ML20248A548

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Forwards Compilation of Fastener Testing Data Received in Response to NRC Compliance Bulletin 87-002. Rept Analyzes Data on Nonconforming Fasteners in Nuclear Industry.Related Info Also Encl
ML20248A548
Person / Time
Issue date: 07/26/1989
From: Carr K
NRC COMMISSION (OCM)
To: Dingell J
HOUSE OF REP., ENERGY & COMMERCE
References
IEB-87-002, IEB-87-2, NUDOCS 8908080310
Download: ML20248A548 (21)
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NUCLEAR REGULATORY COMMISSION j-* j WASHINGTON, D. C. 20555 e

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July 26, 1989 CHAIRMAN The Honorable John D. Dingell, Chaiman Subcommittee on Oversight and Investigations Committee on Energy and Commerce United States House of Representatives Washington, D.C. 20515

Dear Mr. Chairman:

In keeping with our comitment to provide the Subcommittee with information regarding Nuclear Regulatory Comission (NRC) actions on nonconforming fasteners, I am providing a copy of the recently issued report, " Compilation of Fastener Testing Data Received in Response to NRC Compliance Bulletin 87-02," NUREG-1349. The report analyzes data on nonconforming fasteners in the nuclear industry.

A sumary of the data included in the NUREG report was previously provided in testimony to your Subcommittee in June 1988. The data has now been sorted by licensee, manufacturer, supplier, and specification. The data supplied indicated a nonconforming rate of 8 percent for safety-related and 12 percent for nonsafety-related fasteners. Approximately 2 percent of the safety-related fasteners were sufficiently out of specification to warrant follow-up by the NRC to assure that licensees had taken appropriate action. Also enclosed is a copy of s temporary instruction that contains guidance to NRC inspectors regarding follow-up actions to be taken for plants with inventories that contained nonconforming fasteners as identified in data provided to the NRC.

' The NRC is concerned with the broader preidem of counterfeit and fraudulently marketed parts in the nuclear industry and has issued an Advance Notice of Proposed Rulemaking, which was published in the Federal Register on March 6, 1989, to solicit coments regarding what action needs to be taken by the NRC to help assure that products purchased for use in nuclear power plants meet the required specifications. In addition, the NRC issued a generic letter to all licensees on Mar? 21, 1989, specifying actions that should be considered to ensure effective sroarement, inspection, testing, and dedication programs.

Copies of these actias ete also enclosed.

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.The Honorable John D. Dingell .,.

NRC appreciates the efforts of your Subcommittee to focus industry and ,

f Government attention on the problem of counterfeit and fraudulently marketed 4 vendor products, and I am optimistic that NRC's actions in this area will address and resolve this problem in the nuclear industry.

L Sincerely, mW Kenneth M. Carr

Enclosures:

1. Compilation of Fastener Testing Data Received in Response to NRC Compliance Bulletin 87-02, NUREG-1349, June 1989
2. Inspection Requirements for NRC Compliance Bulletin 87-02 " Fastener Testing To Determine Conformance with Applicable Material Specifications," TI 2500/27, dtd May 22, 1989
3. Acceptance of Products Purchased For Use In I Nuclear Power Plant Structures, Systems, and Components, ANPR, dtd March 6,1989
4. Actions to Improve the Detection of Counterfeit and Fraudulently Marketeo Products, Generic Letter 89-02, dtd March 21, 1989 cc: Rep.-Thomas J. B111ey

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[ r, UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, o. C. 20sss

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s e s' . p NRC INSPECTION MANUAL Rvle TEMPORARY INSTRUCTION 2500/27 INSPECTION REQUIREMENTS FOR NRC COMPLIANCE BULLETIN 87-02,

" FASTENER TESTING TO DETERMINE CONFORMANCE WITH APPLICABLE MATERIAL SPECIFICATIONS" 2500/27-01 PURPOSE To provide guidance in evaluating the adequacy of certain licensees' root cause analyses and the implementation of corrective actions in response to NRC Bulletin 87-02.

2500/27-02 OBJECTIVE To verify that licensees ensure that fasteners used in licensed nuclear plants meet the requisite specifications and that operability of safety-related components is not affected.

2500/27-03 BACKGROUND NRC Bulletin 87-02 requested licensees to test safety-related (SR) and nonsafety-related (NSR) fasteners. Supplements 1 and 2 to the Bulletin requested licensees to provide a list of the suppliers and/or manufacturers from whom the fasteners may have been purchased.

Temporary Instruction 2500/26 (deleted by CN 89-004) required an NRC inspector to participate in the licensee's selection of fasteners to be tested to assure that they were representative of installed fasteners.

2500/27-04 INSPECTION REQUIREMENTS This TI applies to 54 sites, and different sections of the TI apply to different plants. Attachment I lists which TI sections apply to which plants. No action is required for plants not listed in attachment 1.

04.01 Assure that adequate root cause analysis and corrective action has been taken by licensees for the significantly out of specification SR fasteners identified in Attachment 2.

Assess the adequacy of the licensee's effort to identify all possible locations where the fasteners may have been used and show that all applica-tions are acceptable and appropriate disposition has been implemented where needed to either "use as-is," or replace.

Issue Date: 05/22/89 ,

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'04.02 Ass,ess the adequacy of rcot cause analysis and corrective actions i taken by licensees which experienced high test failure rates (20 percent or i

. greater) for . SR - or NSR fasteners. particularly for cases which appear to involve inadequate material control. The licensee's analysis should address why the internal QA/0C activities did not discever the problem. A list of

-plants with high test failure rates can be found in Attachment 3.

l 04.03 Assure that appropriate correctivi action regarding potential use in '!

SR applications has been taken by licensees for the following NSR nonconform- i ing SAE J429 Grade 8 fasteners:

Flant[ Sample No.

ETiliockPt. BRP-24 l Catawba CATNS20 Fitzpatrick JAF-42 l

Sequcyah TVA-55312/5314 St. Lucie 30-02615-6.

The substandard results for these fasteners may be indicative of product substitution or counterfeiting; i.e., intentional mismarking of Grade. 8.2 as Grade 8 bolts. (Reference IE Infonnation Notice 80-25, Supplement I which describes " counterfeit fasteners.")

04.04 Assure that appropriate corrective action regardire the potential use of fasteners has been taken by licensees for the following SR and NSR noncon-forming SAE 429 Grade 5 fasteners:

Plant Sample No.

Erowns Ferry BNF-11/12 Davis-Besse DB-ISA/B Diablo Canyon -DC-193435 Duane Arnold DAEC-Y-22 Ft. Calhoun FC-6A/7A/CA/9A Kewaunee KNP-2-7F Limerick LGSI-7-QB McGuire MNS19/20/21 Prairie. Island PIB1/3 St. Lucie 29-98300-2 Watts Bar WB-7999/8002 The substandard results for these fasteners may be indicative of product

. substitution or counterfeiting; i.e., intentional mismarking of Grade 5.2s as Grada 5s.

The issue here is similar to the SAE J429 Grade 8 vs. 8.2 concerns. Grade 5 fasteners are medium carbon steel, quenched and tempered. Carbon content in Grade 5 should be 0.28-0.55 weight porcent, with no specification for boron.

Grade 5.2 fasteners are low carbon martensite steel, fully killed, fine grained, quenched and tempered. Carbon content in Grade 5.2 should be 0.15-0.25 weight percent with a minimum of 0.0005 weight percent boron. Both grades are heat treated, oil or water quenched and tempered at minimum tem-perature of 800'F. Mechanical properties are essentially identical.

5 Issue Date: 05/22/89 2500/27

V 04.05 In reviewing the responses to Bulletin 87-02, it was determined that not all licensees had tested the requested number of SR and NSR fasteners.

In order te tring the number tested to a minimum of 20 SR and a tctal of 40.

the followir.c plants should be notified that they have not satisfied the sarrpie testing requested by the Fulletir,. The litersee should be a:;ked what action is planned to sample and test additional fasterers and report those results to the NRC.

Number Tested Plant Name ] NSR Braidwood 10 l '.

Byron 19 21 Callaway 12 7 Calvert Cliffs 19 20 Cock 18 33 Harris 27 11 Indian Pt. 3 20 19 LaSalle 13 22 Monticello 18 22 ,

Prairie Island 18 18 Summer 10 13 ,

NRC inspectors should follow the requirements stated in TI 2500/26 for obser- {

vation of licensee selection of f asteners to be tested. j 04.06 Assess the adequacy of root cause analysis and corrective action regarding potential use taken by licensees for the significantly out of specification NSR fasteners listed in Attachment 4.

2500/27-05 GUIDANCE 05.01 Responses to Bulletin 87-02 indicated that several licensees have discovered fasteners that are significantly out of specification and/or have high failure rates. It is incumbent upon these licensees to detemine the cause of the substandard fasteners. The root cause analysis should determine if the acceptance and use of the substandard fasteners can be attributed to a failure of the licensee's QA program, failure of the supplier's 0A program, i or deliberate product substitution by the vendor. The analysis should also l consider why the licensee's QA prcgram failed to identify the problem. ]

05.02 Installed fasteners from tested heats or purchase order lots should meet the reouired specifications. If the specifications are not met, a i detailed ar.alysis for use of the fastener in the specific application used l or intended must be performed. The analysis should address the specific i deficiency of the fastener and why the fastener will be able to perform its )

function with that deficiency. If the fasteners are for use in an ASME Code,Section III application, the licensee must apply for and receive relief from f Code requirements from the NRC. Examine a representative sample of the 1 analyses performed to determine the adequacy of the licensee's action.

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_ _ __ _2500/27 Issue Date: 05/22/89 f

.. .j 2500/17-06 REPORTING REQUIREMENTS  !

l 06.01 The inspection effort shall be docurcented in a routine inspection l i

report. Copies of the inspection report should be sent to Ed Baker OWFN,-

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06.02 When inspection activities required by this TI are comnleted, enter the status of these activities in +.he SIMS data system. The SIMS issue number for this TI is BL-87-02.

2500/27.-07 'l l

The activities ree.uired by this TI shall be con:pleted by January 31, 1990.

2500/27-08 .

This TI shall remain in effect until June 1,1990. i 2500/27-09 CONTACTS Questions c.oncerning this TI should be addressed to Edward Baker, !!RR at (301)492-0959 or Greg Cwalina (301) 492-3221.

The Lead Project Manager for this TI is Thierry Ross.

2500/27-10 STATISTICAL DATA REPORTING Record actual inspection effort to this TI against Module Number 25027 (766 System)and 2500/27 (RITS)..

2500/27-11 OP,IGINATIllG ORGANIZATION INFORMATION I 11.01 The Vendor Inspection Branch of NRR initiated this TI.

11.02 It is estimated that direct inspection effort will range between 1 i and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> to complete the requirements for each of the affected sites  ;

(estimated as follows: )

TI Paragraph Hours 04.01 2 04.02 5 04.03 04.04 3

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) 1 04.05 1 l 04.06 4 The total estimated time to complete the inspection for all 54 sites is 317 hours0.00367 days <br />0.0881 hours <br />5.241402e-4 weeks <br />1.206185e-4 months <br /> (0.15 FTE).

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2500/27-12 REFERENCES NRC Bulletir. E7-01, " Fastener Testing to Deternir.e Confornence with Applicable Paterial Specification."

NRC Inspection Procedure 92701, " Fellow-up Testing to Ontermine Conformance l

1 with Applicable Material Specification" dated April 5,1988.

IE Information Notice 86-25, Supplement 1, " Traceability and Material

. Control of Material and Equipment, Particularly Fasteners."

END Attachments: 1. Plants Covered By TI 2500/27

2. Safety Related Fasteners with Substantial Deviations Warranting Licensee Action
3. Summary of Fastener Testing Data
4. Nonsafety Related Fasteners with Substantial Leviations Warranting Licensee Action
5. Other Fasteners with Substantial Deviations from l

Required Specifications

6. Estimate Site Inspection Resources Required l

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  1. ATTAC WENT 1

<g Plants Covered by This TI PLANT TI PARAGRAPH (S)

Region I Beaver Valley 01.06 Calvert Cliffs 01,05 Fitzpttrick 03,06 Ginna 01.06 Indian Point 3 05,06 Limerick 01.04,06 Maine Yankee 01,02 Nine Mile Point 01.02,06 Oyster Creek 01,06 Peach Botton 01,02.06 Pilgrim 02 Salem 02,06 Shoreham 02,06 Vermont Yankee 01,02,06 Region II

, Bellefonte 69 Browns Ferry 04 Brunswick 01 Catawba 03 Crystal River 01 Ferley 01 Grand Gulf 06 Harris 01,05 McGuire 1 02,04,06 North Anna 01 Robinson 01 Sequoyah 01.03 St. Lucie 03,04.06 Sumer 02,05.06 Surry 01 Vogtle 06 Watts Bar 01,04 Region III_

Big Rock Point 01,02,03 Braidwood 05 l Byron 05 l- Callaway 02.05,06 Clinton 01 Cook 05.06 Davis-Bessa 01,04,06 Duane Arnold 04

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ATTACHMENT 1 (CONT.)

Plants Covered by This TI I PLANT f TI PARAGRAPH (S)

Y Region III(cont.)

Fermi 06' Kewaunee 04

-LcSalle 02,05,06-Monticello 05 Palisades 01 Prairie Island 02,04,05.06 Point Beach .06.

Quad Cities 06 Region IV Comanche Peak OP' Ft. Calhoun 01,02.04 River Bend 01 Reginn V Trojan 01,02,06 Rancho'Seco 02.06 Diablo Canyor 1 01.04.

WPPSS- 06 I

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Issue Date: 05/22/89 Al-2 Attachment 1,2500/27

.c ATTACHMENT 2 SAFETY-PELATED FASTENERS WITH SUBSTANTIAL DEVIATIONS WARRANTING FOLLOW-UP ACTION PLANT NAME -SAMPLE N0. DESCRIPTION Beaver Valley BVI-12 ASTM A194 G2H 5/8 HEX NUT Bellefonte BLN-6996 ASME SA194 GR2H 1 1/0-7 NUT Big Rock Pt. BRP-39 ASTM A194 GR2H 1 1/8 hbT Brunswick- B507 STU ASTM SA193 GRB8 STUD

, Calvert Cliffs CCNPP-1(F) ASME SA193 GRB6 3/4 X 6' STUD CCNPP-I(N) ASME SA194 GR6F 3/4 HEX NUT Clinton CPS-18A ASME SA320 GRL7 3/4-10 X 3 CAPSCREW Crystal River CR3 a ASTM A325 TP3 3/4-10 X 2 1/2 HH BOLT

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CR3-?9 ASTM A307 GRA 1/2-13 X 2 1/2 SOCKET HCS Davis-Besse DB-17A ASME SA194 GR2H 1/4-20 NUT DB-17B ASME SA194 GR2H 1/4-20 NUT Diablo Canyon DC-938166 ASME SA194 GR7 1 1/8-7 HH NUT Farley - 50-23 ASTM A193 GRB8 5/8-11 X 2 3/4 BOLT Fort Calhoun FC-C4B ASTM A194 GR2H 3/4 HH NUT FC-C9B ASTM A194 GR2H 5/8 HH NUT Ginna' RGE-36 ASTM A194 GR2H NUT Harris HNP-8 ASME SA193 GRB8M BOLT HNP-25 ASME SA193 GRB8 BOLT Limerick LGSI-4-05 ASTM A193 GRB7 3/4 X 4 1/4 STUD LGS 1-0-05 ASTM A193 GRB7 1 X 5 STUD LGSI-10-0N ASTM A194 GRBM 5/8 NUT LGS 2-03 ASME SA193 GRB7 1 X 5 STUD LGS 2-03E ASME SA193 GRB7 1 X 5 STUD Maine Yankee MY-S-01 ASME SA193 GRB8M 5/8-11 X 5 STUD MY-S-02 ASME SA193 GRBSM 3/4-10 X 1 3/4 BOLT MY-S-03 ASTil A193 GRBB 5/8-11 X 2 3/4 STUD MY-S-09N ASTM A194 GR8MA 1/2-13 NUT MY-S-01N AST11 A194 GRBMA 5/8-11 NUT Nine Mile Pt. NM-70-7-2 ASTM A193 GRE8 1 X 4 STUD NM-70-10 ASTN A193 GRBEM 1/4 HH CAPSCREW NMP-2-15 ASTM A193 GRB8 1/4 HH CAPSCREW i

ATTACHMENT 2 (CONT.)

SAFETY-RELATED FASTENEPS tlITH SUBSTANTIAL DEVIATIONS WARRANTING FOLLOW-l!P ACTION PLANT NAME SAMPI.E NO. DESCRIPTION North Anna NPF4-AB ASTM A193 GRB7 1/2-13 X S STUu I NPF4-AE ASTM A193 GRB7 5/8-11 X 5 STUD-NPF4-A0 ASTM A193 GRB8M 1/2-20 X 12' STUD NPF4-AP ASTM A193 GRB8M 5/8-11 X 12' STUD Oyster Creek 00-002 ASTM A193 GRB8M 5/16-18 X 2 HH CAPSCREW Palisades PAL-10 ASTM A453 GR660 1/2 X 2 1/4 STUD Peach Bottom PB-10 ASTN A194 GR6 7/9-9 NUT River Bend RBS-12N-X ASTM A194 GR2H 3/4-10 HH NUT RBS-16N-X ASTM A563 GRDH 1 1/4-8 HH NUT Robinson RNP-006 ASME.SA193 GRB8 CAPSCREW Sequoyah TVA-55321 ASTM A.193 GRB8M 1/2-13 X 4 BOLT-Surry DPR-CD ASTM F593 ALLOY GP1 1-8 X 2 HH CAPSCREW DPR-DJ ASTM A193 GRB8M 1-8 X 12' STUD DPR-DN ASTM A193 GRB7 1/2-13 X 4 1/2 HH CAPSCREW Trojan TNP-33 ASTM A193 GRB7 3/4-10 X 7 1/2 STUD Vermont Yankee VY-2 SAE J429 GR1 7/8-9-X 2 3/4 MACHINE BOLT Watts Bar WB-7946 ASME SA193 GRB7 1/2-13 X 2.75 STUD WB-7947 ASME SA194 GR7 1/2-13 NUT WB-8004 ASTM A193 GRB7 3/4-10 X 3 3/4 HH BOLT l

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Issue Date: 05/22/89 A2-2 Attachment 2,2500/27 j

ATTACHMENT 3 ,

l SUMMAPY CF FASTENER TESTING DATA j PLAliT TESTED FAILED  % FAILURES '

SR : N SR : N SR : N 1

Arkansas 20 : 20 0: 0 0: 0 Peaver Valley 69 : 13 2(C): 2 5: 15 Bellefonte 40 : 1 3(C): 0 8: 0 Big Rock Pt. 27 : 17 2(C)2(H): 5 15 : 29 Braidwood 18 : 11 0: 0 0: 0 Browns Ferry 48 : 8 2(C)1(M): 0 6: 0 Eirunswick 29 : 22 1(C): 4 3: 18 Byron 19 : 21 0: 0 0: O Callaway 12 : 7 1(M): 3 8: 43 Calvert Cliffs 19 : 20 1(C)1(M)1(H): 3 16 : 15 Catawba 20 : 20 0: 2 0: 10 Clinton 31 : 9 1(H)2(M): 0 10 : O Comanche Peak 33 : 20 2(M): 5 12 : 25 '

Cock 18 : 33 0: 1 0: '3 Cooper 20 : 20 0: 0 0: O Crystal River 20 : 20 1(M)2(H): 1 15 : 5 Davis-Besse 22 : 29 2(H : 4 9: 14

.Diablo Canyon 67 : 25 1(C)3(M)1 :3 7: 12 Dresden 22 : 20 2(C)1 :0 14 : 0 Duane Arnold 24 : 20 1 :3 4: 15 Farley 24 : 20 4(C)1 :0 17 : 0 Fermi 20 : 20 0: 2 0: 10 Fitzpatrick 24 : 24 0: 3 0: 12 Fort Calhoun 20 : 20 1(C)1(H): 4 10 : 20 Ft. St. Vrain 20 : 20 0: 1 0: 5 Ginna 40 : 40 3(C)2(M)1(H): 4 15 : 10 i Grand Gulf 44 : 40 1(M): 2 2: 5 Haddam Neck 20 : 20 0: 0 0: 0 {

Harris 27 : 11 2(H): 0 7: 0 Hatch 20 : 20 0: 0 0: 0 Hope Creek (See Salem) i Indian Point 2 43 : 18 2(M): 2 5: 11 Indian Point 3 20 : 19 0: 2 0: 11 l

Kewaunee 20 : 20 1(M : 1 5: 5 i LaSalle 13 : 22 1(C)3(H : 2 31 : 9 i Limerick 42 : 46 6(M)1(H)1(C : 4 19 : 9 Maine Yankee 20 : 20 3(C)3(H : 1 30 : 5 McGuire 20 : 21 0: 6 0: 29 Millstone 20 : 20 1(C),(M). 1 10 : 5 Monticello 18 : 22 1(C)1(M): 3 11 : 14 Nine Mile Pt. 40 : 40 6(M)2(C)1(H):12 23 : 28 l

North Anna 41 : --

7(M):-- 17 : --

Oconee 20 : 20 0: 0 0: 0 Oyster Creek 20 : 21 1(H): 4 5: 19 1 l Palisades 42 : 48 1(H): 2 2: 4

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ATTACHMENT 3 (CONT.)

PLANT TESTED FAILED  % FAILURES SR : N SR : N SR  : N Palo Verde 22 : 23 1(H): 1 4 : 4 Peach Bottom 22 : 21 1(H)1(M): 5 9  : 24 Perry 20 : 20 2(H): 3 10  : 15 Pilgrin 35 : 29 3(H): 6 8 : 21 Poir.t Peach 20 : 20 2(C)1(M): 1 IS : 5  ;

Prairie Island 18 : 18 0: 4 0  : 22 Quad Cities 20 : 20 2(C): 1 10 : 5 Rancho Seco 30 : 15 1(M): 3 3  : 20 River Bend 42 : 3 2(C)3(~M)2(H): 0 17 : 0 Robinson 35 : 19 1(M)1(H)1(C): 0 6 : O Salem 20 : 20 2(H : 4 10  : 20 San Onofre 41 : 36 1(H : 3 2 : 8 Seabrook 20 : 20 1(H : 0 5 : O Sequoyah 20 : 20 1(C)2(H : 2 15  : 10 Shoreham 20 : 20 2(M): 5 10  : 25 South Texas 40 : 12 3(C)1(M): 0 10 : 0 St. Lucie 21 : 36 1(H)1(C)1(M): 4 14  : 11 Summer 18 : 13 2(C 1(H : 4 17 : 31 Surry 51 : --

4(M)2(C 1(H :-- 14  : --

Susquehanna 20 : 20 1(M1(C: 1 10 : 5 Three Mile Island 28 : 16 1(M : 1 4 : 6 Trojan ' 20 : 20 5  : 30 Turkey Point 22 : 20 1(M)f:1(M:

0 6 9  : 0 Vermont Yankee 21 : 20 8(C)2(M): 3 48  : 15 Vogtle 69 : 18 1(M): 1 1  : 6 Waterford 100 : 40 5(C)1(H): 1 6  : 3 Watts Bar 71 : 1 9(C)2(M): 0 15 : 0 Wolf Creek .20 : M 0: 0 0 : 0 WPPSS :20 : 20 0: 1 0 : 5 Yankee Rowe ' 30 : 10 1(C): 1 3 : 10 Zion 22 : 36 0: 0 0 : 0 TOTAL -- 2238 : 1469 180:153 8 : 10 SP - Safety-related N - Nonsafety-related SR Failures --

l Hardness (H) - 45 (25%)

l Mechanical (M) - 63 (355)

Chemistry (C) - 72 (405)

NOTE: Many fasteners failed specifications in more that one category.

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These fasteners are counted only once in this table in the category of primary failure. -

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ATTACHMENT 4 EONSAFETY RELATED FASTEMERS WITH SUBSTANTIAL DEVIATIONS WARRANTING FOLLOW-UP ACTION PLANT NAME _ SAMPLE NO. DESCRIPTION Beaver Valley BVI-26B ASTM A194 GP2H I NUT Callaway' CAT 660368A ASTM A194.GR2H 5/16-18 NUT CA1660368B ASTM A194 GR2H 5/16-18 NUT-CAT 660368C' ASTM A194 GR2H 5/16-18 NUT Cook 31-772250 ASTM A193 GRB7 1/2 X ? STUD Davis-Besse DB-28 SAE J995C 1 1/4 NUT Fermi DENB-9 SAE J429 GR2 3/B-24 X 2 BOLT Fitzpatrick JAF-14 ASTM A307 GRB 5/S X 7 1/2 BOLT JAF-17 ASTM A193 GRB8 3/4 X 3 STUD Ginna RGE-5? ASTM A307 GRA 3/4-10 X 2 BCLT RGE-53 ASTM A325 TP1 1/2 X 1 3/4 BOLT RGE-60 ASTM A193 GRB8 1/2 X 2 3/4 STUD

- Grand Gulf GG2-A1A ASTM A194 GR2H 3/4 HH NUT GG2-A1B ASTM A194 GR2H 3/4 HH NUT Indian Pt. 3 3IP23 ASTM A194 GR2H 3/4 NUT 31P27 ASTM A194 GR2H 3/4 NUT taSalle L-17-NC ASTM A194 GR2H 3/8-16 NUT Limerick LGS 2-27 ASTM A194 GR2H 1/2 NUT NcGuire MNS32 SAE J995 GRC 3/4-10 NUT MNS33 ASTM A194 GR8M 1/2-13 NUT Nine Mile Pt. NM-63-2 ASTM A193 GRB6 1/2 SOCKET HD CAPSCREW NMP-2-20 ASTM A193 GRB7 1/2 HH SCREW NMP-2-25 ASTM A307 GRB 1 3/4 HH SCREW NMP-2-31-1 ASTM A194 GR6 5/8 HH NUT NMP-2-31-2 ASTM A194 GR6 5/8 HH NUT NMP-2-34 ASTM A193 GRB6 3/4 X 5 STUD Oyster Creek 0C-021 ASTM A193 GRBC 1/2-13 X 2 1/2 HH CAPSCRDI OC-023 ASTM A193 GRB8 1/2-13 X 1 1/4 HH CAPSCREW C0-038 ASTM A194 GR2H 5/8-11 NUT Peach Bottom PB-26 ASTM A193 GRB16 5/8-11 STUD PB-38 ASTM A193 GRB8 9/16-12 X 3 3/4 SCREW PB-39 ASTM A193 GRB8 9/16-12 X 5 SCREW PB-40 ASTM A194 GR2 5/8-11 NUT PB-41 ASTM A194 GR2 5/8-11 NUT ann--~---n o anaa nae - - - - - _ - - - - -

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ATTACHMENT 4 (CONT.)  ;

i:0NSAFETY RELATED FASTENERS WITH SUBSTANTIAL CEVIATIONS_

WARRAflTING FOLLOW-UP ACTION PLANT NAME SAMPLE NO. DESCRIPT:0N-Point Eeach PB-F2 ASTM A193 GRB7 7/16-14 X '4 3/4 HHH BOLT-Prairie Island PIB3 SAE J429 GR5 1 1/2-6 X 6 1/2 BOLT Quad Cities QN-4-CS ASTM A193 GRB7 1/2-13 X 1 1/2 CAPSCREW Rancho Seco RS-1-NQ ASTM A193 GRB7 5/8 X 2 3/4 HH BOLT RS-278-N0 ASTM A194 GR8 1/2-13 NUT Salem SA-12N ASTM A194 GR2H 7/8-9 NUT SA-13N ASTM A194 GR2H 1-8 NUT.

SA-14N ASTM A194 GR2H 1-8 NUT SA-198 ASTM A193 GRB8 3/8-18 X 3/4 BOLT

. Shoreham SNPS 3 ASME SA193 GRB7 1 X E 3/4 STUD St. Lucie 31-24600-1 ASTM A276 (TP316) ' 1/2-13 X 3 HH CAPSCREW Sumer VCS-T ASTN A574 3/4 X 3 SOCKET HEAD CAPSCREW Trojan 'TNP-7R ASTM A194 GR8M 3/4 NUT TNP-21 ASME SA193 GRB16 7/8-9 X 5 STUD TNP-24 ASTM A193 GRB8M 5/16-18 X 1 1/2 BOLT TNP-25 ASTM A193 GRB8M 1/2-20 X 4 BOLT Vermont Yankee VY-27 ASTM A193 GRB8M 1/2-13 X 2 BOLT

VY-29 SAE J429 GR5 3/8-24 X 1 1/4 BOLT Vogtle VEGP-29 ASTM A193 GRB16 5/8-11 X 2 1/2 STUD WPPSS WN2-B2D ASTM A193 GRB8 7/8 X 6 STUD ,

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Attachment 5 l

SUBJECT:

' Evaluation of Licensee's Response to the Testing of Safety l Related and Nonsafety-Related Fasteners TYPE: TI is proposed in order to guide Regions in assessing the licensee's response to NRC Bulletin 87-02.

j RESPONSIBLE OFFICE: NRR/DRIS/RVIB l

' Technical contacts: Fdward Baker )'

Greg Cwalina ESTIMATE SITE INSPECTION RESOURCES REQUIRED:

TYPE H0_URS P.esidence/ Regional Office 1 - 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> / plant Inspections needed at plants identified in Attachment 1.

SCHEDULE FOR ISSUANCE: May 1, 1989 CURRENT INSPECTION DOCUtiENTS THAT MAY BE AFFECTED:

None.

1 1

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4 to U

t Teclaral Resistae / Vol. 54. No. 42 / M'o'nday, March s.1980 / PNM Rules 9229 (3)ne Finance Office will NUCLEAR REGULATORY administratively change the interest ra te COMMISSION procurement _receiptinspection and on a borrower's account in accordance testing, construction and operation of with notification from the servicing 10 CFR Part 50 nuclear power plant structures, systems officialThe installment schedule set and components. The entaria are forth in each borrower's debt instrument Acceptance of Products Purchased for general y structured to confirm the will not change. The original pnneipal Use in Nuclear Power Plant Structures, quahty of products designed, purchased, schedule for principal-plus-interest Systems and Capomnts inspected, tested and installed for use in accounts where principal only is actascir Nuclear Regulatory . nuclear power plant structures, systems stipulated will continue to be used for Commissfor and components. The entena apply to payment calculation by the Finance all activities conducted during the actioet Advance notice of proposed design. construction and operating Office. Amortized accounts will adhere rulemaking.

to the original payment schedule and Faases of nuclear power plants that amount. The last scheduled principal affect the safety-related functions of sussasany: The Nuclear Regulatory , structures, systems and comporents.

installment will be reduced by the Commission (Commission)is proposing amount of the balance previously to deselop regulations requirms Procedures and actions by licensees and generated by the reversal and enhanced acceptance procedures their representatives conforming to reapplication of paymenta. including, but not limited to, receipt these criteria are expected to detect inspection and testing of products substandard and poor quality products (4) When FmHA has processed a but may not necessarily detect change of interest rate for an amortized purchased for use in nuclear power plant structures, systems and counterfeit or fraudulerfly marketed loan and a reduction in instaHment - components. This Advance Notice of products. Recent cases involving amounts is needed to provide for a Proposed Rulemaking (ANFR)is apparently substandard. counterfeit and sound operation. the borrower may mtended to solicit comments on the fraudulently marketed products for request teamortization in accordance need for additional re atory nuclree power plant structures. systems with 51951.207(g)of this subpart. requirements and to o tain an improved and components have prompted the (5) The borrower will be notified in understanding of alternatives to Commission to reconsider the adequaev writing of the new interest rate as 8"Iatory requirements that could of current regulations for detecting changed. pr vide assurance that structures. substandard, counterfeit and systems and components procund for fraudulently marketed products and for i 1951.221 Servictng of ram 0F) use tm Powe p nt l assuring that such roducts are not used hns, ,, p,Qrf t to in nuclear power p ant structures, Borrowers with NPloans are not

    • systems and components.

eligible for any program benefits. part: The comment period expires p. ly Criteria Hl. IV, VIL VIII. and XV of including appeal rights. However. FmHA l',I may use eny servicing tool under this j * ' Appendix B to 10 CFR Part 50 provide i$**y" der d ii]pr cal the criteria for the control of purchased subpart necessary to protect the to do so. but assurance of consideradon structures. systems and components for Government's security interest, cannot be given to comrnents received 8r P wer plants. Hhany.

including reamortization or after this data. heencees and their representatives have rescheduling.The refinr.ncing aoonessEs:Mdl comments to: The purthased products with certifications requirements of Subpart F of this part Secretary of the Commission. U.S. attesting to the quality of the products 1951 do not apply to NP loat4. Debt Nuclear Regulatory Comrmasion. and have depended to varying degrees settlement actions relating te NPloans Washington. DC 20555. Attention: on the certifications as one insis for Docketing and Service Branch. accepting the products. However. recent must be handled under the F detal discoveries of substandard, counterfeit Claims Collection Act. propo 'als will be Deliver comments to: 11555 Rockville Pike. Rockville, Maryland, between M0 and fraudulently mr.rketed products submitted to the National Oibce for fumished to nuclesr power plants by review and approval. Any excention U a.m. and 4:15 p.m. Federal workdays.

Examine copies of comments received contractors and subcontractors the servicing requirements of NPloos at: The NRC Public Document Room, demonstrate tbst current product under this subpart must have prior Gelman Building. 2120 L Street NW., acceptance practices particularly those cont.trrence of the National Office. Washington, DC- based heavily on certifications and j 1951.222,1951.249 [Reservedl stated catalog specifications. have not FOR FURTHER INFORs4AT10N COMTACT:

Max J. Clausen. OfDee of Nuclear been suf'icient in all cases. Additional i 1951.250 OMB contro4 number. details of apparently substandard Reactor Rerdation. U.S. Nuclear Reguhtory Commission. Washington. counterfeit, and fraudulently unerketed Collection of information products are contained in NRC requirements contained in this subpart DC 20555. Telephone (301) 492-0900.

Compliance Bulletin No. 87-02 and have been approved by the Office of suPPLtssENTARmFOResATsOsc Supplements 1 and L NRC Bulletin No.

Management and Budget and have been Background BM5 and Supp!ements 1 and 2. NRC assigned OMB Control Number 0575- Bulletin No. 88-10, NRC Information 0006. Appendix B to 10 CFR Part 50 of the Commission's regulations adopted in Notice No. 88-19. NRC Infonna tion

) Dated: January 27.1989. Notice No. 68-35. NRC Information 1970 (35 FR 10498) establishes the l g 3, ,' quality assurance criteria for safety. Notice No. 884B and Supplement 1. I Acting Admim. stator. Formers Home related structures. systems and NRC luformation Notice No. 8848. and Admmstmoon. components for nucleat power planta. NRC information Notice No. 88-07.8 The purpose of the quality assurance (FR Doc. 89-6081 Filed 3-H9:8:45 am] cnteria in Appendix B la to provide , Thew dommems m eveil.ble for en pcenon et aweso code ses e7-48 ih, Comnussion a Pubhc Document Room. Gelnan requirements for the design.

Buns mD 1. Ween. r4W., %shmgton. DC.

l w . _ - - _ _ - _ - _ _ _ - -

ENCLOSURE 3

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9230 Federal Register / Vol. 54. No. 42 / Monday. March 6.19ts9 / Proposed Rules I

t

, in many cases, as in part discussed in The Commission is concerned about Metallic Products. Nonmetalhc Products.

l the referenced bulletins and information the quality of commercial grade and Components.

I notices, product acceptance practices products that are used throughout the la Cennal j have failed to detect such substandard. nuclear plant. Including applications in counterfeit or fraudulently marked the " balance of plant" structures, sytems 1.1.1a in view of the problems that g

products. nerefore, the Commission is and componenis.This concern stems have been detected with substandard.

considering the need for additional from a recognition that stmetures. counterfeit. or fraudulently marketed fi regulations or other methods to provide sytems and components utihzing products, do the Commission's current

additional assurance that products substandard products may not function regulations provide sdequate criteria for purchased for use in nuclear power as designed and may challenge safety- ensuring the acceptability of purchased 5 plant structares, systems and related systems unnecessarily or products?

crmponents satisfy requirements and complicate the response to off-normal 1.1.1b if the current regulations are specifications that are imposed to events.Commenters are requested to considered to provide adequate criteria.

provide confidence that these items will consider the issues and questions of this how should they be applied to ensure perform as required to protect the public ANPR as they may relate to the need or . that substandard, counterfeit, and health and safety, desirability for either more prescriptive fraudulently marketed products are regulations or, alternatively, a detected and pecluded from use in De Commissions's regulations per ormance-bastd requirement. ruclear power plants?

provide two alternative approaches to Comments are also requested on the assure that structures, systems and 1.1.1c if the current regulations do desirability of any such requirement for not provide adequate criteria, should the components satisfy requirements for safety related applications, as well as Commission establish specific a:tety-related applications. A licensee I r applications throughout the plant. requirements or performance. based mty procure products to the A broad spectrum ofissues needs to requirements to ensure that products requirements of the applicable code or be considered befors the Cocunission

' purchased for use in nuclear power st ndard for the safety.related structure, decides on the scope and content of any pirnt structures. systems and system or component. Alternatively, the proposed new regulatory requirements components satisfy the operational licensee may purchase a commercial addressing the concerns raised by the requirements necessary to protect public grade product and then. using the expenence oflicenues placing health safety?

appropriate procedures and satisfying essentially mo te rehance on 1.1.2a What traceability the Commission's requirements, certif cates, such as Certificates of requirements should be imposed for all dedicate the commercial grade product Cornpliance. and the evidence that some products to be used in safety-related for the safety-related application.The

  • oru tures, systems and component 27 experiences that have been discussed in **[' *I'***"k"8 g' 5 55'd 1.1.2b Should material traceabibry the bulletins and information notices pmviously referenced . apply to products

$[the [erencedbulleti : and information notices'The foliowing

  • " 'Y* # 8' #

that were obtained using both of these questions are posed to raise the issues 9,$hactm and pmcessm W 8ppmaches. . that the Commission has identified and are not to be considered complete nor 1.1.2c Should all critical .

The Commission has concluded that daracteristics. for example, materials.

significant engineering involvement is are they intended to bound the scope of .

operations, functions, etc., be traceable?

required during the procurement process public comment on this ANPR.ne 1.1.2d Should there be any for products used in nuclear power questions are structured in two exceptions to the traceability plants and during any testing of these categories:(1) Products Procured for Use requnements?

products. It is the Commission's view in Safety.Related Stnicture. System and that in the past, inadequate engineering Component Applications, and (2) 1.1.2e What should the identification Dedication of Commercial Crade requirements be for traceability, for involveme'at has been a common weakness in licensees' procurement Products for Use in Safety.Related example, uniquely marking each part programs, particularly when commercial ~ Structure, System and Component whenever possible. bagging. records, grade procurement were involved. It is Applications. etc1 the Commission's position that Public comments are invited on each 1.1.3 Should product acceptances be involvement of a licens*e's engineering of these questions.no comment restricted to inspections and tests or staff in the procurement process should ' resolution process will be improved if should product acceptances include, on include (1) selection of products to be each comment is idemified to the a sample basis. destructive inspections used in the plant. (2) determination of question to which it responds. _ and tests to verify chemiral and Commenters msy submit,in addition to physical characteristics? -

the criticalcharacteristics of the selected products that are to be venfied - the original paper copy, a copy of th 1.1.4 What types ofinspections and .

during product acceptance. (3) letter in an electronic format on IBM PC. tests (appropriate for the various types determination of specific testing DOS compatible 3.5 or 5.25 inch double of products) should be required 7 requirements applicable to the selected sided double density (DS/DD) diskettes. 1.1.5 Should licensees, contractors products.and(4) evaluation of test Data files should be provided in ASCII and subcontractors be encouraged to results.This involvement should be code or,if formatted text is required. perform joint testing?

spplicable to products initially procured data files should be provided in IBM 1.1.6 If destructive inspections and es eafety.related as well as commercial Revisable-Form Text Document Content tests are determined necessary, what I grade pnviucts procured for dedication Architecture (RFT/DCA) format. should be the sampling basis (per end upgrading for use in safety-related 1. Products Procured for Use in Safety- vendor, per purchase order, per applications. 'Ite extent of this Related Structure. Syrtem and shipment, per lot, per container, etc.)?

engineering involvement will be highly Component Applications. 1.1.7 Should semple plan testing be

. dependent on the asture and use of the The questions in this section are permitted for testing or should such products involved. categorized in four subsections: General, testina be on a 100 percent basis?

l 1 - -_- __ a

Federal Register / Vol. 54.g42 / Monday. March 6,1980 / Proposed Rules 9231 1.1.8 What sort of statistical 3.1.20b If a list of approved vendors sampling during product inspection is is established, how should vendors be 1.1.32 ' To what extent should items adequate to provide confidence that the 1.1.ta through 1.1.31 be required for selectedt other than safety-related componentef product has the requisite assurance of 1.1.20c If a list of approved vendors quahty? 1.2 Metaille Products (e.g fasteners, Is established, who thould be 1.1.9 What criteris should be used piping. pipe fittings, weld rod. castings, responsible for maimaining this list? forgings, bar stock, plate material, for aDowing sample plan testing durin8 product acceptance? 1.120d Shouldlicensees be stampings, wi e, cable, etc.J.

restricted to making procurement from 111a Should chemical analyses of 1.1.10 Should the shelf life of this list of approved vendorst appropriate tpes of structures, systems the products be required as part of 1.1.21 Should the use of a certi'icate, product acceptance:7 and componsats be inspected and such as a Certificate of Conformance,in 1.2.1b Should these analyses of the verified as acceptable during product acceptances the procurement process be prohibited Pr ducts be performed by destnictive or or,if allowed. be restricted to issue by oy nondestructive means?

1.1.11 To what extent will an the original equipment manufacturer for effective vendor audit program and 112a Should tests of mechanical mainterence of a qualified vendor list items that have remained under his properties (e.g., hardness. tensile direct contro!? strength, impact, etc.) of the products be reduce the likelihood products bems used m, of questionable nuclear power 1.1.22 Should the furnishing of the required as part of product acceptances?

plantsY original manufacturer's certificate, such 1.2.2b Should tests of mechanical es a Certified Materist Test Report be Properties of the products be performed 1.1.12 . What are the essential made mandatory for procurement of elements, for example, team ty destructive or by nondestructive materials from intermediate vendoray meanaf composition, depth of audits, and j approach, that must be included in an 1.1.23 Should the transcribing of an 103 When destructive tests are effective vendor audit program? original manufacture's test date by required, are test coupons (when 1.1.13 What reinspection or reaudit intermediate vendors onto the vendor's applicable) en acceptable source of test frequency is appropnate to maintain certification, for example. Certified - materials for the tests of chemical and Material Test Report, be forbiddent mechanical properties or should confidence in those vendors on a qualified vendor listi 1.1.24 To what extent should material samples be removed from licensees or their representatives be actual products?

1.1.14 How do licensees ensure that l Code Certificate holders and "N stamp required to inspect the implementation 1.3 NonmeteHic Products (e/g.,

vendors are current? Ic ntractor product acceptance lubricants, tape, ela stomers, seals.

programs?

1.1.15 Is there an auditable method to paints, filters, etc.) l demonstrate that licensees actually purchased the product from a qualified tosu t imple ann o'f P rt 1.3.t a Should chemiesl analyses be 21 Wpb ad wh? required fo lebricants, tape, elastomers.

vendor, for example, the holder of an 1.1.20 in addition to the - etc., during product acceptances?

ASME Code stamp holder certification?

requimments of to CFR Part 21. should 1.3.1b Should these analyses be 1.1.16a Should negatise inspection, ,

heensees be required to notify performed by destructive or by I testing and audit results.be shared with manufactur 7s, suppliers and vendors of nondestructive means?

other parties?

1.1.18b ls a Federal requirement ce se ide ti e p b w th 1.3.2 Should physical property tests necessary to pesmit this sharing of '

j E d (e g., viscosity for lubricants, hardness products or prryams? for elastomus. efficiency fur filters, ete-)

information?

1.1.27 Should licensee participation be required during product acceptances?

1.1.16c Should procure nent contracts be required to include a in a national data system for reporting 1.4 Co.nponents (e g., pumps, valves provision for public release of the equipment / component faflures by circuit breakers. controllers and results of audits of the vendorf manufacturer and appdcation be electronic parts /assemblics and anelt 1.1.16d Are there restramt of tradr required? replacement parts) antitrust concerns or liabilities 1.1.28 Is there specific data that 1.4.1 Should components be associated with these actionsf should be included in a national data subjected to functional tests during 1.1.17 Should licensees, contractors system that would significantly enhance product acceptances and subcontractors be encouraged to its usefulness in establishing equipment 1.4.2a Should components be make joint procurement and to share perfonnance history?

disassembled. if necessary during inspection / audit results of joint 1.1.29 What are the implications of product acceptance, to venfy procurement to enhance the any new Commission requirements on dimensional characteristics?

effectiveness ofinspections/ audits? the Commission's endorsement of the 1.4.2b If the componentsire not 1.1.18 If joint procurement and American Society of Mechanical disassembled. what methods should be inspections / audits are encouraged, Engineers (ASME) Boiler and Pressure utilized to verify critical characteristics? i should controls be imposed and,if so. Vessel Code in 10 CFR 50.55a? 1.4.3a Should the chemical and what and how should these controls be 1.1.30 What is the best way to I physical properties of component i imposed? coordinate any new requirements with materials be analyzed during product {

1.1.19 What audit and testing the ASME Boiler and Pressure Vessel acceptance inspections?

documentation should be required to Codet 1.4.3b if the chemical and physical '

provide traceabihty and give confidence 1.1.31 Should the new requirements properties of component materials are to to all participants in joint product that relate to areas covered by the be analyzed during product acceptance acceptances? .

ASME Boiler and Pressure Vessel Code inspections, what means should be 1.1.20s should the fiRC establish (e.g., SA meterial specifications) be utilized?

and publish a list of approved vendors handled through the code comraittee 2. Dedication of Commercial Grade i for various products? , system? Products for Use in Safety.Related '

P-- -

s 9232 Federal Register / Vol. 54. No. 42 / Monday. March 8.1989 / Proposed Rules _

Structure. System and component 2.1.9 How should inspections venfy for elastomers. efficiency for filters, etc.)

Applications. all critical characteristics (for example, necessary for upgrading these products?

The questions in this section are chemistry, pnysical properties. 213 May critical charactenstics be categorized in five subsections: General, dimensions spects processes. etc.)? inspected by samples or is 100 percent Metallic Products, Nonmetallic Products, 21.10a If destructive inspections and inspection necessary to verify these tests are determined to be necessary, characteristics?

Components, s.nd Others Questions.

how should samples be selected if 2.4 Components 2.1 General products are heat / lot identified?

2.1.1 Shocid the Commission 2.1.10b licw should samples be 2.41 Must each c*itical catabhsh specific requirements or selected if products cre not heat / lot characteristic be inspected before the performance-based requirements to identified 7 component is acceptable for use in ensure that commercial grade products 11.11 Should sample plan testing be safety-related systems?

being dedicated for use in safety-related permitted for nondestructive testing or 2.4.2 How should the chemical and nuclea power plant structures, systems should such testing be on a 100 percent physical properties of component cnd components satisfy the operational basis? rnaterials be analyzed during upgrade requirements necessary to protect public 2112 What criteria sre appropriate inspections?

health and safety? for allowing sample plan testmg duritt8 2.4.3 If critical characteristics cannat 11.2 Should NRC regulations be upgrade inspections be inspected on each component piece, revised to endorse and incorporate by should it be acceptable to establish 2.2 Metallic Products heat / lot traceability, establish reference, the industry codes, standards-or guidance documents for dedication 211a Are chemical enalyses of the unifonnity oflot by sample inspection programs of commet:ial grade products products appropriate as part of upgrade and thereby accept the lott for use in safe'y-related stmeture, inspections? 2.4.4 a Must components be 100 211b Should these analyses be percent functionally tested or may they system and component applications 2.1.3 a What should the traceability performed by destructive or by be subjected to fun lnal tests on a requirements be for all commercial nondestructive means? ** I b f products being upgraded for use in 212a Are tests of mechanical 2.44b is ted by sample, what is safety-related structurea. systems and properties (e.g., hardness, tensile th bas' f r perfoming only sample components? strength, impact etc.) appropriate as part 213b if upgrading traceability of upgrade inspections? ,,

.. 4.5a Should disassembly of provisions are necessary, what should 2.2.2b Should these tests be components be required to verify entical these provisions includet performed by destructive or by non, charactensdest 2.1.3c Should material traceability destructive meanst 2A.5b May verification of critical through allintermediary cont acts, 2.2.3 [f the produc'is heat / lot characteristics be done on a sampling subcontractors and processors be traceabia, is sLmple inspectioD basis or are 100 percent inspections required? (destructive and nondestnictive) necessary?

2.1.3d ifitem traceability is adequate for confirmation of critical 2.4.5c What is the basis for necessary, should there be any characteristics?

214 If the productis not heat / lot performing only sample inspections?

provisions for upgrading products whose 2.4.5d if components are not traceability cannot be established traceable, is it necessary to either sample or 1m percent test. for exampla, disassembled to venfy dimensions, what 213e Sheuld the upgrading methods can be utilized to vertfy traceability provisions be any different hardness, to estab!!sh uniformity and

  • then destnictively analyze them (for dimensions?

if the products are heat / lot identitled or nott example, chemical analyses. tensile 2.5 Other Questions 213f What should the identification tested. impact tested. etc.) to determme 2.5.la Are there any other agency /

requirements be for traceability, for acreptabilityy .

2.2.5 Should requirements in orgamration standards or programs that example, marking, bagging and records? should be adopted for use in upgradmg 2.1.4 How should products intended addition to those included in industry commercial grade products for use m for use in applications in which products standards (e.g., additional samples, etc.) safety-related systems?

are norma .ly required to meet specific 1 be required 7 standards f>e inspected to verify that all 216 When destructive tests are 211b Should these standards or required, are test coupons (when programs be endorsed by NRC entical characteristics are satisfied? regulations?

215 Should the shelf life of available) an acceptsble source of test materials for chemical and mechanical 2.5.2 Are there other alternatives appropriate types of pmducts be that could provide the necessary inspected and verified as acceptance as properties tests or should material samples be removed from actual assurances?

part of the upgrade inspection process? 213 To what extent should any 216 What types of shelf life controls products?

should be imposed on products that are existing controls or any additional 2.3 Nonmetallic Products controls being contemplated in the being upgraded for use in safety-related 2.3.ta Are chemical analyses ANFR be extended to nonsafety.related structures systems and componentat 2.1.7 Should all upgrade inspections necessary to citablish critical applications in " balance of plant" be restricted to inspections and teots of characterist.r.s for lubricants, tape. structurcs, systems and components?

should they include, on a sample beals. elastomers, etc., proposed for upgrading List of Subjects in 10 CFR Fart 50 destructive inspections and tests to for use in safety-related systems?

l ' verify chemical and physical 211b Should these analyses b9 Antitrust. Classified informathn. hre

  • perfonned by destructive or by non- protection. Incorport tion by refe:ence.

characteristics? Intergovernmental relations. Nuclear

,i '

218 What types ofinspections and destructive means?

21? Are physical property tests power plants and reactors. Penalty.

tests (appropriate for the various types of products) should be requiredt (e.g., viscosity for lubricants, hardness Radiation protection. Reacter siting I

k

I e

Federal Register / Vd. 54. Ns.~42 / Monday March 6.1989 / Proposed Rules 9233 criteria. and Reporting and lander (which are SBA participating recordkeeping requirements. 2. Section 120.104-1 is amended by lendars who have exemplary records in adding a ne.w paragraph (f) to read as The aathority citation for this making guaranteed loans) to keep one follows:

d i. half of the guaranty fee for a CLP or Authority: Sec.181. Pub. l. 834o3. no Sta t. regularly processed loan of $50.000 or i 120.104-1 Guamhy M s. i' less and a inaturity in excess of twelve * * * *

  • 201. Pbb 9 8e a 242 asem ded Enordhs.The proposed amendment of the (f) Retent/On of Cuoronty ree. Except (42 U.S.C. 6641). regulation would implement this for loans made under the Preferred Dated at Rockvtlie. Maryland. this 28th day statutory provision. Lenders Program in Subpart D of this of February. tsas. Public Law 100-590 also refers to the Part, when a Certified Lender or for the Nuclear Regulatory Commission. use of a sirnplified loan form for these Preferred lender makes a loan of Samuel l. Chilk. small loans. SBA periodically reviews $50.000 or less, with a meturity in excess Secretaryofthe commissen Its loan forms and the current version of :welve months, it may retain one. half was revised in the last several years, of the guaranty fee charged to the

[FR Doc. 89-M01 Filed 5-4-a9. 8.45 am)

'"**f******* SBA considers that the information borrower.

requested on the present forms is the Dated: January 26.1989.

minimum necessary in order to make an in rmed decision on the kmes Abdnor.

SMALL BUSINESS ADMINISTRATION Adminisuntor.

creditworthiness of a borrower.

13 CFR Part 120 regardless of the etnount of the loan. p De M 8FM M 8 M Accordingly. SEA is not at this time ""mem sensea Business Loan Policy making any changes to its loan forms to --

accommodate this smallloan proposal.

AGENCY:SmallBusiness Administration. For purposes of the Regulatory DEPARTMENT OF COMMERCE i,cnoN: Notice of proposed rulemakinr. Flexibility Act (5 U.S.C. 605(b)). SBA certifies that this proposed rule will not. Bureau of Export Administration

SUMMARY

Section 102 of the Small if promulgated in final forrr.have a Business Administration significant impact on a substantial 15 CFR Part 787 Reauthorization and Amendment Act of 1988. Pub. L 100-590 (102 Stat. 2989), number of small entities because recent enacted November 3.1988, amends the history andicates to SBA that there will IDocht nom 47 82471 not be made a large number cfloans Small Business Act (15 U.S.C. 636) with $50.000 or less. Volunt** Self-Disci ""

respect to guaranty fees on loans of SBA certifies that this proposed rule AGENCY: Bureau of Export

$50.000 or le,ss by Certified or Preferred does not constitute a major rule for the lenders. This proposed rule would Aininistration. Commerce.

implement such amendment. purposes of Executive Order 12291.

AcnoN: Proposed rule with request for since the change is not likely to result in comments.

DATE: Comments must be received on or an annual effect on the economy of $100 before April 5,1989.

million or more because it is not

SUMMARY

The Bureau of Export ADDRESS: Comments frnpy be mailed to: anticipated that such a large number of Administration proposes to amend the Allan Mandel. Small Business $50.000 loans will be made, in 1986, the Export Administration Regulations to i Administration.1441 L Street NW average SBA loan was $150.000 for 1987 set forth procedures for decling with Washington. DC 20410. it was $160.000. anJ for 1988 it was voluntary self disclosures of violatione FOR FURTHER INFORMAT ON CONTACT: $161.000 of the Export Administration Act, as Allan Mandel. 202-6534,96 The proposed rule if promulgated in amended, and the Export suPPcEMENTARYINFORMAT10N The final form. would not impose additional Administration Regulations. There base '

Small Business Administration (SBA) rt' porting or recordkaeping requirements been inquiries from the pubb,c which f g which would be subject to the suggest that there are uncertainties with p rt?c ati g lend r to chain the SBA Paperwork Reduction Act. 44 U.S.C. respect to the effect that a voluntary guaranty with respect to a percentage of Chapter 3E self. disclosure may have on the a q alified loan. On loans with This pros.osed rule would not have treatment of violations. By publishiPF maturities in excess of twelve ;aonths, federalism implications warranting the the practice of the Bureau of Export

~

the guaranty fee is two percent. Such fee preparation of a Federal Assessmentin Administration with respect to is paid by the lender to SBA. but the accordance with Executive Order 12812. voluntary self. disclosures, this rule will lender may pass that charge on to the List of subjects in 13 CFR Part 120- reduce that uncertainty.

1 I

small business concern borrower. This L an Pregrams/ Business.

Depending on the facts aqd is true whether the Ican being Pursuant to the 3uthority containedin circumstances of each case.the guaranteed by SBA is a regular oan. a section 5(bl(6) of the Small Business Act voluntary self. disclosure of a violation (15 U.S.C. 634(b)(B)) and Section 136 of will ordinarily be a mitigating factor ogt (Cl nder a nder s Pub. L 100-590 (102 Stat. 2989). SBA which the Bureau of Export romised a three-day turnaround review proposes to amend Part 120. Chapter I. Administration wiU consider. along with y SDA). or a loan made under the e 13. Code of Federal Regulations, as other aggravating and mitigating factors.

Preferred Lenders Program (PLp) (under i 11 ws. .

when determining the approp*iate which the loan does not get any PART 120-BUSINESS LOAN POLICY processing review by SBA). Congress posed- l j

wants to encourage lenders to make 1. The authority citation for Part 120 DATE: Comments should be received by smaller loans which are less profitable continues to read as follows: April 5.1989. l j

for lenders. Public Law 100-590 Authoriry: 15 U.S C. 634(b)(61 and 836 (a) ADDRESS: Written comments (six Copies) I authorizes a Certified or Preferred a,nd (b).

should be sent to: William H. Arvin.

j: y yf UNITED STATES

,c i g NUCLEAR REGULATORY COMMISSION

{ gy j WASHINGTON, D C. 20555 )

K% y

          • March 21, 1989

( t l

TO: ALL HOLDERS OF OPERATING LICENSES AND CONSTRUCTION PERMITS FOR HUCLEAR POWER REACTORS

SUBJECT:

ACTIONS TO IMPROVE THE DETECTION OF COUNTERFEIT AND FRAUDULENTLY l MARKETED PRODUCTS (EENERIC LETTER 89-02)

Recent instances of counterfeit and fraudulently marketed vendor products have heightened the NRC's concerns for licensees' capability to' assure the quality of procured products and to reduce the likelihood of the use of counterfeit or fraudulent products in nuclear power plants. During recent NRC inspections of licensees and vendors, the NRC has observed a wide variety of practices and progrhms for procurement, receipt inspection, testing and dedication of equip-ment and material for safety-related applications. The purpose of this generic letter is to share with all licensees some of the elements of programs that appear to be effective in providing the capability to detect counterfeit or fraudulently marketed products and in assuring the quality of vendor products.

The staff is aware of and encourages the industry working group efforts to develop guidance in these areas.

Three characteristics of effective procurement and dedication programs have been identified during these NRC inspections. These charactr tics are (1) the involvement of engineering staff in the procurement and proi , acceptance pro-cess (2) effective source inspection, receipt inspection, and testing programs, and(3) thorough,engineeringbased,programsforreview, testing,anddedica-tion of commercial-grade products for suitability for use in safety-related applications. NRC has found that programs that embodied the above three ele-ments were generally effective in providing enhanced capability to detect counterfeit or fraudulently marketed products and in assuring the quality of procured products, both in safety-related and other plant systems.

Licensees may want to consider the applicability of these characteristics to their programs to reduce the likelihood of the introduction of counterfeit or fraudulent products into their plants and to assure the quality of procured vendor products.

It should be noted that the NRC staff conditionally endorses the guidelines contained in EPRI NP-5652, " Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications (NCIG-07)," that was issued by EPRI in June 1988 for evaluating commercial-grade products for suitability for use in safety-related applications.

Backaround:

Numerous instances have been identified by the NRC during the past 2 years in which the nuclear industry received, accepted, and installed items of hardware ENCLOSURE 4

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Multiple Addressees that were not of the quality purported by the manufacturer or supplier due to apparent misrepresentation. Significant deficiencies have also been identified in the programs related for dedicating commercial-grade products for use in safety-applications.

The use in nuclear facilities of products which are counterfeit or fraudulently marketed ds expected.

increases the likelihood that some plant equipment may not perform regarding this(See the enclosed list of NRC Information Notices and Bulletins matter.)

Discussion:

Procurement quality assurance (QA) controls for products to be used in safety-related applicat ons are established in Appendix B to 10 CFR Part 50, and in Regulatory Guides 1.28, 1.33, and 1.123.

It is recognized that Appendix B pro-vides criteria for QA programs and does not specifically address fraudulent activities; however, an efft.ctively implemented licensee QA program would increase the li blihood of detecting fraudulently marketed vendor products.

Although a properly implemented QA program may more readily detect substandard products than will the commercial-grade component upgrade process, a licensee's commercial-grade dedication process, as described in paragraph C., will greicly enhance the effectiveness of current upgrade practices. The actions described in paragraphs A. and B. have also proved useful in detecting substandard, counterfeit or fraudulently marketed products intended for use in systems needed for the safe operation of the facility.

A. Engineering Involvement in the Procurement Process Appropriate engineering involvement is warranted during the procurement and product acceptance processes, including testing, for products used in nuclear power plants. Inadequate engineering involvement has been a common weakness in licensees' procurement programs, particularly when com-mercial-grade procurement were involved. Involvement of a licensee's engineering staff in an effective procurement process would normally include (1) development of specifications to be used for the procurement of products to be used in the plant, (2) determination of the critical characteristics of the selected products that are to be verified during product acceptance, (3) determination of specific testing requirements applicable to the selected products, and (4) evaluation of test results.

The extent of necessary engineering involvement is dependent on the nature and use of the products involved.

D. Product Acceptance Programs l

Experience indicates that reliance on part number verification and certi- j fication documentation is insufficient to ensure the quality of procured products. Licensees with effective product acceptance programs have i

1 l included receipt / source inspection and appropriate testing criteria, i effective vendor audits, special tests and inspections and post-installa-tion tests in their programs. These licensees have applied the inspection  !

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V Multiple Addressees and testing criteria to products procured for use in safety-related systems and for all commercial-grade products being evaluated for suitability for use in safety-related systems. The inspection and testing criteria also i have required identification and verification of the products' critical characteristics. In selecting the critical characteristics to be verified, consideration may be given to the safety significance, complexity, and application of the various products. For suppliers with acceptable QA pro- ,

grams, as confirmed by licensee audits, samplicg plans are often utilized to perform the required inspections and tests. In addition to these receipt / source inspections and tests, effective licensee programs normally verify the traceability to the original manufacturers of procured materials, equipment, and components in those cases where original manufacturer's certifications are elements of the safety-related pro-curement or commercial-grade dedication progran.. Effective audits have included consideration of audit approach, depth of audit, and audit team composition and have included appropriate engineering / technical represen-tatives. Comprehensive multi-licensee audit teams have also been found to be effective.

C. Dedica tion Programs It is each licensee's responsibility to provide reasonable assurance that nonconforming products are nut introduced into their plants. Dedicatior.

programs that ensure the adequacy of critical parameters of products used in safety-related applications can also contribute to the identification of counterfeit or fraudulently marketed vendor products.

The NRC staff believes that licensees who use methods similar to those described in EPRI lip-5652 " Guideline for the Utilization of Comercial-Grade Items in Nuclear Safety-Related Applications (NCIG-07)," to verify the critical characteristics of commercial-grade items intended for safety-related applications have the basis for effective dedication programs.

Properly implemented, the ,EPRI guidelines, as modified below, establish methods which satisfy existing requirements of Appendix B to 10 CFR Part 50 as they apply to the dedication process of commercial-grade items.

1. Acceptance Method 2. " Commercial-Grade Survey of Supplier,"

should not be employed as the basis for accepting items from suppliers with undocumented commercial quality control pro-grams or with programs that do not effectively implement their own necessary controls. Likewise, Method 2 should not be employed as the basis for accepting items from distributors unless the survey includes the part manufacturer (s) and the survey confirms adequate controls by both the distributor and the part manufacturer (s).

2. Acceptance Method 4, " Acceptable Supplier / Item Performance Record," should not be employed alone unless:

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' Multiple Addressees. l b a.

L The established historical record is based on industry-wide performance data that is ~directly applicable to the item's critical characteristics and the intended safety-related application; and

b. The manufacturer's measures for the control of design, process, and material changes have been adequately imple-r.iented as verified by audit (multi-licensee team audits are acceptable).

The NRC staff believes that if licensees' procurement programs effectively implement the elements discussed in paragraphs, A., S.,'and C., they will reduce the likelihood of'the introduction of counterfeit or fraudulent pro-ducts into their plants.

Although no response to this letter is required, if you have any questions regarding this matter, please contact the technical contact listed below.

Sincerely, even . V3rga 0 b-Acting Associate rector for Projects 3 Office of Nuclear Reactor Regulation

Enclosures:

1. List of Bulletins and Information Notices
2. List of Recently Issued Generic tetters CONTACT:

E. William Brach, NRR (301)492-0961 1

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Enclosure 1 BULLETINS AND INFORMATION NOTICES CONCERNING NONCONFORMING (

MATERIALS AND EQUIPMENT AND INSTANCES OF INADEQUATE DEDICATION OF EQUIPMENT FOR SAFETY-RELATED APPLICATIONS Bulletin No. Title Date 87-02* Fastener Testing to Detennine Conformance 11/06/87 with Applicable Material Specifications 87-02, Supplement 1* 04/22/88 87-02, Supplement 2* 06/10/88 88-05* Nonconforming Materials Supplied by Piping 05/06/88 s Supplies, Inc., at Folsun, New Jersey, and West Jersey Manufacturing Company at Williamstown, New Jersey 88-05 Supplement 1* 06/15/88 88-05, Supplement 2* 08/03/88 88-10* Nonconforming Molded-Case Circuit Breakers 11/22/88 Information Notice No. 87-66 Inappropriate Application of Consnercial-Grade 12/31/87 q Components 88-19* Questionable Certification of Class 1E 04/26/88 Components 88-35 Inadequate Licensee Performed Vendor Audits 06/03/88 88-46* Licensee Report of Defective Refurbished 07/08/88 Circuit Breakers 88-46 Supplement 1* 07/21/88 88-46, Supplement 2* 12/30/88 88-48* Licensee Report of Defective Refurbished Valves 07/12/88 88-48, Supplenient 1* 08/24/88 88-97 Potentially Substandard Valve Replacement Parts 12/16/88

  • These items reflect instances in which suppliers and manufacturers of safety-related material may have intentionally eluded 0A requirements to misrepresent the quality of their products. In the instances marked by an asterisk, the pro-blem was brought to NRC's attention by either a licensee or a nuclear supplier.

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Enclosure 2 LIST OF RECENTLY ISSUED GENERIC LETTERS Generic Date of letter No. Subject Issuance Issued To f 4

89-01 IMPLEMENTATION OF 1/31/89 ALL LICENSEES HOLDING PROGRAMMATIC CONTROLS OPERATING LICENSES FOR RADIOLOGICAL EFFLUENT AND CONSTRUCTION TECHNICAL SPECIFICATIONS PERMITS FOR NUCLEAI!

IN THE ADMINISTRATIVE POWER REACTOR FACILITIES.

CONTROLS SECTION OF THE TECHNICAL SPECIFICATIONS AND THE RELOCATION OF PROCEDURAL DETAILS OF RETS TO THE OFFSITE DOSE CALCULATION MANUAL OR TO THE PROCESS CONTROL PROGRAM.

88-20 INDIVIDUAL PLANT 11/23/88 ALL LICENSEES HOLDING EXAMINATION FOR SEVERE OPERATING LICENSES ACCIDENT VULNERABILITIES - AND CONSTRUCTION 10 CFR 50.54(f) PERMITS FOR NUCLEAR POWER REACTOR FACILITIES 88-19 USE OF DEADLY FORCE BY 10/28/88 ALL FUEL CYCLE FACILITY LICENSEE GUARDS TO PREVENT LICENSEES WHO POSSESS.

THEFT OF SPECIAL NUCLEAR USE, IMPORT, EXPORT, MATERIAL OR TRANSPORT FORMULA QUANTITIES OF STRATEGIC SPECIAL EUCLEAR MATERIAL 88-18 PLANT RECORD STORAGE ON 10/20/88 ALL LICENSEES OF OPTICAL DISKS OPERATING REACTORS AND HOLDERS OF CONSTRUCTION PERMITS 88-17 LOSS OF DECAY HEAT REMOVAL 10/17/88 ALL HOLDERS OF 10 CFR 50.54(f) OPERATING LICENSES l OR CONSTRUCTION )

PERMITS FOR

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PRESSURIZED WATER I REACTORS 88.16 REMOVAL OF CYCLE-SPECIFIC 10/04/88 ALL POWER REACTOR PARAMETER LIMITS FROM LICENSEES AND TECHNICAL SPECIFICATIONS APPLICANTS 88-15 ELECTRIC POWER SYSTEMS - 09/12/88 ALL POWER REACTOR ]

INADEQUATE CONTROL OVER LICENSEES AND i DESIGN PROCESSES APPLICANTS l

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