United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 89-70, Supplement 1: Possible Indications of Misrepresented Vendor Products

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF NUCLEAR REACTOR REGULATION
                           WASHINGTON, D.C.  20555

                               April 26, 1990


Information Notice No. 89-70, SUPPLEMENT 1:  POSSIBLE INDICATIONS OF 
                                                 MISREPRESENTED VENDOR 
                                                 PRODUCTS


Addressees:

All holders of operating licenses or construction permits for nuclear power 
reactors.

Purpose:

This information notice is intended to provide supplementary information to 
that provided in Information Notice 89-70 which discussed possible 
indications of misrepresented vendor products.  It is expected that 
recipients will review the information for applicability to their facilities 
and consider actions, as appropriate, to avoid similar problems.  
Suggestions contained in this information notice do not constitute NRC 
requirements; therefore, no specific action or written response is required.

Background:

On October 11, 1989, the NRC issued Information Notice 89-70 which provided 
the industry with some tips for detecting misrepresented vendor products, 
including a list of some common characteristics of misrepresented products.  
The notice was prompted by a concern about the growing number of instances 
of misrepresented vendor products which had been identified by the NRC and 
the nuclear industry.  On several occasions equipment which has been 
procured as new has not conformed to original manufacturer specifications, 
procurement documentation requirements and applicable plant design 
requirements even though it was represented to be in conformance with stated 
specifications.

Description of Circumstances:

Detecting misrepresented products is difficult and most quality assurance 
programs are not designed to easily detect counterfeit or fraudulent 
practices.  The criteria used to confirm the quality of products during 
receipt inspection and testing generally have assumed vendor integrity and 
are not focused on identifying an intent to deceive.  The NRC has continued 
to study the misrepresented products issue and has discovered additional 
information that may be helpful to the industry.  In addition to the list of 
common characteristics of misrepresented vendor products which was included 
in the original information 



9004200525
.

                                                  IN 89-70, Supplement 1 
                                                  April 26, 1990 
                                                  Page 2 of 2 


notice (IN 89-70), an additional list of characteristics that may make 
products vulnerable to misrepresentation, fraudulent practices, and 
counterfeiting is provided in Attachment 1 of this supplement. 

Attachment 2 presents a summary listing of components, products, and 
services that have been previously identified as having been misrepresented 
and notes the information notice or bulletin that discussed the particular 
item in more detail.  

As part of our continuing effort to increase the likelihood of detection of 
misrepresented products in other areas of the plant, the NRC has drawn on 
its experience and has developed a list of components that may be vulnerable 
to misrepresentation.  This list is included as Attachment 3.

This information notice requires no specific action or written response.  If 
you have any questions about the information in this notice, please contact 
one of the technical contacts listed below or the appropriate NRR project 
manager. 




                              Charles E. Rossi, Director
                              Division of Operational Events Assessment
                              Office of Nuclear Reactor Regulation


Technical Contacts:  S. L. Magruder, NRR
                     (301) 492-0985

                     G. C. Cwalina, NRR
                     (301) 492-3221


Attachments:
1.  Characteristics That May Make Products Vulnerable to 
      Misrepresentation, Fraudulent Practices, and Counterfeiting
2.  Components, Products, and Services That Have Been Misrepresented
3.  Components and Products That May Be Vulnerable to Misrepresentation
4.  List of Recently Issued NRC Information Notices
.

                                                       Attachment 1 
                                                       IN 89-70, Supplement 1 
                                                       April 26, 1990 
                                                       Page 1 of 1


            CHARACTERISTICS THAT MAY MAKE PRODUCTS VULNERABLE TO
         MISREPRESENTATION, FRAUDULENT PRACTICES, AND COUNTERFEITING


- High turnover usage rate 

- No easy or practical way to uniquely mark the component itself

- Critical characteristics, including environmental qualification, not 
  easily discernible in external visual inspection or characteristics 
  that are difficult to verify through receipt testing

- May be widely used in noncritical and critical applications

- Use may not result in a used appearance

- Often marketed through a supplier and drop shipped from locations other 
  than that of the original supplier

- Special processes for ASME materials may be subcontracted (heat treating, 
  testing, and inspections)

- Easily copied by secondary market suppliers

- Viable salvage market

- Reduced number of original equipment manufacturers

- Obsolete or hard-to-get components

- Components manufactured by a company that is no longer in business

- Items with documentation from a plant where construction has been 
  suspended, cancelled, or deferred

- Moderate or low cost

- High profit potential (rejected heats of a material are purchased 
  and recertified) 
.

                                                       Attachment 2 
                                                       IN 89-70, Supplement 1 
                                                       April 26, 1990 
                                                       Page 1 of 1


      COMPONENTS, PRODUCTS, AND SERVICES THAT HAVE BEEN MISREPRESENTED


- Replacement Parts

     - Valve (Information Notice (IN) 88-97)
     - Circuit Breaker (IN 88-46, Bulletin (B) 88-10)

- Circuit Breakers

     - Metal Clad (IN 89-45)
     - Molded Case (IN 88-46, B 88-10)

- Circuit Breaker Parts (IN 89-45)

- Fuses (IN 88-19)

- Fasteners (IN 89-22, IN 89-59, B 87-02)

- Steel Products (IN 89-18, IN 89-56)

- Fittings and Flanges (B 88-05)

- Valves (IN 88-48)

- Services - Eddy Current Testing (IN 89-18)
.

                                                       Attachment 3 
                                                       IN 89-70, Supplement 1 
                                                       April 26, 1990 
                                                       Page 1 of 2 


     COMPONENTS AND PRODUCTS THAT MAY BE VULNERABLE TO MISREPRESENTATION


I.   GENERAL ITEMS

     - Spare/replacement kits from vendors other than the original equipment
       manufacturer

     - Elastomers - "O" rings, seals

     - Lubricants

     - Adhesives

     - Electrical connectors  

II.  ELECTRICAL ITEMS

     - Motor control centers

          - Complete units

          - Components

               - Starters
               - Starting coils
               - Contactors
               - Contactor kits
               - Overload relays
               - Starter control relays
               - Overload heaters

     - Protective/control relays

     - DC power supplies/chargers

     - AC inverters

     - Current/potential transformers

     - Exciters/regulators

     - Bus transfers/auto bus transfers

     - Motor generator sets

     - Generators

     - Rewindable motors
.

                                                       Attachment 3 
                                                       IN 89-70, Supplement 1 
                                                       April 26, 1990 
                                                       Page 2 of 2 


     COMPONENTS AND PRODUCTS THAT MAY BE VULNERABLE TO MISREPRESENTATION
                                 (continued)


     - Printed circuit boards

     - Bulk commodity items

          - Fuses
          - Splices
     
     - Vacuum breakers (BWR)

     - Indicators/controllers

     - Panel lights/switches

     - Transmitters/instrument switches

     - Isolation devices

III. MECHANICAL ITEMS

     - Welding materials

          - Rod
          - Wire
          - Flux

     - Small piping products

     - Small structural members (pipe supports)

     - Spent fuel pool cooling pumps and similar pumps

     - Ultimate heat sink supply manual valves and similar valves

IV.  DIESEL GENERATOR ITEMS

     - Diesel speed governors

     - Diesel fuel transfer pumps

     - Diesel injection pumps 

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