure also establishes the requirements for notifying the Office of Inspector General (OIG) of S/CIs. The objective is to prevent the inadvertent requisition, procurement, acceptance, and installation of S/CIs. This procedure also describes the process for screening, distributing, and reviewing external notifications of S/CIs and defective items (DIs) for project impact.
2.0 SCOPE
This procedure applies to safety and non-safety systems, structures, and components; critical load path of hoisting and rigging equipment; industrial safety items; and any items (including non-permanent) within the WTP where the introduction of the S/CIs would have the potential for creating unsafe conditions.
3.0 ROLES AND RESPONSIBILITIES
3.1 BNI-WTP MANAGER OF QUALITY
Has overall responsibility for implementation of S/CI Program
3.2 BNI-WTP AND WTCC ORGANIZATION MANAGERS
Ensures work processes for which they are responsible have adequate controls to prevent introduction and use of S/CIs
Ensures subcontractors and suppliers are advised of unacceptability of S/CIs
Ensures work processes for purchased items provide for examination of S/CI indicators
3.3 MANAGER OF ENGINEERING AND DESIGN AUTHORITY
Ensures participation in the inspection and testing of items that exhibit S/CI indicators as well as confirmed S/CIs, both pre- and post-installed
Specifies testing for procured or installed S/CIs, as necessary, using approved Engineering test methods
Ensures NCRs have suitable instructions for disposition of S/CIs
3.4 ASSET MANAGEMENT
Dispositions S/CIs as appropriate
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3.5 MANAGER OF PROCUREMENT AND SUBCONTRACTS
Ensures procurement process controls contain provisions specific to prohibited procurement of S/CIs
Ensures S/CI requirements are flowed down to subcontractors/suppliers as well as sub-tier suppliers as indicated in contractual agreements
Ensure work processes are implemented for acceptance of only those items that comply with procurement specifications, consensus standards, and commonly accepted industry practices as well as being free from S/CI indications
Disseminates applicable information to affected subcontractors and suppliers to the extent authorized
Ensures work processes are implemented for surveillances of material management storage areas and inspections of inventory to identify, control, and assist in dispositions of S/CIs
3.6 SUBCONTRACT/PROCUREMENT INTERFACE
Notifies S/CI Coordinator when a subcontractor/supplier identifies potential S/CI
Notifies subcontractor/supplier of S/CI determination
Initiates nonconformance report (NCR) if an S/CI is impounded
3.7 CONTRUCTION MANAGER
Provides controls for processes that could introduce S/CIs
3.8 WTCC QUALITY MANAGER
Provides controls for processes that could introduce S/CIs
Ensures NCR process provides adequate controls for identified S/CIs
WTCC POC for S/CI information
3.9 BNI-WTP/WTCC EVALUATION TEAM
Investigates potential S/CIs for validity
3.10 SUSPECT/COUNTERFEIT ITEMS COORDINATOR
Develops, maintains, and provides oversight of the S/CI Program
Leads evaluation team to investigate questionable items
Serves as the Point of Contact (POC) for OIG communications
Develops and maintains the S/CI log
Notifies project management of S/CIs and defective items (DIs) that may affect the WTP project
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Tracks questionable item notifications and results for trending and metrics reporting
Conducts program effectiveness reviews
Conducts NCR validation for S/CI specific NCRs
3.11 SUPPLIER QUALITY
Identifies items that exhibit S/CI indicators as questionable during the receiving process and documents on Unsatisfactory, Over, Short, and/or Damaged (UOS&D) Report
Notifies the S/CI Coordinator and initiate an NCR for items that exhibit S/CI indicators
3.12 S/CI IDENTIFIER (BNI-WTP/WTCC EMPLOYEE/ONSITE SUBCONTRACTOR/SUPPLIER)
Identifies questionable items that exhibit S/CI indicators
Secures questionable items to prevent their use
Contacts appropriate management and the S/CI Coordinator immediately upon discovery of a questionable item which exhibits S/CI indicators
Initiates an NCR when discovering an item that exhibits indications of being S/CI
4.0 PRECAUTIONS AND LIMITATIONS
N/A
5.0 PREREQUISITES
N/A
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6.0 PROCEDURE
NOTE:
The steps in this procedure are intended to be used as needed, depending on the procedure attribute of interest, and not in a prescribed sequence except as noted.
6.1 GENERAL
6.1.1 The managers who are responsible for the respective work processes PERFORM the following steps:
NOTE:
The following work process controls are the responsibility of the BNI-WTP Manager of Quality, WTCC Quality Manager, Construction Manager, Manager of Procurement and Subcontracts, Manager of Engineering and Design Authority, Manager of Field Quality Control, Safety & Health Manager, Plant Engineering and Maintenance Manager, and Deputy General Manager
a. ENSURE the following work processes have adequate controls to prevent the introduction and use of S/CIs as applicable:
Engineering
Design
Procurement
Testing
Inspection
Maintenance (including replacement and modification)
Evaluation
Disposition
Lessons Learned
b. ENSURE appropriate codes, standards, and quality requirements are included in the procurement and subcontract documents to ensure that suppliers are advised of the unacceptability of S/CIs.
c. ENSURE procurement documents for both material and services contain the following information:
Requirements that prohibit the delivery of S/CIs and prohibit subcontractors from introducing S/CIs to the WTP
Requirements that specify items be new and not reconditioned, used, or repaired unless otherwise specified in the procurement document.
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d. ENSURE purchased items are examined for questionable S/CI part indicators, in accordance with this procedure.
e. EVALUATE S/CI-related NCRs for potential trends as part of the preparation of Contractor Assurance quarterly trending. (24590-WTP-GPP-RACA-TM-0001, Trend Analysis and Reporting provides details)
f. ISSUE Lessons Learned reports, as appropriate, and REVIEW for use in improving the prevention and identification of S/CIs. (24590-WTP-GPP-RACA-LL-0001, WTP Lessons Learned provides details)
g. DO NOT DESTROY, ALTER, or DISPOSE of identified S/CIs or documentation without reporting to DOE and obtaining the authorization of the OIG.
6.1.2 The Manager of Procurement and Subcontracts PERFORMS the following steps:
a. ENSURE work processes are implemented such that technical and Quality Assurance (QA) requirements to prevent the introduction of S/CIs are identified in requisition packages and passed on to manufacturers, suppliers, and subcontractors.
NOTE:
Current information on S/CI detection and a list of S/CI and DI notifications can be found on the WTP project intranet home page under Safety and Quality.
b. ENSURE work processes are implemented, to the extent authorized for external distribution, such that project suppliers and subcontractors are made aware that project-applicable S/CI and DI notifications obtained from the following sources can be accessed via a password protected external website (http://www.hanfordvitplant.com/suspectcounterfeit-items), along with the appropriate guidance on the prevention of providing S/CIs to the WTP:
DOE Office of Health, Safety, and Security (HSS) S/CI and DI Website
Government-Industry Data Exchange Program (GIDEP)
Institute of Nuclear Power Operations (INPO)
Occurrence Reporting and Processing System (ORPS)
c. ENSURE procurement process controls include provisions for preventing the procurement of S/CIs in accordance with this procedure.
d. ENSURE proformas contain requirements to prevent introduction of S/CIs to WTP.
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e. ENSURE work processes are implemented such that acceptance is made of only those items that comply with procurement specifications, consensus standards, and commonly accepted industry practices.
f. ENSURE work processes are implemented such that inventory is inspected and surveillances of material management storage areas are performed in accordance with project procedures to identify, control, and disposition potential S/CIs.
6.1.3 The Construction Manager PERFORMS the following step:
a. ENSURE controls are provided for the following processes for S/CIs installed that create potential hazards:
Identification
Inspection
Documentation
Evaluation
Segregation when practical
Notification of relevant organizations
Disposition
6.1.4 The WTCC Quality Manager PERFORMS the following step:
a. ENSURE controls are provided for the following processes for S/CIs installed that create potential hazards:
Identification
Inspection
Documentation
Evaluation
Segregation when practical
Notification of relevant organizations
Disposition
b. ENSURE the NCR process provides controls that ensure S/CIs identified during routine maintenance and/or inspection are reported, evaluated, and dispositioned to prevent future use in safety applications.
c. ENSURE information regarding S/CIs is communicated with WTCC Management.
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6.1.5 The Manager of Engineering and Design Authority PERFORMS the following steps:
a. PARTICIPATE in the inspection and testing of identified potential S/CIs and confirmed S/CIs, both pre- and post-installation.
b. ENSURE the technical and Quality Assurance (QA) requirements are identified in requisition packages.
c. ENSURE NCRs on contaminated (e.g. radiological, chemical) S/CIs take into consideration the facility/program-specific waste management procedures when determining the disposition of the S/CI.
NOTE:
Current information on S/CI detection and a list of S/CI and DI notifications can be found on the WTP project intranet home page.
6.1.6 The S/CI Coordinator PERFORMS the following steps:
a. USE the online listing found on the WTP project intranet home page to collect, maintain, and disseminate S/CI and DI information pertinent to the WTP work scope.
b. MAINTAIN the S/CI and DI list up-to-date and accurate using available sources including:
DOE HSS S/CI and DI Website
Government-Industry Data Exchange Program (GIDEP)
Institute of Nuclear Power Operations (INPO)
Occurrence Reporting and Processing System (ORPS)
c. ENSURE S/CIs identified and associated documentation is retained in case it is needed for criminal investigation or litigation.
d. PERFORM trend analysis of reported S/CIs annually, in accordance with 24590-WTP-GPP-RACA-TM-0001, Performance Measures and Trending.
6.1.7 Manager of Engineering and Design Authority ENSURES support is provided for the following steps:
a. PERFORM an Engineering evaluation, using approved test methods (i.e., in accordance with applicable codes/standards), to determine procured or installed S/CIs do not pose a potential safety hazard and meet design requirements. Also consider the potential risks to the public and workers, cost/benefit impact, and schedule for replacement, if required.
b. PROVIDE a disposition to perform one of the following:
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To leave the S/CI installed and clearly identified to the workforce with appropriate design change documentation, as required
To remove and replace the S/CI
To provide for an alternate outcome
c. PARTICIPATE in replacing, maintaining, or modifying equipment
6.2 IDENTIFICATION OF QUESTIONABLE ITEMS BY WTP EMPLOYEE
NOTE:
It is the responsibility of all project employees to report questionable items that exhibit S/CI indicators to their manager/supervisor and the S/CI Coordinator. Typical S/CI indicators can be found on Attachment 2. Records from Kobe Steel Ltd, Kobe Steel USA, Kobelco, or other implicated affiliates, are considered an S/CI Indicator, based on their admittance of record falsification.
An additional listing of indicators of S/CIs can be found in DOE S/CI Guide 414.1-3 Appendix 4 which can be found on the S/CI homepage, which is located on the WTP Project home page under Safety and Quality.
The WTP Employee process flowchart can be found on Attachment 3. For better viewing, the zoom feature in the electronic version may be used.
6.2.1 Supplier Quality PERFORM the following steps:
a. IF during the receiving process an item exhibits S/CI indicator(s) (examples in Attachment 2), THEN IDENTIFY the item as questionable.
1. NOTIFY supervision and COMPLETE receiving or inspection process in accordance with 24590-WTP-GPP-RAPS-SQ-1044, Field Material Receiving, and/or 24590-WTP-GPP-RAPS-SQ-1041, Receiving Inspections, as appropriate.
2. NOTIFY the S/CI Coordinator.
b. WHEN receiving or inspection process is complete, THEN INITIATE an NCR in accordance with 24590-WTP-GPP- RAQS-NC-0002, Nonconformance Reporting and Control and GO TO Step 6.2.3.
6.2.2 The WTP employee PERFORMS the following steps:
a. IF some item exhibits S/CI indicators, (examples in Attachment 2), THEN PERFORM the following
1. IDENTIFY the item as questionable,
2. NOTIFY the S/CI Coordinator, and
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3. INITIATE an NCR in accordance with the governing procedure noted below:
a) For items controlled by Material Management, Construction, or Startup, work in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.
b) For items handed over to Plant Management, work in accordance with 24590-WTP-GPP-RAQS-NC-0001, Operating Nonconformance Reporting and Control.
6.2.3 The S/CI Coordinator PERFORMS the following steps:
a. VERIFY the item that exhibits indications of being a S/CI is secured from being used.
b. VALIDATE the NCR when appropriate.
c. INITIATE S/CI log entry and provide communication to WTCC POC.
d. INVESTIGATE item in question and gather information (e.g., photographs, procurement documents).
e. IF the investigation of the questionable item becomes complex in nature, THEN ASSEMBLE a team of appropriate personnel (i.e., Technical Specialists) to evaluate the item.
6.2.4 The BNI WTP/WTCC Evaluation Team PERFORMS the following steps:
a. EVALUATE questionable item regarding S/CI validity.
b. NOTIFY S/CI Coordinator with results.
6.2.5 The S/CI Coordinator, PERFORMS the following steps:
a. SERVE as the S/CI Point of Contact with the Office of Health, Safety, and Security,
b. DETERMINE whether the item is S/CI using input from the Evaluation Team.
c. DOCUMENT the determination on the NCR, or with a surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.
d. IF the item is determined to be a S/CI, THEN PERFORM the following:
1. NOTIFY the following within 3 days of the determination via email using a CCN:
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DOE
Office of Environmental, Safety, and Health
OIG
2. NOTIFY Occurrence Reporting.
3. UPDATE S/CI log with determination.
NOTE:
The OIG typically responds within 10 days. The response identifies the OIG’s intent regarding a course of action.
4. IF OIG response is not received within 10 working days, THEN CONTACT OIG and OBTAIN a timeframe in which their response will be provided.
5. UPDATE S/CI log with OIG response.
6. WHEN response is received from OIG, THEN NOTIFY affected management, utilizing the project organizational chart, of path forward regarding OIG disposition.
NOTE:
Items determined as S/CI are dispositioned in one or more of the following three methods. Quantities may be split between the various methods.
• Ship to OIG
• Make available to S/CI training for use as a training aid
• Disposal by Asset Management
Material Management processes shipments of government property in accordance with 24590-WTP-GPP-RAPS-MM-1103, Field Material Withdrawal and Shipping.
7. UPDATE the NCR disposition to reflect OIG response.
a) IF the OIG requests the items, THEN SELECT “Reject” disposition
1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the OIG.
b) IF items are requested to be retained for S/CI training, THEN SELECT “Reject” disposition
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1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the S/CI coordinator.
2) RETAIN S/CI item for training purposes if not requested by OIG, in accordance with section 6.4.
c) IF items are to be disposed of as excess, THEN SELECT “Reject” disposition
1) SUBMIT DECEX form 24590-GPA-F00006 in accordance with 24590-WTP-GPP-RAPS-GP-1028.
e. IF the item is determined not to be a S/CI, THEN PERFORM the following:
1. NOTIFY S/CI Identifier that the item has been determined to not be S/CI.
2. UPDATE the S/CI log.
3. CONTINUE the NCR process.
6.2.6 Asset Management PERFORMS the following steps:
a. IF the NCR requires disposal of the item, THEN DISPOSE the S/CI item. (24590-WTP-GPP-RAPS-GP-1028, Government Property – Scrap/Salvage provides details).
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6.3 IDENTIFICATION OF QUESTIONABLE ITEMS BY SUBCONTRACTOR/SUPPLIER
NOTE:
It is the responsibility of all subcontractor/suppliers that are located directly on the WTP site to report questionable items that have been delivered and are located at the WTP project that exhibit S/CI indicators to their manager/supervisor and the S/CI Coordinator. Typical S/CI indicators can be found on Attachment 2. Records from Kobe Steel Ltd, Kobe Steel USA, Kobelco, or other implicated affiliates, are considered an S/CI Indicator, based on their admittance of record falsification.
An additional listing of indicators of S/CIs can be found in DOE S/CI Guide 414.1-3 Appendix 4 which can be found on the S/CI homepage, which is located on the WTP Project home page under Safety and Quality.
The subcontractor/supplier process flowchart can be found on Attachment 4. For better viewing, the zoom feature in the electronic version may be used.
6.3.1 The WTP on site Subcontractor/Supplier (including sub-tier) PERFORMS the following steps:
a. IF an item exhibits S/CI indicator(s), (examples in Attachment 2) THEN IDENTIFY the item as questionable and SECURE item from use by segregation and/or tagging.
b. NOTIFY WTP Subcontract/Procurement interface and PROVIDE information regarding item.
6.3.2 The Subcontract/Procurement interface PERFORMS the following step:
a. NOTIFY the S/CI Coordinator regarding questionable items discovered by the subcontractor/supplier.
6.3.3 The S/CI Coordinator PERFORMS the following steps:
a. INITIATE S/CI log entry and provide communication to WTCC POC.
b. INVESTIGATE item in question and gather information (photographs, procurement documents, etc.).
c. IF the investigation of the questionable item becomes complex in nature, THEN ASSEMBLE a team of appropriate personnel (i.e., Technical Specialists) to evaluate the item.
6.3.4 The Evaluation Team PERFORMS the following steps:
a. EVALUATE questionable item regarding S/CI validity.
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b. NOTIFY S/CI Coordinator with results.
6.3.5 The S/CI Coordinator PERFORMS the following steps:
a. DETERMINE whether the item is S/CI using input from the evaluation team.
b. IF the item is determined to be a S/CI, THEN PERFORM the following:
1. DOCUMENT the determination with a Surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.
2. NOTIFY Subcontractor/Procurement interface to impound WTP owned item and control the S/CI in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.
c. IF item is not S/CI, THEN PERFORM the following:
1. NOTIFY S/CI Identifier (Subcontractor/Procurement interface) that item has been determined to not be S/CI.
6.3.6 The Subcontract/Procurement interface PERFORMS the following step:
a. WHEN notified by the S/CI Coordinator that an item has been determined to be S/CI, THEN IMPOUND and CONTROL the WTP owned S/CI in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.
b. IF an NCR has not yet been initiated, THEN INITIATE an NCR in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.
6.3.7 The S/CI Coordinator PERFORMS the following steps:
a. WHEN an item has been determined to be S/CI, THEN PERFORM the following:
1. VALIDATE the NCR that was initiated to document the S/CI.
2. NOTIFY the following within 3 days of the determination via email using a CCN:
DOE
Office of Environmental, Safety, and Health
OIG
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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3. NOTIFY Occurrence Reporting.
4. UPDATE S/CI log with determination.
NOTE:
The OIG typically responds within 10 days. The response identifies the OIG’s intent regarding a course of action.
5. IF OIG response is not received within 10 working days, THEN CONTACT OIG and OBTAIN a timeframe in which their response will be provided.
6. UPDATE S/CI log with OIG response.
7. WHEN response is received from OIG, THEN NOTIFY affected management, utilizing the project organizational chart, of path forward regarding OIG disposition.
8. UPDATE the NCR disposition to reflect OIG response.
a) IF the OIG requests the items, THEN SELECT “Reject” disposition
1) SUBMIT Shipping Request Form 24590-GCB F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the OIG.
b) IF items are requested to be retained for S/CI training, THEN SELECT “Reject” disposition
1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the S/CI Coordinator.
2) RETAIN S/CI item for training purposes if not requested by OIG, in accordance with section 6.4.
c) IF items are to be disposed of as excess, THEN SELECT “Reject” disposition
1) SUBMIT DECEX form 24590-GPA-F00006 in accordance with 24590-WTP-GPP-RAPS-GP-1028.
6.3.8 Asset Management PERFORMS the following steps:
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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a. IF the NCR requires disposal of the item, THEN DISPOSE the S/CI item. (24590-WTP-GPP-RAPS-GP-1028, Government Property – Scrap/Salvage provides details).
6.4 S/CI RETENTION PROCESS
6.4.1 S/CI Coordinator PERFORMS the following steps for retained items:
a. WHEN S/CI is turned over to the S/CI Program for retention, THEN VERIFY the item is rendered useless.
b. ENSURE the item is:
Tagged with identification number
Recorded in S/CI Retention Log
Secured in S/CI Storage
6.5 EXTERNAL S/CI NOTIFICATIONS AND REVIEW PROCESS
6.5.1 S/CI Coordinator PERFORMS the following steps:
a. SCREEN S/CI notifications that are communicated through various sources to determine site-specific relevance, risks, and vulnerabilities.
NOTE:
Safety concerns are discussed with Safety and Health Management to determine if immediate/compensatory action should be initiated.
b. For S/CIs applicable to the site, INITIATE S/CI log entry.
c. INVESTIGATE (which includes distribution to applicable individuals) to determine if the item exists at the WTP, through interviews, word search of project documents, etc. If the item exists at WTP, go to section 6.2.2.
d. DOCUMENT the determination with a Surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.
6.6 EXTERNAL DI NOTIFICATIONS AND REVIEW PROCESS
6.6.1 The S/CI Coordinator PERFORMS the following steps:
NOTE:
A current list of S/CI and DI notifications can be found on the WTP project intranet home page. The review process for external notifications is described in sections 6.5 and 6.6.
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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a. SCREEN DI information regarding defective or recalled items as communicated through DOE Corporate Operating Experience Program documents and external operating experience documents for site-specific relevance, risks, and vulnerabilities.
NOTE:
Safety concerns are discussed with Safety and Health Management to determine if immediate/compensatory action should be initiated.
The applicability review is performed and documented through the project issues management process.
b. IF DI is potentially applicable to WTP, THEN DISTRIBUTE the DI by initiating a Recommendation in accordance with 24590-WTP-GPP-RACA-CR-0110, Condition Report and Recommendation Initiation.
7.0 ACCEPTANCE CRITERIA
N/A
8.0 TRAINING
The following training (e.g., qualifications, training components, certifications) are required in order to perform this procedure:
Role Qualification
Managers, Supervisors, Inspectors (Assigned to Mid-Level)
(CBT) 24590-WTP-CBT-TRA-000546 RR – 24590-WTP-GPP-RAQA-QA-0003
9.0 RECORDS
Records generated during the performance of this procedure include the following:
OIG Notification (CCN)
10.0 REFERENCES
10.1 INTERFACING REFERENCES
24590-WTP-GPP-RAPS-SQ-1044, FIELD MATERIAL RECEIVING
24590-WTP-GPP-RAPS-MM-1103, FIELD MATERIAL WITHDRAWAL AND SHIPPING
24590-WTP-GPP-RAPS-GP-1028, GOVERNMENT PROPERTY – SCRAP/SALVAGE
I ~ =====--+ ............... ........____----i, '-- I
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
Control of Suspect/Counterfeit Items 24590-WTP-GPP-RAQA-QA-0003, Rev 5 Level of Use: Information
24590-RAPR-F00001 Rev 15 (Revised 7/23/2019) Page 21 of 27 Ref: 24590-WTP-GPP-RAPR-PR-1001
24590-WTP-GPP-RAQS-NC-0002, NONCONFORMANCE REPORTING AND CONTROL
24590-WTP-GPP-RAQS-NC-0001, OPERATING NONCONFORMANCE REPORTING AND CONTROL
24590-WTP-GPP-RAPS-SQ-1041, RECEIVING INSPECTIONS
24590-WTP-GPP-RACA-LL-0001, WTP LESSONS LEARNED
24590-WTP-GPP-RACA-TM-0001, TREND ANALYSIS AND REPORTING
24590-WTP-GPP-RAQA-QA-1000, QUALITY ASSURANCE SURVEILLANCE
24590-WTP-GPP-RACA-CR-0110, CONDITION REPORT AND RECOMMENDATION INITIATION
10.2 DEVELOPMENTAL REFERENCES
24590-WTP-QAM-QA-06-001, QUALITY ASSURANCE MANUAL
24590-WTP-QAM-RAQA-QA-0001, COMMISSIONING AND OPERATIONS QUALITY ASSURANCE MANUAL
DOE G 414.1-3, SUSPECT/COUNTERFEIT ITEMS GUIDE FOR USE WITH 10 CFR 830 SUBPART A, QUALITY ASSURANCE REQUIREMENTS
DOE O 414.1C, QUALITY ASSURANCE
DOE G 414.1-2B, QUALITY ASSURANCE PROGRAM GUIDE
IAEA-TECDOC-1169, MANAGING SUSPECT AND COUNTERFEIT ITEMS IN THE NUCLEAR INDUSTRY
DOE O 414.1D, QUALITY ASSURANCE
10.3 FORM REFERENCES
24590-GCB-F00006, WTP Shipping Request Form 24590-GPA-F00006, Declaration of Excess (DECEX) Form
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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ATTACHMENT 1 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS
ACRONYMS and ABBREVIATIONS BNI-WTP Bechtel National Inc.- Hanford Tank Waste Treatment and Immobilization Plant DI Defective Item DOE US Department of Energy HSS DOE Office of Health, Safety, and Security NCR Non-Conformance Report OIG Office of Inspector General QA Quality Assurance S/CI Suspect/Counterfeit Item UOS&D Unsatisfactory, Over, Short and/or Damaged WTCC Waste Treatment Completion Company LLC WTP Hanford Tank Waste Treatment and Immobilization Plant
Definitions
suspect/counterfeit item (S/CI)
An item is suspect when inspection or testing indicates that it may not conform to established Government or industry-accepted specifications or national consensus standards or whose documentation, appearance, performance, material, or other characteristics may have been misrepresented by the supplier or manufacturer. A counterfeit item is one that has been copied or substituted without legal right or authority or whose material, performance, or characteristics have been misrepresented by the supplier or manufacturer. Items that do not conform to established requirements are not normally considered S/CIs if nonconformity results from one or more of the following conditions (which must be controlled by site procedures as nonconforming items):
defects resulting from inadequate design or production quality control;
damage during shipping, handling, or storage;
improper installation;
deterioration during service;
degradation during removal;
failure resulting from aging or misapplication; or
other controllable causes.
Subcontract/ Procurement Interface
Individual serving as the Point of Contact responsible for contractual interaction. May also be known as Buyer, Subcontract Administrator, Procurement Representative, etc.
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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ATTACHMENT 2 S/CI INDICATORS
The following are examples of misrepresented products identified by DOE and US Nuclear Regulatory Commission (NRC) licensees. These are provided as example of S/CI indicators.
1. Visual Inspection (Items may be substandard or fraudulent when):
Name plates, labels, or tags:
Have been altered, photocopied, painted over
Are not secured well
Show incomplete data
Are missing (e.g., preprinted labels normally show typed entries).
Obvious attempts at beautification have been made (e.g., excess painting or wire brushing, evidence of hand painting [touch-up], or stainless steel is painted)
Handmade parts are evident, gaskets are rough cut, or shims and thin metal part edges show evidence of cutting or dressing by hand tools (e.g., filing, hacksaw marking, or use of tin snips or nippers)
Hand-tool marks are on fasteners or other assembly parts (e.g., upset metal exists on screw or bolt heads) or dissimilar parts are evident (e.g., majority of bolts are of the same material and one or more bolts are a different material)
There is a poor fit between assembled items
Configuration is not consistent with other items from the same supplier or varies from that indicated in supplier literature or drawings
There is an unusual box, or unusual packing of component or item
The supplier is not a factory-authorized distributor
Dimensions of the item are inconsistent with the specifications requested on the PO and/or those provided by the supplier at the time of shipment
The item or component matches the description of one that is on a suspect items list
2. Documentation (Documents may be suspect and/or counterfeit when):
Provided from Kobe Steel Ltd, Kobe Steel USA, Kobelco or other implicated affiliates that have admitted to falsification of records. (link to Kobe companies: http://www.kobelco.co.jp/english/about_kobelco/group/ ) or (BNI Procurement Management may be contacted for current list of Kobe affiliates)
The use of correction fluid or correction tape is evident
Type or pitch change is evident
The document is not signed or initialed when required or is excessively faded or unclear (indicating multiple, sequential copying), or data are missing
The name, or title, of the document approver cannot be determined
Technical data is inconsistent (e.g., chemical analysis indicates one material and physical test indicates another)
Certification or test results are identical between items when normal variations should be expected
Document traceability is not clear. The document should be traceable to the item(s)
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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Technical data are not consistent with code or standard requirements (e.g., no impact test results provided when impact testing is required, or certified material test report physical test data indicates no heat treatment and heat treatment is required)
Documentation is not delivered as required on the PO or is in an unusual format
Lines on forms are bent, broken, or interrupted, indicating data has been deleted or exchanged (e.g., cut and paste)
Handwritten entries of data are on the same document where typed or preprinted data exists
Data on a single line located at different heights indicate the possibility of retyping
3. Fasteners
Head markings are marred, missing, or appear to have been altered
Threads show evidence of dressing or wear (i.e., threads should be of uniform color and finish)
Head markings are inconsistent with a heat lot
Head markings matching one of those identified on the suspect headmark list
4. Electrical Devices
Connections show evidence of previous attachment (e.g., metal upset or marring)
Connections show arcing or discoloration
Fasteners are loose, missing, or show metal upset
Molded case circuit breakers are not consistent with manufacture-provided checklists for detecting substandard and/or fraudulent breakers
Missing, or photocopied, Underwriters Laboratories labels on products requiring such
Altered markings (i.e., hand painted information)
5. Rotating Machinery and Valve Internal Parts
Shows marring, tool impressions, wear marks, traces of Prussian blue or lapping compound, or other evidence of previous attempts at fit-up or assembly
Heat discoloration is evident
Evidence of erosion, corrosion, wire-drawing, or “dimples” (i.e., inverted cone-shaped impressions) on valve discs, seats, or pump impellers)
6. Valves
Painted valve appears to be freshly painted and valve stem has paint on it
Wear marks are on any painted surface
Valve stem is protected, but protection has paint on it
Paint does not match standard original equipment manufacturer (OEM) color
Valve Tags:
Are attached with screws instead of rivets
Are attached in a different location than normal
Appear to be worn or old
Have paint on them
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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That look newer than the valve
Have no part numbers
Show irregular stamping
Handwheels
Are old looking handwheels on new looking valves
Look sand-blasted or newer than the valve
There are different types of handwheels on valves of the same manufacturer
Bolts and Nuts
Have a used appearance (e.g., excessive wrench marks on flats)
Material is improper (e.g., a bronze nut on a stainless-steel stem)
Valve Body
The ground off casting marks with other markings stamped in the area (i.e., OEM markings are nearly always raised, not stamped)
There are signs of weld repairs
There are incorrect dimensions
There is a freshly sand-blasted appearance, including eye bolts, grease fittings, stem, etc.
There is evidence of previous bolt head scoring on backsides of flanges, or evidence that this area has been ground to remove such marks
On a stainless valve, finish that is unusually shiny indicates bead-blasting. A finish that is unusually dull indicates sand-blasting. The finish on a new valve is in-between.
Manufacturer’s Logo
Is missing
The logo plate looks newer than the valve
The logo plate shows signs of discoloration from previous use
Other
There is foreign material inside the valve (e.g., metal shavings)
There is valve stem packing that shows all the adjustments have been run out
There are in-gate valves, a gate that is off-center when checked through the open end of the valve
There are obvious differences between valves in the same shipment
7. Price
Price is significantly less than that of the competition
Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
Control of Suspect/Counterfeit Items 24590-WTP-GPP-RAQA-QA-0003, Rev 5 Level of Use: Information
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ATTACHMENT 3 WTP EMPLOYEE FLOWCHART
Suspect/ Counterfeit Items Process
S/CI
Iden
tifie
rS/
CI C
oord
inat
orS/
CI a
nd E
ng
Eval
uatio
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amO
ccur
renc
e R
epor
ter
OIG
WTP Employee Process of Identification of Questionable items that contain characteristics of being S/CI
An item is identified as exhibiting characteristics/indications of
being S/CI
Investigate Item in question, and gather information, photo’s,
etc..
Based on complexity, S/CI Evaluation team may be
formed and receive information to review
Determine applicable Technical Specialists for
Evaluation Team and capture in S/CI Log
Notify S/CI Coordinator, secure item from use and Initiate NCR providing
a description of S/CI concern
Team responds within target of 10 working days regarding the
validity of the S/CI item
Is the Item S/CI?
Fill out OIG Notification form and send to OIG, DOE within 3 days of
decisionConcurrently notify
Occurrence reporting
No
Provide disposition to close NCR, Update S/CI
log and notify S/CI Identifier
Notified of team determination
OIG reviews information and determines if
further involvement on their part is needed
Receive response from OIG, updates
S/CI log, send Notification to
distribution, and provide disposition
for NCR
Receive Notification that OIG is being contacted
Coordinate disposition of the S/CI in accordance
with the applicable procedures referenced in sections 6.2 and 6.4
Based on feedback from OIG, provide
final disposition on NCR
Yes
Validate NCR and ensure tags are
applied
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Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.
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ATTACHMENT 4 SUBCONTRACTOR/SUPPLIER FLOWCHART
Suspect/ Counterfeit Items Process
S/CI
Iden
tifie
rS/
CI C
oord
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CI a
nd E
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Eval
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Repo
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OIG
Subc
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Pr
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WTP Supplier/Subcontractor Process of Identifying Questionable items that contain characteristics of being S/CI
An item is identified as exhibiting characteristics/indicators of
being S/CI
The Procurement & Subcontract interface is
informed of the Questionable item and provided information
regarding item
Determine Applicable Technical Specialists for
Evaluation Team and capture in S/CI Log
Based on complexity, S/CI Evaluation team may be
formed and receive information to review
Investigate Item in question and gather
information, photo’s, etc..
Secure item using the Suppliers/Subcontractors
Program, the item is segregated and/or tagged
as Questionable
Team responds within target of 10 working days regarding the
validity of the S/CI item
Is the Item S/CI?
Send notification to OIG, DOE within 3 days of decision
Concurrently notify Occurrence reporting
No
Update S/CI log and notify S/CI Identifier through the Supplier/
Subcontractor interface
Notified of team determination that item
was not S/CI and communicate with
Identifier
OIG reviews information and determines if
further involvement on their part is needed
Receive response from OIG, updates
S/CI log, send Notification to
distribution, and provide disposition
for NCR
Receive Notification that OIG is being contacted
Yes
Update S/CI log and contact Supplier/Subcontract interface to
secure S/CI item from Subcontractor
notify the S/CI Coordinator with
applicable information
Support process of impounding the WTP owned S/CI item from
the Subcontractor/Supplier
Becomes aware of the segregated
Questionable item
Receive Notification that the Questionable item was
determined to be S/CI. And request to impound item
Provide the S/CI item to Buyer
(Subcontractor/Procurement
interface)
S/CI Item received and impounded and
initiate NCR to control item
Notified of team determination that item
was not S/CI
Communicates results to WTP S/CI
Coordinator
Coordinate disposition of the S/CI in accordance with the
applicable procedures referenced in sections 6.3
and 6.4
Based on Feedback from OIG, Provide
Final Disposition on NCR
Validate NCR
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This document has been digitally signed using the Electrosign process.
Document for Signature
Document Number: 2490-WTP-GPP-RAQA-QA-0003 Rev: 5
Participants Signature Completed Status Result Comments
Signers 6/24/2020 6:17 PM
Hart, Dan 6/24/2020 6:23 PM Completed Approve
Fortier, Mike 6/24/2020 6:30 PM Completed Approve
Final Approver 6/24/2020 6:30 PM
Jolly, Raj 6/24/2020 8:24 PM Completed Approve
ELECTR□SIGN
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