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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