Information Notice 1987-66, Inappropriate Application of Commercial-Grade Components
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF 'NUCLEAR REACTOR REGULATION
WASHINGTON, d. C. 20555
December 31, 1987 NRC INFORMATION NOTICE NO. 87-66:
INAPPROPRIATE APPLICATION'OF COMMERCIAL-
GRADE COMPONENTS
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 inappropriate application of commercial-grade com- ponents within qualified Class lE electrical panels and to identify the
'differences in the quality and qualified life expectancy between a particular
manufacturer's nuclear-grade and commercial-grade relays.
It is expected that recipients will review this information for applicability
to their facilities and consider actions, as appropriate, to avoid similar
problems.
However, suggestions contained in this information notice do not
constitute NRC requirements; therefore, no specific action or written response
is required.
Description of Circumstances
During a September 16-October 3, 1986 NRC inspection at the Sequoyah Nuclear
Plant, Units 1 and 2, it was revealed that the licensee had replaced previously
qualified equipment with components and parts of commercial-grade, without pro- viding adequate documentation of their qualifications and dedication. The items
selected by the NRC inspectors included two Agastat time-delay relays from one
Class lE panel.
Both relays were Agastat model number 7012PD relays. The
manufacturer's markings on these two relays indicate that they were neither
manufactured nor controlled as qualified Class lE components, because the model
number is not preceded by an "E."
The licensee was unable to identify or produce
the procurement documents for these relays; consequently, the inspectors presumed
that these components had not been supplied or dedicated as qualified devices.
Therefore, the qualification of the panel was deemed "indeterminate," since the
components may not have been capable of performing their intended function.
872905
IN 87-66 December 31, 1987 During an NRC inspection on May 11-22 and June 1-5, 1987 at the Joseph M. Farley
Nuclear Plant, Units 1 and 2, it was revealed that the licensee had allowed
commercial-grade components to be purchased for Class 1E panels without adequate
evidence of component qualification.
As a result, hardware items were installed
in safety-related applications where they may not have been capable of performing
their intended function.
One example at Farley was the installation of a
commercial-grade Agastat relay in a Class 1E panel.
The Agastat model number
on the relay was not prefixed by an "E"; hence, the relay was not considered
Class lE-qualified by the manufacturer nor was it found to have been dedicated
by the licensee for Class lE application.
The NRC requested and received information from the Amerace Corporation of
Union, New Jersey, concerning the projected qualified life of its nuclear
grade (E series) Agastat and commercial-grade electrical relays.
Amerace
indicated that its typical 7000 nuclear grade E series electrical-pneumatic
timing relays have a projected qualified life of 10 years from date of manu- facture or 25,000 operations, whichever occurs first.
Its commercial-grade
7000 series relays have a 2-year projected qualified life.
Discussion:
The relays discussed above are all electrical-pneumatic Amerace Agastat timing
relays.
These-relays are being used here as an example of how degradation of
a qualified component or system can occur if a licensee does not implement
-adequate controls In procurlng replacement components. IneP aie'n'apparent
physical form, fit, or function differences between the commercial-grade and
nuclear-grade Agastat relays.
However, there are several very distinct dif- ferences in the design, manufacturing, testing, and modification controls that
are imposed by Amerace for the two different relay series, as discussed below:
Commercial-Grade 7000 Series Relays
1. No design change or configuration controls are required.
2.
Functionability product testing is neither as comprehensive nor as docu- mented as for the comparable E7000 series testing.
3.
Internal component substitutions are not documented or controlled, and
parts that can be rejected for the E7000 series can be utilized in the
7000 series.
4.
Commercial-grade relays are assembled and manufactured at facilities in
Mexico, Canada, Belgium, and Union, New Jersey.
5.
Undocumented field modification of the 7000 series relays is allowed by
the distributors as they deem necessary.
6. Amerace does not project a qualified life expectancy longer than two
years for these relays.
IN 87-66 December 31, 1987 Nuclear-Grade E7000 Series Relays
1. The design, manufacture, modification, and testing are performed only
at the Union, New Jersey facility under a 10 CFR Part 50 Appendix B
and ANSI N-45.2 program.
2. Amerace imposes in-process manufacturing inspections that are more stringent
than for its commercial-grade series.
/
3. Design and configuration traceability control is in place for each
piece-part.
4. The projected qualified life expectancy is 10 years or 25,000 operations.
5. Only the E7000 series relay is tested and analyzed to comply with the
requirements of the applicable iEEE and ANSI standards.
6.
Final functionability tests areiperformed to encompass all operational
parameters for each E7000 series; relay.
The NRC staff learned of these differences during a vendor inspection and sub- sequent discussions with Amerace personnel. These types of differences in a
manufacturer's product should be readitly discernible by a licensee's pre-award
survey and procurement program actions, regardless of the type of replacement
component purchased..-
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 Adnministrator of the appropriate Regional
Office.
Charlesi E. Rossi, ecto 1
Division of Operational Events Assessment
Office elf Nuclear Reactor Regulation
Technical Contact:
Joseph J. Petrosino, NR.R
(301) 492-4316 Attachment:
List of Recently Issued NRC Information Notices
Attachuent
December 31. 1987 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES 1987
.1 Informaet-o-n
Notice No.
87-28, Supp. 1 -
87-65
87-64
87-35, Supp. 1
87-63
87-62
87-61 Subject
Air Systems Problems at
U.S. Light Water Reactors
Plant Operation Beyond
Analyzed Con4it1ons
Convictioi for'Falsificaion
of Security Tr4ining Record*
Reactor Trip Breoker
0oel DS-416.
Failed to Open on Manual
Initiation From the Control
Room
Inadequate Net Poitive
Suction Head in Low Preisure
Safety Systems
Mechanical Failure of
Indicating-Type Fuses
ate or_
Issuance
Issued to
12/28/87
All holders of OLs
or CPs for nuclear
power. reactors.
12/23/87:
All holders of OLs
or CPs'for nuclear
power reactors.
12/22/i7
'All nuclear power
reactor facilities
and all major fuel
fac111ty licensees.
12/16/87
All holders of OLs
or CPs for nuclear
power reactors.
12/9/47
All holders of OLs
or CPs for nuclear
powei' reactors.
12/4/07
All holders of OLs
or CPs for nuclear
powel reactors.
12/7/87
All holders of OLs
or CPs for nuclear
power reactors.
12/4/87
All holders of OLe
...
87-60
Failure of Westinghousum
W-2-Type Circuit Breaker
Cell, Switches.
Depressurization of Rflactor
Coglant Systems in
Pr 1ijrized-Water Reactors
I: .-
OL a Operating License
CP = Construction Porlit
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
OFFICIAL BUSINESS
PENALTY FOR PRIVATE USE. S300
FIRST CLASS MAIL
POSTAGE & FEES PAID
USUISRC
PERMIT No. 0GF7
IN 87-66 December 31, 1987 Nuclear-Grade E7000 Series Relays
1. The design, manufacture, modification, and testing are performed only
at the Union, New Jersey facility under a 10 CFR Part 50 Appendix B
and ANSI N-45.2 program.
2. Amerace imposes in-process manufacturing inspections that are more stringent
than for its commercial-grade series.
3.
Design and configuration traceability control is in place for each
piece-part.
4. The projected qualified life expectancy is 10 years or 25,000 operations.
5. Only the E7000 series relay is tested and analyzed to comply with the
requirements of the applicable IEEE and ANSI standards.
6.
Final functionability tests are performed to encompass all operational
parameters for each E7000 series relay.
The NRC staff learned of these differences during a vendor inspection and sub- sequent discussions with Amerace personnel.
These types of differences in a
manufacturer's product should be readily discernible by a licensee's pre-award
survey and procurement program actions, regardless of the type of replacement
component purchased.
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.
Original Sgo9d by
CMaIdet £- Rss
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact:
Joseph J. Petrosino, NRR
(301) 492-4316 Attachment:
List of Recently Issued NRC Information Notices
- See previous concurrences
- VIB:DRIS
- VIB:DRIS
JPetrosino
JStone
12/23/87
12/23/87 p a
7:,B
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Cow~
.Z96 P"->e
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- GCB:DOEA:NRR
SMackay
12/23/87
- GCB:DOEA:NRR
CBerlinger
12/23/87
- TECH EDITOR
AThomas
12/23/87
12t.1/87
IN 8 fg
January
, 198e Nuclear-Grade E7000 Series Relays
1. The design, manufacture, modification, and testing are performed only
at the Union, New Jersey, facility under a 10 CFR Part 50 Appendix B
and ANSI N-45.2 program.
2. TAC imposes in-process manufacturing inspections that are more stringent
than its commercial-grade series.
3. Design and configuration traceability control is in place for each
piece-part.
4. The projected qualified life expectancy is 10 years or 25,000 operations.
5. Only the E7000 series relay is tested and analyzed to comply with the requirements
of IEEE-323, IEEE-344, and ANSI C37.98.
6.
Final functionability tests are performed to encompass the entire operational
parameter for each E7000 series relay.
The NRC staff learned of these differences during a TAC vendor inspection and
subsequent discussions with TAC personnel. These types of differences in a
manufacturer's product should be readily discernible by a licensee's pre-award
survey and procurement program actions, regardless of the type of replacement
component purchased. These examples reflect a failure on the part of these
licensees to adequately implement pre-award survey, procurement, and commercial
component dedication programs. Licensee's should take appropriate measures to
ensure that Class lE-qualified replacement components are either procured as
Class lE-qualified components, or that the basis for using a commercial-grade
component in a safety-related application is adequate.
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:
Joseph J. Petrosino, NRR
(301) 492-4316 Attachment:
List of Recently Issued NRC Information Notices
- See previous concurrences
Ofe
VIB:DRIS
VIB:DRIS
GCB:DOEA:NRR
GC:DOEA:NRR
TECW EDITOR
D:DOEA:NRR
JPetrosino*
JStone*
SMackay
CBerlinger
d
T~orm5 CERossi
12/23/87
12/23/ 87
12/1:/87
12 ?"/87
12/z3/87
12/ /87
IN 8f- January , 198t 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:
Joseph J. Petrosino, NRR
(301) 492-4316 Attachment:
List of Recently Issued NRC Information Notices
OFC
- HIB:
I Vki
- GCB: DOEA:NRR: GC9B: DME:NRR:TECH EfiITUR :D:DOEA:NRR:
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- CHBerlinger :A.toHAss : CERossi
DATE :.1/p'cZ87
- t/t5/87
- /t/z3187
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- /X /7g-187 :
/
/87
- The Amerace Corporation QA Director and Chief Engineer concurred by telephone.