Information Notice No. 87-66: Inappropriate Application of Commercial-Grade Components

                                                               IN 87-66 


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

                                December 31, 1987


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 1E 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 providing adequate documentation of their qualifications and 
dedication.  The items selected by the NRC inspectors included two Agastat 
time-delay relays from one Class 1E 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 
1E 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.






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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 1E-qualified by the manufacturer nor was it found to 
have been dedicated by the licensee for Class 1E 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 procuring replacement components.  There are no 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.
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                                                            Page 3 of 3 


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. 




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

Technical Contact:  Joseph J. Petrosino, NRR
                    (301) 492-4316

Attachment:
List of Recently Issued NRC Information Notices