Information Notice 1987-66, Inappropriate Application of Commercial-Grade Components

Inappropriate Application of Commercial-Grade Components

ML031130660
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	12/31/1987
From:	Rossi C Office of Nuclear Reactor Regulation
To:
References
IN-87-066, NUDOCS 8712290155
Download: ML031130660 (7)

IN 87-66 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.

ecto 1 Charlesi E. Rossi, Division of Operational Events Assessment

Office elf Nuclear Reactor Regulation

Joseph J. Petrosino, NR.R

(301) 492-4316 Attachment:

List of Recently Issued NRC Information Notices

Attachuent

IN 87-66 December 31. 1987 .1 LIST OF RECENTLY ISSUED

NRCINFORMATION NOTICES 1987 Informaet-o-n ate or_

Notice No. Subject Issuance Issued to

87-28, Air Systems Problems at 12/28/87 All holders of OLs

Supp. 1 - U.S. Light Water Reactors or CPs for nuclear

power. reactors.

87-65 Plant Operation Beyond 12/23/87: All holders of OLs

Analyzed Con4it1ons or CPs'for nuclear

power reactors.

87-64 Convictioi for'Falsificaion 12/22/i7 'All nuclear power

of Security Tr4ining Record* reactor facilities

holding an OL or CP

and all major fuel

fac111ty licensees.

87-35, Reactor Trip Breoker 12/16/87 All holders of OLs

Supp. 1 Westinghouse 0oel DS-416. or CPs for nuclear

Failed to Open on Manual power reactors.

Initiation From the Control

Room

87-63 Inadequate Net Poitive 12/9/47 All holders of OLs

Suction Head in Low Preisure or CPs for nuclear

Safety Systems powei' reactors.

87-62 Mechanical Failure of 12/4/07 All holders of OLs

Indicating-Type Fuses or CPs for nuclear

powel reactors.

87-61 Failure of Westinghousum 12/7/87 All holders of OLs

W-2-Type Circuit Breaker or CPs for nuclear

Cell, Switches. power reactors.

... 87-60 Depressurization of Rflactor 12/4/87 All holders of OLe

Coglant Systems in or CPs for PWRs.

Pr 1ijrized-Water Reactors

I:.-

OL a Operating License

CP = Construction Porlit

UNITED STATES

NUCLEAR REGULATORY COMMISSION FIRST CLASS MAIL

POSTAGE & FEES PAID

WASHINGTON, D.C. 20555 USUISRC

PERMIT No. 0GF7 OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE. S300

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

Joseph J. Petrosino, NRR

(301) 492-4316 Attachment:

List of Recently Issued NRC Information Notices

• See previous concurrences

• VIB:DRIS *VIB:DRIS *GCB:DOEA:NRR *GCB:DOEA:NRR *TECH EDITOR

JPetrosino JStone SMackay CBerlinger AThomas

12/23/87 12/23/87 12/23/87 12/23/87 12/23/87 12t.1/87 Cow~ p a 7:,B

g .Z96

.

P"->e r/g s7>Y

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IN 8fg

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

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

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:

~~~~~~~~~~~-

- - - - - :-- ---- -- - a------ ------ _____

______

__________

______

NAME : no * ne  ::tRP'c a) :CHBerlinger :A.toHAss : CERossi

DATE :.1/p'cZ87  : t/t5/87  :/t/z3187  : / /87  :/X /7g-187 : / /87  :

• The Amerace Corporation QA Director and Chief Engineer concurred by telephone.