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L O C K H E E D M A R T I N 7 t IN EL-95/227

0

September 1995

LMITCO INTERNAL REPORT

Guidelines for Identifying Suspect/ Counterfeit Material

A Program Source and Reference Document

APPROVED FQR EXTERNAL RELEASE

I NEL-95/227

September 1995


A Program Source and Reference Document

DISCLAIMER

This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warrqty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or use- fulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, proctss, or service by trade name, trademark, manufacturer, or otherwise dots not necessarily constitute or imply its endorsement, m o m - mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

DISCLAIMER

Portions of this document may be illegible in electronic image products. Images are produced from the best available original document.


INEL-95/227 September 1995

Rev. 0

Reviewed by

Victor L. Wenczel Suspect/Counterfeit Material Procurement Quality Engineer

Date

Approved by

/Date '

Darrell4% Pat'terson . SuspedCounterfeit Material Subject Matter Contact Technical Lead Quality Engineering Services

iii

CONTENTS

EXECUTIVESUMMARY .................................................. INTRODUCTION . . . .

(DOEBH.0266, ES&H BULLETIN, ISSUE NO . 92-4. DATED AUGUST, 1992) .... Counterfeit Parts ...................................................... Fatalities From Substandard Bolts ......................................... Counterfeit/Substandard High-Strength Bolts ................................. Fastener Quality Act ................................................... Posters and Headmarks ................................................. Indicators-Headmarks .................................................. Current Activities ..................................................... Precautions .......................................................... Dispodition .......................................................... Refurbished Molded-Case Circuit Breakers .................................. Indicators of Refurbished Breakers ........................................ Testing ............................................................. Precautions .......................................................... Disposition ..........................................................

CHAPTER OME: SUSPECT/COUN"ERFEIT MATERIAL INSPECTION ...........................

Definitions ........................................................... Detection Methods for Suspect/Counterfeit Material ........................... Listing of Known Suspect/Counterfeit Items .................................

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2

5

6

1-1

1-3

1-4

1-4

Preventing the Reintroduction of SuspectEounterfeit Materials ................... 1-5

Procurement ......................................................... 1-5

V

... ... -

Installed Inspection .................................................... 1-6

Control and Disposal of Suspect/Counterfeit Materials .......................... 1-7

Disposition .......................................................... 1-7

Reporting Suspect/Counterfeit Materials .................................... 1-8

Source Requirements ................................................... 1-8

Summary of US NRC Compliance Bulletins ................................. 1-10

Summary of US NRC Information Notices .................................. 1-10

US Nuclear Regulatory Commission (IWC) Position Documents ................. 1-11

Commercial Grade Items ............................................... 1-12

Fasteners .......................................................... 1-13

CHAPTER TWO: INDICATIONS FOR IDENTIFYING SUSPECT/COUNTERFEIT MATERIALS ........ 2-1

General ............................................................. 2-3

Documents .......................................................... 2-4

Visual Manufacturing Quality ............................................ 2-5

Specific ............................................................. 2-5

APPENDIX: IDENTIFICATION OF SUSPECI'/COUNERFEIT MATERIAL .................... A-1

Table 1 Suspect Component List ......................................... A-6

Table 2 Suspect Indication List .......................................... A-18

FIGURE

1 . Suspect/counterfeit parts ................................................. 4

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...... ....... ~- .-... . . ) . . , . I .. 2. . . . . . . - I .

EXECUTIVE SUMMARY

These "Guidelines for Identifying SuspectKounterfeit Material" (SM) are intended to assist users of products in identifying: substandard, misrepresented, or fraudulently marked items. The .

guidelines provide information about such topics as: precautions, inspection and testing, dispositioning identified items, installed inspection and reporting suspect/counterfeit materials.

These guidelines apply to users who are developing procurement documents, product acceptance/verification methods, company procedures, work instructions, etc.

The intent of these SM guidelines in relation to the Quality Assurance Program Description (QAPD) and implementing company Management Control Procedures is not to substitute or replace existing requirements, as defined in either the QAPD or company implementing instructions (Management Control Procedures). Instead, the guidelines are intended to provide a consolidated source of information addressing the issue of Suspect/Counterfeit materials. These guidelines provide an extensive suspect component listing (Table One) and suspect indications listing (Table Two) found in the Appendix. Users can quickly check their suspect items against the list of manufacturers products @e., type, I.D. number, and nameplate information) by consulting either of these listings.

The DOE Source Requirements for Suspect/Counterfeit Material (SM) are prescribed by DOE in the "Plan for the Suspect/Counterfeit Products Issue in the Department of Energy (DOE)," dated October 1993.

LMIT Company Level Documents Addressing Suspect/Counterfeit Materials are as follows:

a. Quality Assurance Program Description, Section 3.1.7, "Suspect/Counterfeit Materials"

b. Quality Assurance Program Requirements Document, Section 7.9, "Suspect/Counterfeit Materials"

c. MCP 592 Rev 0, "Acquisition of Goods & Services"

d. MCP 590 Rev 0, "Procurement document Control and Procurement Quality Requirements"

e. Additional company procedures are being developed.

For resolving S/h4 probIems or questions please contact the S / M subject matter contact, Darrell D. Patterson, OV-TAP, 526-2564. '

vii

INTRODUCTION

The purpose of these guidelines are to provide users with information that may help identify items which may be substandard, misrepresented, suspect, or supplied with fraudulent intentions. These guidelines are not all inclusive and users are encouraged to develop additional checklists and to share the information with other users.

These guidelines are primarily targeted at items purchased as new that have not been subjected to testing or conditioning. These guidelines may not always be valid when inspecting items that are rebuilt. However, they can be used for installed inspections or maintenance activities.

The content in this Introduction is taken from: Environmental, Safety & Health Bulletin, Issue No. 92-4, August 1992, DOE Quality Alert, U.S. Department of Energy.

Counterfeit Parts

These guidelines provide a summary of information that has been disseminated by various organizations within the Department of Energy (DOE) to alert the DOE community that some vendors have sold substandard bolts and circuit breakers to its contractors. Such sales can be considered a crime. In certain cases, suppliers of these substandard parts may also be subject to the civil penalty enforcement provisions of the Price Anderson Amendments Act of 1988. DOE contractors have reported by way of example, an excess of 1,000,000 suspect counterfeit bolts and over 700 suspect/counter€eit circuit breakers to the Department.

Fatalities From Substandard Bolts

A Report was issued by the Subcommittee on Oversight and Investigations for the Committee on Energy and Commerce of the U.S. House of Representatives entitled The Threatfiom Substandard Fasteners: Is America Losing its Grip?, dated July 1988, stated the following under the heading "Setum Corporation, Tennessee":

A death has occurred, in parr; because a bolkbroke as an iron worker was tightening it. The iron worker lost his balance and fe@ missing the safety net The bo& manufactured in Mexico or Spain, was substandard.

The Los Angeles Times printed a story under the headline "Counterfeits Now Nuts, Bolts Issue" in January 1989, which included the following:

Several people have died in crashes involving private planes that offscials determined were caused by defective fasteners...the nuts, bolts and screws that hold together an aircrap. The National Tramporfation Safety Board's computer database indicated there were 61 aviation accidents between 1984 and 1987 caused by bad fasteners. How many of those fasteners were counterfeited is just now being investigated.

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And just last summer, three dinerent military planes at Tinker Air Force Base in Okdahoma experienced engine failure as a result of defective bolts that may have been counte feit. ..

The Houston Post ran a story with the headline, "Fatal Navy fire blamed on faulty bolt" on. .... , March 15, 1992, which stated the following:

A Feb. 22 @e aboard a Navy destroyer that killed two'sailon and injured four was caused by a faulty bolt in the ship's engine room. ..the fire broke out aboard the steam-powered vessel after a stainless steel bolt connecfing a high-pressure steam line sheared. ..a closer analysis of the bolkshowed it hadn't been sold to the Navy by any known domestic company, and sources speculate that i3 might have been a foreign-made fastener.

Countetfeit/Substardard High-Strength Bolts

Counterfeit bolts have been found in military and commercial aircraft, surface ships, submarines, nuclear weapon production facilities, bridges, buildings, and the space shuttle. These bolts often do not possess the capabilities of the genuine bolts they counterfeit and can threaten the reliability of industrial and consumer products, National Security, or lives. At Congressional hearings in 1987, the Army testified that they had purchased bolts that bore the headmarks of Grade 8 high-strength bolts but that were actually inferior Grade 8.2 bolts. The international Fasteners Institute 0 reported finding substandard, mismarked, and/or counterfeit, high- strength Grade 8 bolts in the United States commercial marketplace. In 1988, IF'I reported that counterfeit medium- strengeh Grade 5 bolts had also been found.

Foreign bolts dominate the American marketplace due to their price advantage, and the majority of suspect/counterfeit bolts are imported. IdentiEying, testing, and replacing these bolts has proven expensive and difficult, both mechanically and technically. Not finding and replacing these bolts, however, has proven fatal in some instances.

Fastener Quality Act

Congress has passed legislation aimed at curbing future bolt counterfeiting. The Fastener Quality Act was passed.by Congress in November 1990 to impose sanctions upon those who sell untraceable fasteners or bolts. However, the Act has not been implemented. When testing laboratories and regulations are established by the Department of Commerce, the Senior Nuclear Managers Group (SMG) will amend the guidance issued March 12,1992.

DOE contractors have reported suspect/counterfeit bolts in several different ways. Some have weighted bolts and reported them in pounds, and others have counted the bolts and reported the actual numbers. As of June 1992, DOE contractors have reported finding in excess of 1,000,000 suspect/counterfeit bolts.

2

Posters and Headmarks

Figure 1 may be removed and photocopied as needed for use as a poster and handy reference to known suspect fastener headmarks. Bolts with the headmarkings shown have a significant likelihood of being found to be inferior to standards. Generally, the cost of replacement of these

bolts is less than the cost of chemical, hardness, and tensile strength testing. Note also that counterfeit bolts can be delivered with counterfeit certificates4ocumentation alone is insufficient to demonstrate compliance with standards.

The Fastener Quality Act of 1990 will require the registration of the headmarks of manufacturers, and it also will reqyire everyone in the distribution chain to ensure bolt traceability.

Indicators-fieadmarks

There are several consensus organizations that have published standards for the properties of fasteners. One of these is the Society of Automotive Engineers (SAE). The SAE grade or alleged grade of a bolt is indicated by raised or indented radial lines on the bolt’s head, as shown in Figure 1. These markings are called headmarks. DOE is currently concerned with two different grades of fasteners: one has three equally spaced radial lines on the head of a bolt which indicate that it should meet the specifications for a Grade 5 bolt; the other has size equally spaced radial lines which indicate a Grade 8 bolt. Letters or symbols on the head of a bolt indicate the manufacturer.

Figure 1 is a suspect/counterfeit Headmark List that was prepared by the United States Customs Service after extensive testing of many samples of bolts from around the nation. Any bolts anywhere in the DOE community that are currently in stock, in bins, or installed that are on the Customs Headmark List should be considered suspect/counterfeit. The headmarks on this list are those of manufacturers that have often been found to have sold bolts that did not meet the indicated consensus standards. Sufficient testing has been done on the bolts on this list to presume them defective without further testing.

Current Activities

The Senior Nuclear Managers Group took action in December 1990 to disseminate information for substandard material to field activities. Subsequently, the group developed a plan of action with two purposes:

1.

2.

to determine the scope of the problem and to take immediate corrective actions as appropriate,

to provide guidelines for strengthening the procurement process so as to preclude the acceptance of counterfeit parts in the future.

3

S USPECTKO UNTERFEIT PARTS

HEADMARK LIST

ALL GRADE 5 AND GRADE I FASTENERS OF FOREIGN OIllGlN WHICH DO NOT BEAR ANY MANUFACTURERS HEADMARI(S:

Girda 5 0 # GradrI

GRADE 5 FASTENERS WITH THE FOLLOWING MANUFACTURERS' HEADMARKS.

MARK MANUFACIIIIIER MARK MANUFACTURER

J J l n n H n M @ 1(5 Koub Kogvo IJPl

GRADE I F M E N E R S WITH THE FOLLOWING MANUFACNRERF HEADMARK%

MARK MANUFACIURER MARK MANUFACNRER

@ A &AhSMfo IJPl @ KS KDOUbMpyo IJPI

@ R l Tab1 Ltd IJPl

@ H Hinornoto Mml UP1 @ FM hrranar Co 01 Japan IJPl

@ M Mlnarnid~Si . lboIJP1 @ KY Kyori Mlp IJPl

GRADE U FASTENERS WKH THE FOUOWING HEIOMARKS:

MARK MANUFACTURER

GRADE ASZS FASENERS I ~ E N N ~ Dmvm YARGET ONIYI WITH THE KKLOWJNO HEADMARKS:

MARK MANUFACWRER

Kay: CA.clNb. JPJlpvr TW-T.lmh YU-YUpakvh

ANY BOLT ON THIS U S SHOULD BE TAE&TED AS OEF€crmEWTHOuT FURTHER TESTING.

OR, IF YOU SEE ANY 1NDlCATlON 7'HAT A CIRCUIT BREAKER MAY BE USED OR REFURBISHED (SEE BULMIN, NO. DOUEH-0266)

Figure 1. Suspect/counterfeit parts.

Figure 1

4

Consistent with SNMG guidance, each site should

1. continue inspection of inventories and systems for suspect/counterfeit parts,

2.

3.

continue to review and revise procurement and quality assurance procedures so that the problem does not recur, and

continue to detect any new attempts by unscx%pulous vendors to supply substandard parts.

Precautions

The following precautions should be recognized when addressing the issue of suspect/counterfeit parts:

1.

2.

Selective Testing

Some facilities perform selective testing of sample bolts rather than have an independent testing laboratory run all the tests required by consensus standards. In many cases, a new counterfeit bolt has roughly the same physical strength as the graded bolt it mimics, but does not have either the chemical composition or the heat treatment specified by the consensus standards. As a result, it will stretch, exhibit metal fatigue, or corrode under less harsh service than the genuine bolt. Simple tensile strength tests cannot be used to identify substandard high-strength fasteners and should not be solely relied upon in performing acceptance test.

Using Suspect/Counterfeit Grade 5 Bolts in Grade 2 Applications

Some sites use suspect/counterfeit Grade 5 bolts in applications that only call for Grade 2 bolts. Eventually the suspect/counterfeit Grade 5 bolts will be used in an application that requires a genuine Grade 5 bolt and that application may fail. In some cases, cheap imported graded bolts have been purchased in place of ungraded bolts because the small price differential made the extra quality seem to be a bargain. Given the expense of removing suspect bolts from DOE facilities, the practice of using suspect bolts for m y application should be stopped.

3. Keep Bolts in Original Packages

All bolts purchased should be kept in the original packages, not emptied into bins. The packages should have labels or other markings that would permit them to be associated with a particular procurement action and a specific vendor. Approved vendor lists should be checked to assure that fastener vendors on that list have been audited for adequacy of their quality programs recently. *

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Disposition

I consistent with SNMG guidance:

1.

2.

3.

4.

Segregate and retain bolts

Separate all suspect/counterfeit bolts including those found with headmarks that match those on the U.S. Customs Service Headmark List shown in Figure 1. The Office of inspector General and the Office of Nuclear Safety should be notified when suspect/counterfeit bolts are being retained. These should be retained as potential evidence until specifically released by the Office of Inspector General and the Office of Nuclear Safety for Price Anderson Enforcement. Bolts on the Headmark List may only be disposed of when the above organization no longer needs them as evidence.

Report all suspect/counterfeit bolts

Regardless of use or test results, it is imperative that all suspect/counterfeit bolts be reported to ORPS in accordance with DOE 5000.3A, Occurrence Reportiug and Processing of Operations Information, Attachment I, "Categorization of Reportable Occurrences." The reports should include identification of the particular headmark, the number of bolts found with that headmark, and the supplier.

Report to the Office of hpector General

Any cases where there are indications that suppliers knowingly supplied items and services of substandard quality.

J

Witness and document

Record the melt down of all suspect/counterfeit bolts when approval is given for disposal as discussed in No. 1 above.

Refurbished Molded-Case Circuit Breakers

Investigations thus far of electrical components at DOE facilities uncovered over 700 suspect/counterfeit molded-case circuit breakers that were previously used, refurbished and sold to DOE contractors.

The following factors should be recognized regarding suspect or refurbished circuit breakers:

1. The quality and safety of refurbished molded-case circuit breakers is questionable since they are not designed to be taken apart and serviced or refurbished. There are no electrical standards established by Underwriters Laboratory (VL) for the refurbishing of molded-case electrical circuit breakers, nor are there any "authorized" refurbishes of moldedcase circuit breakers. Therefore, "refurbished" molded-case circuit breakers should not be accepted for use in any DOE facility.

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2. -One source of refurbished molded-case circuit breakers is from the demolition of old buildings. Some refurbishes are junk dealers who may change the amperage labels on the circuit breakers to conform to the amperage ordered and then merely clean and shine the breakers.

This situation was brought to DOE's attention by the Nuclear Regulatory Commission (NRC) which, in turn, had been informed of the practice by the company that manufactures circuit breakers. In early 1988, a sales representative identified "refurbished" circuit breakers at Diablo Canyon Nuclear Power Plant. A subsequent investigation confirmed that circuit breakers sold to the power plant as new equipment were actually refurbished. The managers of the two firms that refurbished and sold these breakers have been convicted of fraud and have paid a substantial he.

3.

4.

NRC published information Notice No. 8 8 4 dated July 8,1988, on the investigation hdings and circulated it to all applicable government agencies, including DOE. On July 20, 1988, DOE notified all field offices that refurbished circuit breakers may have been installed in critical systems. Shortly thereafter, DOE established the Suspect Equipment Notification System (SENS), a submodule of ES&H Events and News on the Safety Performance Measurement System (SPMS). SENS has since been replaced by the supplier Evaluation and Suspect Equipment (SESE) submodule which includes Suspect Equipment Reports.

Some of DOE's older sites have circuit breakers in use that are no longer manufactured. According to the Nuclear Management and Resources Council (NUMARC), examples of such breakers are Westinghouse breakers with frames E, EA, F and FA. If a DOE contractor has an electrical box that requires a breaker with one of these frame sizes, that contractor would not have been able to purchase.it from Westinghouse for several years. If the contractor were to order a replacement breaker from an authorized Westinghouse dealer, the dealer could not get a new replacement breaker from the manufacturer. To fill the order, the dealer had to turn to the secondary or refurbished market.

Dealing with an authorized distributor does not preclude ending up with refurbished circuit breakers. Westinghouse has announced that it is considering satisfying this market by manufacturing circuit breakers that will fit in these applications.

The solution, as recommended by NUMARC, is not to focus on the credentials of the distributor but on the traceabilify of the circuit breaker itsel€ A purchaser can be assured of having a new circuit breaker only if the breaker can be traced back to the original manufacturer.

Indicators of Refurbished Breakers

Typically, refurbished circuit breakers sold as new equipment have one or more of the following characteristics:

1. The style of breaker is no longer manufactured.

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2.

3.

4.

5.

6.

7.

8.

9.

10.

The breakers may have come in cheap, generic-type packaging instead of in the manufacturers’ original boxes.

Refurbished circuit breakers are often bulk-packaged in plastic bags, brown paper bags, or cardboard boxes with handwritten labels. New circuit breakers are packed individually in boxes that are labeled with the manufacturer’s name, which is usually in two or more colors, and are often date stamped.

The original manufacturer’s labels and/or the Underwriters Laboratory (UL) or Factory Mutual (FM) labels may have been counterfeited or removed form the breaker. Refurbishing operations have been known to use copying machines to produce poor quality copies of the original manufacturer’s and the certifying body’s labels.

Breakers may be labeled with the refurbisher’s name rather than the label of a known manufacturer.

The manufacturer’s seal (often multicolored) across the two halves of the case of the breaker is broken or missing.

Wire lugs (connectors) show evidence of tampering.

The surface of the circuit breaker may be nicked or scratched yet have a high gloss. Refurbishes often coat breakers with clear plastic to produce a high gloss that gives the casual observer the impression that the breaker is new. The plastic case of new circuit breakers often have a dull appearance.

Some rivets may have been removed, and the case may be held together by wood screws, metal screws, or nuts and bolts.

Contradictory amperage ratings may appear on different parts of the same refurbished breaker. On a new breaker, the amperage rating is stamped into, raised from, or machine- painted on the handle of the circuit breaker. In order to supply a breaker with a hard-to- find rating, refurbishes have been known to file down the surface of the handle to remove the original rating and hand-paint the desired amperage rating.

Uesting

In a news release dated February 6, 1989, the National Electrical Manufacturers Association (NEMA) announced the cancellation of its Publication AB-2-1984 entitled, “Procedures for Field Inspection and Performance Verification of Molded-Case Circuit Breakers used in Commercial and Industrial Applications,” and stated the following:

”These procedures were intended for use with breakem that had been originally tested and calibrated in accordance with N E M Standards Publication AB 1 or Underwriters Laboratories Standard UL 489, and not subsequently opened, cleaned or modijied..Therefore the Standards Publication contained none of the destructive test procedures. ..necessaly to veri8 the product’s ability to withstand such conditions as full

8

I

voltage overload or short circuit. Wthout such tests, even if a rebuilt breaker had passed the tests specified in AB-2, there would be no assurance that it would not fail under overload or short circuit conditions. It is NEMA% position that regardless of the results of electrical testing, refurbished electrical circuit breakem are not reliable and should not be used."

Precautions

Follow these precautions regarding suspect or refurbished circuit breakers.

1. Require that molded-case breakers be new and unaltered. Proof that they are new and unaltered requires the vendor to show traceability back to the original manufacturer.

2. Do not rely completely on dealing with authorized dealers for protection from purchasing refurbished molded-case circuit breakers.

3. Approve formal procedures for inspecting circuit breakers that are received and installed according to the indicators of refurbished breakers listed above.

4. contact the original manufacturer if any indication of misrepresentation is encountered. There are many original manufacturers of molded-case circuit breakers whose products are being refurbished and sold as new. These manufacturers have the most specific information about how to assure that their products have not been refurbished.

Disposition

1. Segregate and retaiu all circuit breakers found with indications that they may be refurbished. These will be retained as potential evidence until specifically released by the Office of Inspector General and the Office of Nuclear Safety for Price Anderson Enforcement. Circuit breakers that may be refurbished may only be disposed of when the above organizations no longer need then as evidence.

2. Report suspect electrical components to ORPS and as appropriate to the Suspect Equipment Reports (SER) on SPMS. The ORPS categorization group should be identified as "Cross-Category items, Potential Concerns of issues." The description of cause section in the ORPS report should included the text "suspect counterfeit parts."

3. Witness and document the destruction of all suspect/counterfeit circuit breakers when approval is given for disposal as discussed in No. 1 above.

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CHAPTER ONE

SUSPECT/COUNTERFEIT MATERIAL INSPECTION

1-1

CHAPTER ONE

SUSPECT/COUNTERFElT MATERIAL INSPECTION

These guidelines provide information on the requirements associated with Suspect/Counterfeit Material (SM), prevention measures that are in place, and identification signs. The guidelines 'provide information on those items/products that have been Counterfeited or that are Suspect Materials.

These guidelines cover the necessary information needed to find, identi@, control, prevent the reintroduction of, report and to dispose of SM.

Each facility/program/project should use a graded approach in their procurements and in the performance of their installed and inventory inspections. Suspect/Counterfeit material knows no boundary by such things as Quality Levels or Safety Factors. Co-mingling of SM is a paramount consideration in any efforts to preclude the reintroduction of SM in maintaining inventories. Suspect/Counterfeit materials have been found from car brake linings to nuclear reactor valves. Priorities should be placed on the highest risk activities or items first, but do not ignore or forget the low risk items or activities later.

Definitions

Counterfeit or Fraudulent

Suspect

Fastener

When materials or items are knowingly misrepresented by the vendor, supplier, distributor or manufacture.

When incomplete information, missing marking or other conditions raise questions as to the validity of an material or item. (requires investigation to establish if counterfeit or fraudulent)

A screw, nut, bolt or stud having internal or extemal threads or a load-indicating washer, containing any quantity of metal and are thoroughly hardened. Any screw, nut, bolt or stud having internal or external threads which bear a grade identification marking required by a standard or specification. A washer to the extent that it is subject to a standard or specification applicable to a screw, nut, bolt or stud. This means an assembly, as designated in a other specification, when it is sold or purchased as a single unit.

1-3

Exclusion Items & Dates: -.

Systems, components, items, materials, and structures installed, modified, or mainkded prior to /

January 1, 1980 and those having maintenance subsequent to January 1, 1980 are excluded, provided maintenance records clearly establish that no potentially suspect/counterfeit systems, - . components, items, materials, and structures were installed. (requires investigation of records to document). Reference E. L. Wilmont, Assistant Manager for Site Engineering and Support, Letter Dated June 21,1991 "DOE-ID Guidance for the Development of a Installed Suspect Material Action Plan")

Screw, nut, bolt or stud having internal or external threads or a load-indicating washer under 1/4"/5mm in diameter and ASTM A307 GRADE A fasteners (must have the A307 A head mark) are excluded. Reference the Fastener Quality Act, Public Law 101-592, ,H. R 3000.

Detection Methods for Suspect/Counterfeit Material

DOE Detection Information:

DOEEH-0266, ES&H Bulletin, Issue No. 92-4, DOE Quality Alert, dated August 1992, APPENDIX "A" - Discusses Counterfeit Parts generically. Specifically focuses on Fasteners (High Strength Bolts) and Molded-Case Circuit Breakers. Provided are: how to recognize, report, and disposition identified counterfeit/suspect fasteners; latest Counterfeit HeadMark List (Figure 1); background on substandard/counterfeit circuit breakers; indicators of refurbished breakers; testing of circuit breakers; precautions; and &positioning. (See Introduction).

Additional Detection Information:

Identification of Suspect/Counterfeit Material, reference APPENDIX This information is derived from several references such as EPRI, General Physics, M&O Contractors, etc.. Subjects addressed are; Product Characteristics, Tel Tale Signs (Visual Manufacturing quality), Identification/Labeling, Mfg. Markings, and Documentation.

..

Listing of Known S us pect/Counte rf eit Items

A listing by component, manufacture, description, supplier and appropriate references was prepared in a Internal Technical Report No. ES&Q-1710-92-69, dated September 24, 1993, reference APPENDIX This report provides the information on the various items which have had a history of being counterfeited. It should be used when purchasing items or performjng installed inspections as a indicator for a need to be cautious and to presume that the item is suspect until proven otherwise.

1-4

Preventing the Reintroduction of Suspect/Counterfeit Materials

There are many methods available and being used as part of the quality program to prevent and detect the existence of SM materials. Awareness training was conducted early on in the program and is now ,considered completed as a formal activity. Continued training is conducted as part of one's job awareness and by the use of procedures. Some of the ongoing activities being employed to prevent and detect SM are listed below.

Procurement

Use of Qualified Suppliers: I

Performance Based (EPRI NP-6630 Guidelines) Joint user groups; SQIG, MME Certificate Holders, NRC License Holders, etc.

Purchase Order/Contracts:

Invoke technical requirements via product specification Products shall be new, unless approved by Engineering Receipt Tnspection/Product verification Quality Clauses address SM material

QA Controls:

ANSI-ASME NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities" ASME FAP-1-1990 for fasteners, "Quality Assurance Program Requirements for Fasteners

Other recognized standards, MIL,-I-45208A, ISO-9000, etc. Manufacturers and Distributors"

Emphasis placed on:

Procurement Specification Vendor Qualification Vendor Auditing Receipt Inspection Technical verification of product quality, not just documentation review QA overview/assessment of implementation

Engineering Involvement in Procurement Process:

Specification development/involvement (EPRI NP-5638 & NCIG-04 for Nuclear environment) Determination of critical characteristics for POProduct verification Determination of specific verification testing requirements and methods (utilize graded approach)

1-5

Verification Testing Performed During:

Standard Receiving Inspection Instruction Receiving Inspection & Testing (end user) Quality Control Receiving Inspect Post Installation Testing Evaluation of verification test results Participation in verification process to assure performance capability of a new item Review any technical changes during procurement process Replacement for modificatiodobsolete equipment Nuclear applications utilize EPRI NP-6406, NCIG-11, EPRI NP-5638

Product Acceptance:

Source inspection and/or vendor audits Receipt inspection and appropriate testing criteria On-site inspection Special test and inspection; and Post-installation test

Dedication Programs for use of Commercial Grade Items (CGI) in safety related applications:

Establish methods similar to those of EPRI NP-5652 Special tests and inspections

Commercial Grade Survey of Supplier/Distributors

Source verification Acceptable supplieditem performance record

Utilize manufacturing direct procurement and shipping (exclude distributors)

Installed Inspection

Safety Systems, Structures, and Components:

Those with adverse affect on environment, safety and health of public Those whose failure adversely affect worker health and safety Fasteners, electrical components, and other identified SM products in inventory

Areas Routinely Accepted by the Public:

Those whose failure do not adversely affect worker health and safety Fasteners, electrical components, and other identified SM products in inventory

Control and Disposal of Suspect/Counterfeit Materials

Control:

When Suspect/Counterfeit items are found they shall be segregated and controlled as nonconforming material in accordance with each facilities respective procedures. These items shall remain under their control until annual disposal activities are initiated.

Disposition

Determine the function of the item with respect to a documented system or user classification, which is based on the following:

1. the safety or non-safety function of the item, and

2. the programmatic impact of the failure of the item.

Review the pertinent Suspect Material reference material to understand the historical concern.

Perform sound engineering evaluation of the suspect item using the following as a minimum:

1.

2.

3.

4.

5.

6.

the environment the item is to function in, such as: vibration, temperature conditions high-ambient-freezing, corrosive elements, radiation, etc;

critical to function design characteristics, such as: those parts, pieces, things, that an item possess in order to perform it's specified function, within specified tolerank, and in specified conditions;

the seismic qualifications of the item;

redundancy of the item with relation to risk;

life cycle of the item, for instance does the item need to function for one year or ten years;

historical information on the item, such as, has the item been performing acceptably for the last "X number'' of months or years, and no other considerations have come into play, or the item is scheduled to be pulled from sexvice in the near future.

Approve and document the evaluation considering the following:

A sound engineering decision weighing all these considerations should be documented by a system, design, or maintenance engineer knowledgeable in the function and application of the item, and receive concurrence from a qualit) and safety engineer.

1-7

Disposal:.

On an annual bases the LMIT Subject Matter Contact will arrange for the pick up and proper disposal of each facilities SM. This is usually scheduled for the month of September and requires that a chain of custody be maintained from the time the SM is picked up until it is disposed of at the smelter facility. (currently NUCOR in Plymouth, Utah).

Reporting Suspect/Counterfeit Materials

It is a requirement of DOE (reference current directive from HQ below) that all counterfeit items be reported as a reportable occurrence in accordance with DOE Orders 2030.4B, Reporting Fraud, Waste, and Abuse to the Office of Inspector General and 50003B, Occurrence Reporting and Processing Systems (ORPS). The "description of cause" section in the ORPS report shall include the text "suspect/counterfeit products". The offices of EH and IG shall be provided copies of these reports. However one must be sure that one has truly a counterfeit item. Many items may be suspect because of no markings, incomplete documentation, rough handling and be a Quality Control problem, but not a counterfeit problem. The reporting agency must determine that they truly have a counterfeited item before thm reuort it on ORPS

Source Requirements

These documents provide the requirements issued to the INEL by the Department of Energy (DOE) as forwarded by DOE-ID for implementation. These documents and supporting government reference documents are listed below in descending chronological order.

Current Directive from HQ:

Plan for the Suspect/Counterfeit Products Issue in the Department of Energy (DOE), dated October, 1993. Transmitted from DOE-ID to INEL Contractors via Alice C. Williams Letter No. AM/OPE-OIM-DST-94-004, dated January 24, 1994. This Plan codifies all previous Direction provided by DOE into one document.

Historical Direction from DOE Headquarters and DOE ID:

k C. Williams, Manager Office of Infrastructure Management, Letter dated January 24,1994 "Plan for the Suspect/Counterfeit Products Issue in the Department of Energy"

E. C. Brolin, Acting Deputy Director Office of Nuclear Energy, Memorandum Dated October 22, 1993 "Plan for the Suspect/Counterfeit Products Issue in the Department of Energy"

E. C. Brolin, Acting Deputy Director Office of Nuclear Energy, Memorandum Dated April 28,1993 "Procurement /Controls to Preclude Purchase of Suspect/Counterfeit Parts"

Environment, Safety And Health Bulletin issue No. 94, DOE Quality Alert Dated August 1992 "Counterfeit Parts"

1-8

S. J. Michelsen, Director Office of Contractor Management and Assistance Office of Procurement Assistance and Property, Memorandum Dated July 22,1992 "Inspector General Report 'I

SuspectMerior Bolts"

R. J. Secondo, Acting Assistant Manager for Site Engineering and Support, Letter Dated August 24,1992 "Recycling of Currently Stored Suspect Fasteners"

E. L. Wilmot, Assistant Manager for Site Engineering and Support, Letter Dated June 21, 1991 "DOE-ID G-uidance'for the Development of a Installed Suspect Material Action Plan"

A. A. Pitrolo, DOE-ID Site Manager, Letter Dated April 19, 1991 "Implementation of the DOE- ID Interim Action Plan for the Development of a Installed Suspect Material Action Plan"

A. A. Pitrolo, DOE-ID Site Manager, Letter Dated March 13,1991 "DOE-ID Identification of Defective Parts and Components Steering Committee"

W. H. Young, Assistant Secretary for Nuclear Energy, Memorandum, Dated March 8, 1991 "Suspect Parts"

Director Office of Procurement Information SystemsProperty Office of Procurement, Assistance and Program Management (Haymond), subjeck Counterfeit and Substandard Products, dated February 5, 1991. Contains the following attachments:

A. Bogus Products, letter by Haymond, addresses: Reporting of discovered counterfeit bolts, circuit breakers, or any other suspect bogus items to your local Office of Inspector General. Item segregated and secured until dispositioning. (Attachment 1)

B. General Accounting Office (GAO) Report RCED.-91-6 Nuclear Health and Safety: Counterfeit and Substandard Products are Government-wide Concern (Attachment 2).

C. US. Customs Service Report: Fastener Identification Markings (Attachment 3)

D. Headmark List, prepared by the U.S. Customs Service (Attachment 4)

E. U.S. Army Corps of Engineers, DCAF Bulletin and accompanying Information on ASTM A325 and A490 Structural Bolts, Nuts and Washers (Attachment 5).

J. M. Barr, Rear Admiral, US Navy, Deputy Assistant Secretary for Military Application Defence Programs, Memorandum, Dated December 19,1990 "Counterfeit and Substandard High Strength Fasteners"

W. H. Young, Assistant Secretary for Nuclear Energy, Memorandum, Dated December 5, 1990 "Minimum Requirements to Identify, Purge and Prevent the Acceptance of Counterfeit Parts"

1-9

Additional Reference Material:

References on SuspectlCounterfeit Material that can be obtained for future or supplemental informational needs. These references can be obtained from the Technical Library or in some cases the company Subject Matter Contact.

Summary - of US NRC Compliance Bulletins

BULLETIN NO.

87-02

88-05

88-10

NOTICE NO.

85-15

88-19

88-35

88-46

88-48

88-97

89-14

89-18

89-22

SUBJECTEtTL E

Fastener Testing To Determine Conformance with Applicable Material Specifications, Supplements 1 & 2

Nonconforming Material Supplied by Piping Supplies, Inc. At Falsom, New Jersey and West Jersey Mfg. Company at Williamston, New Jersey, Supplements 1 & 2

Noncdnforming Molded Case Circuit Breakers Re: Information Notice 88-46

Summary of US NRC Information Notices

S U B E c T / T I T L E

Nonconforming Structural Steel for Safety Related Use

Questionable Certification of Class IE Components

Inadequate Licensee Performed Vendor Audits

Licensee Report Of Defective Refurbished Circuit Breakers, Supplements 1,2,3, & 4

Licensee Report of Defective Refurbished Valves, Supplement 1

Potentially Substandard Valve Replacement Parts

Inadequate Dedication Process for Commercial Grade Components which Could Lead to Common Mode Failure or a Safety System

Criminal Prosecution of Wrongdoing Committed By Suppliers of Nuclear Products or Services

Questionable Certification of Fasteners

1-10

89-45

89-56

89-59

89-70

90-57

Metalclad, Low-Voltage Power Circuit Breakers Refurbished with Substandard Parts, Supplements 1 & 2

Questionable Certification of Material Supplied to the Defense Department by Nuclear Suppliers

Suppliers of Potentially Misrepresented Fasteners

Possible Indication of Misrepresented Vendor Products, Supplement 1

- -

Substandard, Refurbished Potter & B d e l d Relays Misrepresented As New

US Nuclear Regulatory Commission (NRC) Position Documents

Documents that address Counterfeit/Fraudulent Material:

1. USNRC Generic Letter 89-02, Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products

2. SECY-89-10, USNRC Advance Notice of Proposal Rule-making (ANPR), "Acceptance of Products Purchased for Use in Nuclear Power Plant Structures, Systems, and Components"

Note: This document requested public comment on whether or how NRC regulations should be revised to provide increased assurance that counterfeit or misrepresented vendor products are not installed in nuclear power plant.

3. SECY-90-057, Policy Issue (Information) on USNRC Advance Notice of Proposal Rule-making (ANPR), "Acceptance of Products Purchased for Use in Nuclear Power Plant Structures, Systems and Components"

Note: The policy issue provides a summary of staff efforts and plans to develop a basis for preceding with a proposed rulemaking to more specifically identify additional regulatory actions to assure that products purchased for use' in nuclear power plants will perform the functions necessary to protect the public health and safety.

4. NUMARC RESPONSES TO ANPR - SECY-90-304, NUMARC Initiatives on Procurement

1-11

5. Generic Letter 91-05, Licensee .Commercial-Grade Procurement and Dedication Programs, Games G. Partlow, US Nuclear Regulatory Commission, Washington, DC, April 9,1991.

Note: See Fastener Document Section for other related NRC documents addressing testing of Fasteners, etc. (ie., NUREG 1349).

Commercial Grade Items

1. EPRI Documents addressing Commercial Grade Items for Nuclear Applications.

2. EPRI NP-5652, Guideline for the Utilization of Commercial-Grade Items in Nuclear- Related Applications (NCIG-07).

3. EPRI NP-6406, Guideline for the Technical Evaluation of Replacement Items in Nuclear Power Plants (NCIG-11).

4. EPRI NP-5638, Guidelines for Preparing Specifications for Nuclear Power Plants (NCIG-04).

5. EPRI NP-6630, Guidelines for Performance Based Supplier Audits (NCIG-16).

6. EPRI NP-6629, Guidelines for the Procurement and Receipt of Items for Nuclear Power Plans (NCIG-15). -.

7. EPRI NP-7218, Guideline for the Utilization of Sampling Plans for Commercial Grade Items Acceptance (to be issued June 1992)

8.

9.

EPRI NP-6200, A Performance-Based Selective Inspection Process

Westinghouse Hanford Company Standard Practice, WHC-CM-6-1, SECTION EP-5.3, REV 0, Procurement of Safety Related Commercial Grade Items.

10. Westinghouse Hanford Company FJ?lT Engineering Instruction, WHC-CM-6-27, SECTION EI-086, REV 1, Material Control for Items Used in Safety Class Applications.

11. Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products (Generic Letter 89-01), Steven A 'Varga, US Nuclear Regulatory Commission, Washington, DC, March 21, 1989.

12. Licensee Commercial-Grade Procurement and Dedication Programs (Generic Letter 91-02, Games G. Partlow, US Nuclear Regulatory Commission, Washington, DC, April 9, 1991.

1-12

13.

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13

14.

Commercial Grade Items, Seabrook's Inventory Review Program, Stephen P. Buchwald, ASQC Eighteenth Annual National Energy Division Conference Presentation.

Fasteners

ASME-FAP-1-1990, Quality Assurance Program, Requirements for Fastener Manufacturers and Distributors

Appendix Public Law 101-592, Fastener Quality Act

H. R. 3000 Fastener Quality Act, 1990, White Paper prepared by National Fastener Distributor Association

Nuclear Utility Management and Resource council (NUMARC) paper on "Nuclear Procurement Program Improvements"

EG&G Energy Measurements Standard Operating Rule, No. 41-073.A Control Of Highstrength Threaded Fasteners

International Listing, Fastener Manufacture Identification Symbols, Faster Technology International Magazine, 1987

Military handbook, Listing of Fastener manufactures' Identification Symbols, MIZ,

HDBK-57A (IS), 29 Sept. 89

Industrial Fasteners Institute, Research Report: Division IV - Large Externally Threaded Products & Accessories and Division V - Internally Threaded Fasteners, False Grade 8 Engineering Performance Marks on Bolting and Improper Marking of - Grade 8 Nuts

EPRI NP-5067, Vol. 1 & 2, Good Bolting Practices

EPRI NP-5769, Vol. 1 & 2, Degradation & Failure of Bolting in Nuclear Power Plants

WINCO Procedure, FPR-18, FPR Fastener Assurance Program

U.S. Regulatory Commission, Compilation of Fastener Testing Data Received in Response to NRC Compliance Bulletin 87-02, NUREG-1349, June 1989

U.S. Regulatory Commission, NRC Inspection Manual, Temporary Instruction 2500D7, Inspection Requirements for NRC Compliance Bulletin 87-02, 'Fastener Testing to Determine Conformance with Applicable Material Specifications." This temp. instr. provides guidance in evaluating the adequacy of certain licensees" root cause analyses and the implementation of corrective actions in response to NRC Bulletin 87-02.

BrookHaven, Quality Assurance Manual, Section 7.3, Dedication of Commercial Grade Items.

1-13

15.

16.

17.

18.

19.

Westinghouse Savannah River Company (WSRC), ESH & QA Division, Suspect Fastener Investigation, Revision June 4, 1991, Document Control No. WSRC TR-91- 368. WSRC conducted a total of 1480 fastener tests for fasteners pulled from inventories. Tests included hardness , tensile, carbon analysis, and metallography. WSRC states Nonconformance results were similar to those identified in NUREG 1349.

Westinghouse Savannah River Company, RSES Investigation of Suspect Fasteners -X Facility, October 14, 1991. Based on walkdown, pulled studs/nuts from several flanges and conducted mechanical and chemical testing per ASTM specification.

Westinghouse Savannah River Company, Site Specification # SY-0001, Revision 2 (or later), Specification of Procurement of Bulk Fasteners

Westinghouse Savannah River Company, Site Specification # C-SPP-G-00053, Revision 4, Specification for Procurement of Bulk Fasteners, dated 8/20/91.

Westinghouse Savannah River Company, FFIF Readiness Review Board For Reactor P12A Restart Item'1.3.19 (Rev 0), dated May 16, 1991. F'FI'F's plan to deal with the issue of suspect bolts. Sample of bolts pulled from battery racks. Physical, hardness & Chemical tests conducted. Plan discusses results of NUREG 1349. Note: For additional NRC documents, see NRC Position Documents Section.

CHAPTER TWO

INDICATIONS FOR IDENTIFYING SUSPECT/ COUNTERFEIT MATERIALS

2-1

- .- I-

CHAPTER TWO

INDICATIONS FOR IDENTIFYING SUSPECT/ COUNTERFEIT MATERIALS

An item may have one or more of the indications described below and not be fraudulent. If an *item exhibits some of the indications listed below it is considered suspect and further investigation is warranted. Contact with the manufacturer may help establish whether the item in question has a quality control problem or is actually fraudulent.

General

Items may be suspect or fraudulent when:

1.

2.

3.

4.

5.

6.

7.

8-

9.

10

Nameplates, labels or tags have been altered, photocopied, silkscreened, painted over, are not secured well, show incomplete data, or are missing. Preprinted labels will normally show typed entries.

Obvious attempts at beautification have been made, such as: excess painting or wire brushing, evidence of hand painting (touch-up), stainless steel is painted, non-ferrous metals (copper, brass, bronze, etc.) are clean and bright indicating recent polishing.

Handmade parts are evident, such as: gaskets are rough cut, shims and thin metal part edges show evidence of cutting or dressing by hand tools (filing, hacksaw marking, use of tin snips or nippers).

Hand tool marks exist on fasteners or other aisembly parts (upset metal exists on screw or bolt head) or dissimilar parts are evident (seven of eight bolts are of the same material, one is of a different material).

Poor fit between assembled items.

Configuration is not consistent with other items from the same supplier or varies horn that indicated in supplier literature or drawing.

Inconsistency between vendor name on the item and on the shipping container.

Nameplates attached with inconsistent fasteners, such as: screws instead of rivets or rivets and screws.

Nameplates attached in a different location than normal.

Nameplates that appear old or worn, with paint on them, and look newer than the component.

2-3

11. Nameplates missing manufactures standard markings, stamps, or logos and with irregular stamping or inconsistent type style.

12. Difterence appearances of items in the same shipment.

13- Unusual boxing and packaging of item. Packaging inconsistent with supplier's normal packaging or documentation requirements.

- .

14. Price if the item is offered at unusually low price.

Documents

1. The use of correction fluid or cotrection tape is evident. Type style, size: or pitch change is evident.

2. The document is not signed, initialed when required, is excessively faded or unclear (indicating multiple, sequential copying) or data is missing.

3. The name of the document approver or his title cannot be determined or typed approval name and approval signature do not match.

4. Technical data is inconsistent with Code or standard requirements (e.g., no impact test results are provided when impact testing is required or CMTR physical test data indicates no heat treatment and heat treatment is required, chemical analysis indicates one material, physical tests indicate another, etc.).

5. Certification or test results are identical between items when normal variations should be expected.

6. Document traceability is not clear. The documentation should be traceable to the items procured.

7. Documentation is not delivered as required on the purchase order or is in an unusual format.

8. Documents 'XEROXED" or copied.

9. Corrections are not properly lined-out, initialed and dated.

10. Text on page ends abruptly and number of pages conflicts with transmittal.

11. Inconsistent configuration between product and product literature.

12. Lines on forms are bent, broken, or interrupted indicating data has been deleted or exchanged (cut and paste).

2-4

Visual Manufacturing Quality

1-

2-

Poor fit between assembled items.

Configuration is not consistent with other items from the same supplier or varies from that indicated in the supplier literature or drawing.

3- Increased dimensions.

4. Evidence of previous bolt head scoring on backsides of flanges or evidence that the area has been ground.

5- Loose or missing fasteners.

6 . Evidence of marring, tool impressions, traces of Prussian blue or lapping compound, or other evidence of previous attempts at fit-up.

7- Heat discoloration is evident.

8- Dissimilar materials carelessly in contact.

9. Cleanliness of item.

Specific

Surplus or Rebuilt Valves:

1. Paint

.

.

.

.

.

Valve appears freshly painted and valve stem has paint on it Wear marks or scratches on any painted surface Valve stem is protected, but protection has paint on it Paint does not match standard OEM color Exterior evidence of attempted repairs i.e. brush marks to repair spray paint Inconsistent shades on painted surfaces

2. Valve Tags

Tags attached with screws instead of rivets Tags attached in a different location than normal Tags that appear old or worn Tags with paint on them Tags that look newer than the valve Tags with no part numbers Tags with irregular stamping Tags without manufacturing logos

2-5

3.

4.

5.

6.

7.

Handwheels

.

.

. Old looking handwheel on new looking valves Handwheel that look sandblasted or newer than the valve Different types of handwheel on valves of the same manufacturer

Bolts/Nuts

.

. Bolts/nuts have a used appearance (excessive wench marks on flats) Improper bolt/nut material (e.g., a bronze nut on a stainless stem) Bolts with different size or grade markings

Valve Body

. Ground off casting marb with other markings stamped in area, OEM markings are nearly always raised, not stamped

. Signs of weld repairs Incorrect dimensions

. Fresh sand-blasted appearance including eye bolts, grease fittings, stem, et.

. Evidence of previous bolt head scoring on backsides of flanges, or evidence that this area has been ground to remove such marks

. On a stainless valve, a finish that is unusually shiny indicates bead-blasting. A finish that is unusually dull indicates sand-blasting. The finish on a new valve is in-between.

Manufacturer’s Logo

. Missing

. -

Logo plate looks newer than valve Logo plate shows signs of discoloration from previous use

Other

. Foreign material inside valve (e.g., metal shavings) Valve stem packing that shows all the adjustments have been run out In gate valves, a gate that is off-center when checked through the open end of the valve Obvious differences between valves in the same shipment

.

.

Fasteners:

1.

2.

Head markings are marred, missing, or appear to have been altered.

Threads show evidence of dressing or wear (threads should be of uniform color and finish).

Head markings are inconsistent within a heat. 3.

2-6

4. Mixed grade or manufactures head marks in same lot or shipment

Electrical Devices:

1.

2.

3.

4.

5.

6.

7.

Connections show evidence of previous attachment (metal upset or marring).

Connections show arcing or discoloration.

Fasteners are loose, missing or show metal upset.

Molded case circuit breakers are not consistent with manufacturer provided checklists for detecting substandard/fiaudulent breakers.

Missing UL or other labels.

Rivets are missing and screws are used inplace of where rivets are normally used or rivets look to be reused.

Molded case circuit breakers are shinney or look to have been painted with a lacer.

Rotating Machinery and Valve Internal Paris:

1. Shows marring, tool impressions, wear marks, traces of Prussian blue or lapping compound or other evidence of previous attempts at fit-up or assembly.

2. Heat discoloration is evident.

3. EGdence of erosion, corrosion, wire-drawing or "dimples" (inverted coneshaped impressions) on valve discs or seats or pump impellers.

2-7

APPENDIX

IDENTIFICATION OF SUSPECT/ COUNTERFEIT MATERIAL

A-1

,i

A-2

ABSTRACT

Suspect/counterfeit material is any item that either potentially or actually does not meet stated claims, such as standards and specifications (see definitions in Chapter One, page 1-3). This includes the copy or modification of an item without the authority or right to do so. The suspect material list consists of Tablel, a susuect component list and Table-2, a suspect indication list. The suspect component list is a compilation of reference information for documented incidences where suspect material has been supplied. The suspect indication list is a compilation of possible indicators of suspect material that have been provided by US. Government agencies and various published articles.

This document is intended as a compilation of available information and is not intended to indict any manufacturer, supplier, or product. The appropriate references contained in this document should be consul@ prior to taking any action related to procurement, inspection, or technical d l X i t i O l l .

A-3

CONTENTS

ABSTRACT ............................................................. A-3

TABLE 1 SUSPECT COMPONENT LIST .............................................. A-7

CircuitBreakers ....................................................... A-8

Switches ........................................................... A-16

Transmitters ......................................................... A-16

Motors ............................................................ A-16

Relays ............................................................. A-17

FUS~S .............................................................. A-18

Controllers ......................................................... A-18

Starters ............................................................ A-18

Resistors ........................................................... A-19

Starter Controls ...................................................... A-19

GaugeGIasses ....................................................... A-19

MercuryLamps ...................................................... A-20

Electrical Frames Frames ................................................ A-20

Pushbutton Station ................................................... A-20

Overload Relay Thermal Unit ........................................... A-20

Piping, Fittings, Flanges, and Components .................................. A-21

Valves ............................................................. A-21

Flanges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-22

Valve Replacement Parts ................................................ A-22

Pumps & Replacement Parts ............................................ A-22

A-5

ChannelMembers .................................................... A-22

FireBarriers .......................................................... A-22

Valve Actuator ...................................................... A-22

SteeI .............................................................. A-23

Fasteners ........................................................... A-23

TABLE 2 SUSPECT INDICATION LIST .............................................. A-25

Piping and Piping Components (Including Mechanical and Metal Products) ......... A-26

Electrical Components ................................................. A-30

Fasteners ........................................................... A-32

Documentation and Certification ......................................... A-33

A-6

TABLE 1

SUSPECT COMPONENT.LIST

A-7

COMPONENT

Circuit Breakers

TABLE-I a SUSPECT COMPONENT LIST A

MANUFACTURER/ TYPE

General Elktric (Component Examples)

General Electric (Component Examples)

DESCRIPTION

Metal Clad, low voltage, DC

1,2, & 3 pole various

amperages

- KHL36125

- AK-275-3 - AK-2 - AK-1-50 AK-1-75

THEF 136050

- B - TDQ - TCVVFS - 7 3 3

TEB122015-WL * TEB132090-WL - TElllOl5 - TED134060-WL

TEB122050-WL - THEDl36100 WL TED126050 - THED136060 WL - TJ3GB2120 - TEFl34Q15 - THE!?l36M1100 - TED 134030-WL

S A K 2 A 2 5 THED-136100-WL THED-136050-WL

+ THED-136045-WL - THFK-236070-WL TE-122070 THED-136150-WL THED-13600-WL TED-113020 TEG36050

. THED-124015-WL - TFI 36090 * TI? 361050-WL

AK-3A-25 TDQ-32150

A-8

SUPPLIER

Satin America & Circuit Breaker systems, Inc

Bud Ferguson’s Industrial Control & Supply Inc,

General Cirfuit Breaker & Electrical Supply,

HLC Electric Supply

California Breakers, Inc,

PENCON International (DBA) General Magnetics/ Electric Wholesale,

ANTITHEET

(DBA) ATS Circuit Breakers and AC Circuit Breaker-Electrical

systems, Inc

Supply

REFERENCES

NRC I.N. 89-45, Supplements and Attachments SENS Report ID #6 5-23-89

NRC I.N. 8846, Supplements and Attachments

NRC I.N. 90-46

Office of Nuclear Safety 93-5 (#ll)

.

~ _ _ _

COMPONENT

Circuit Breakers

. TABLE-1. SUSPECT COMPO)

h!lANUFACTUREEV TYPE

Westinghouse (Component Examples)

Not Provided

* DB-25 & DS-416

* FSN-5925-628-0641 - DB-25 DB-50

* HKB3150T * FB3020 * FB3070 - FB3050 - Em3025 - LBB3125 * HKA31250 - JA3200 * Em2100 * 225N - EB1020 * HDEA2030 * MCP331000R * MCP43155OCR * BAB3060H * 656D148GO3 . FA-2100 * EH-2050 * HFB-3050

HFD(B)-3020 6 MA3600 'F2020 * EH2100 p EB3050 - HMC38OOF p EA2090 * FA3125 ' HMCPlSO t HFD

DESCRIPTION

Commercial Grade

Low voltage

Trip units; Navy trip units; 1,2, & 3 pole various amp. ratings.

A-9

ENT LIST

SUPPLIER

Westinghouse Electric Supply 03. gVEsC0)

~ _ _ _ _

Satin America & Circuit Breaker Systems, Inc

General Circuit Breaker & Electrical Supply,

HLC Electrid Supply,


PENCON International (DBA) General Magdetics/ Electric Wholesale,

ANTI THEFT Systems, Inc (DBA) ATS Circuit Breakers

Electrical Supply a d AC Circuit Breaker -

REFERENCES

NRC I.N. 91-48

NRC I.N. 89-45 & Supple. #2

NRC I.N. 88-46, Supplements and Attachments

Office of NUL Safety 93-9

COMPONENT

Circuit Breakers

TABLE-1. SUSPECT COMPONENT LIST

MANUFACTURER/ TYPE

Westinghouse (Cont.) (Component Examples)

- El32070 - JB3100 EB2030

* 8MC800 * cAH3200 - EHB3040 - JL3-Bl50 - JL3-B200 - JL3-BO90

- HFA,HFB,FA * JI3-(B)8070 - JL3-Bl25 - EH2020 * FA-3035 - EH-2050

FA-2100 - FA-2050

. JL3-BlOOO

HFB-3050 JA-2225 - HLM38OOT - F3lOON

f MA3500 - El32015 - LA3uH)wL - HLA3200T 2602D58U9 - HLB32OOT - 2602156G19 - EHB2100 - l A & l B - HL38OOT

* MDL#KAF - QNB3020 * QNB3030 - BA * BA * E3060

DESCRIPTION

Shunt Trips Aux Contacts 2 & 3 pole Circuit breakers of various amperages

~ ~~~

225 amp., 3 pole 3 pole, 20 amp. 3 pole, 30 amp. 1 pole, 20 & 30 amp. 2 pole, 20 & 30 amp. 3 pole, 60 amp.

3 pole 20 amp.

SUPPLIER


HLC Electrical Supply,



ANTI mFr systems, Inc. (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

Not Provided

Not Provided

REFERENCES

NRC LN. 88046, Supplements and Attachments

SENS ID. #10 3-17-89 SENS ID. #11 3-3-89

SENS Report ID #12 10-19-88 NRC I.N. 88-46

,i

A-10

COMPONENT

Circuit Breakers

TABLE-I, SUSPECT COMPONENT LIST

MANUFACTURER/ TYPE

(Component Examples)

Model - E43B015

* EQ-B - EE-3BO30

* EBB070 * EBH050 - EMB125 * EBB040 - E42B020 * QJ2B200 * JL3B400 * HE9BO40 - EE3B050 * BQ2B030 * EBB070

EBB100 - E m 0 5 0 * EE2B030

FJ3B225 ET

- K A * EH-313015 * JL3B070 * JL3B150 * E43B015 * EJ?2-B030 - EH3B100 - QPlB020

QJ3B200 - EBB100 f 1193

DESCRIPTION

%phase 480 volt

1 pole, 20 amp. 3 pole, 30 amp.

2 & 3 pole, Mlious amperages

A-11

SUPPLER

Cal. BreakersElect. Wholesale Supply Co.

Not Provided



California Breakem, hc,

PENCON International (DBA) General Magnetics/ Electric Wholesale

ANTI THEFT Systems, Inc (DBA) ATS Circuit Breakm and AC Circuit Breaks - Electrical S~ppIy

REFERENCES

SENS Report ID #8, 5-5-89

SENS ID #lo, 3-17-89 SENS ID #11, 3-3-89

NRC I.N. 88-46, Supplements and Attachments

COMPONENT

Circuit Breakers

TABLE-1 SUSPECT COMPONENT LIST

MANUFACTURER/ TYPE

~

ITE, Gould & lTE Imperial

Brown Boveri Elect. (BBE) MEA Brown Boveri (Component Examples)

TypeHK 5HK 7.5 HK 15 HK 38HK - ITE62-6

DESCRIPTION

Not Provided ID 4-Kv Not Provided Not Provided Not Provided

SUPPLIER

Brown Bover S E A Brown Boveri

REFERENCES

NRC I.N. 89-86

NRC I.N. 87-41

Office of NUC. Safety 9225

A-12

COMPONENT

Circuit Breakers

TABLE- I SUSPECTCO

~

hUNUFACTURER/ TYPE

Square "D" Co. Component Examples

- KHL 36125 (Any %e)

* QOB120

~~

* Q0220 * Lo-3 * SBW-12 * 989316

FAL3650-16Mor FAL36050-16M KA36200

* 999330

Manufacturer not provided

ED3025

RPONENT LIST

Molded case

1 pole, 15 amp

2& 3 pole -20 &50 amp breakers

3 pole - 200 amp breaker 30A/600V

Not Provided

A-13

SUPPLIER


HLC Electric Supply,



ANTI THEFT systems Inc (DBA) ATS Circuit Breaken and AC Circuit Breaker - Electrical Supply

Not Provided





ANTI THEFT Systems, Inc (DBA) ATS Circuit Breaken

Electrical Supply

Stokely Enterprises

and AC Circuit Breaker -

REFEEU2NCES

NRC I.N. 88-46, Supp. & Attach.

NRCB 88-10

NCR'1.N. 90-46

SENS ID #lo, 3-17-89

NRC I.N. 89-45 & Supple. #2

DOE Letter 8-26-91 Reprinted "NuVEP Bulletin 7-26-91

TABLE-I SUSPECT COMPONENT LIST

MANUFACTURER/ TYPE

Fed. Pacific (Component Examples)

* NEF431020R - NE111020 - N E

- NF%3-1100 - NE224060 - NE22-4100 * NEF-433030 * 2P125

Jefferson (Component

Examples)

DESCRIPTION

3 pole, 20 amp 1 pole, 20 amp 1 pole, 15 amp

1, & 3 pole- 30, 60 & 100 amp breaken

Not Provided

A-14

SUPPLIER

____

General Circuit Breaker & Electrid Supply,




MITI THEFT Systems, Inc (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply





ANTI THEFT Systems, Inc. (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical supply

REFERENCES

SENS ID. #10 3-17-89

SENS ID. #113-3-89

NRC LN. 8846, Supp. & Attach.

NRC I.N. 88.46, Supp. & Attach.

~~

COMPONENT

Circuit Breakers

TABLE-I. SUSPECT COMPONENT LIST

MANUFACTURER/ TYPE

Superior (Component Examples)

N U - 3

Cutler Hammer (Component Examples)

* 10177H13 - 10177H21 * 10177H32 - 10177H1036 * 10177H1049

DESCRIPTION

Not Provided

Not Provided

A-15

SUPPLIER



California Breakm, Inc,

PENCON International (DBA) General Magnetics1 Electric Wholesale,

ANTI THEFT systems, Inc (DBA) ATS Circuit Breakem

Electrical Supply and AC CiCuit Breaker -





ANTI THEFT systems, Inc (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

REFEWNCE S

NRC I.N. 88-46, Supp. & Attach.

NRC I.N. 88.46, Supp. & Attach.

COMPONENT

Circuit Breakers

Switches

Transmitters

Motors


MANUFACTURER/ TYPE

Manufacturer Not Provided (Component Examples)

5ODHP250


chouse Hinds #EDSC2129

Sq. D ?Lpe G, Class 9012,9025, 9016

Rosemount

Siemen & Allis (Component Examples)

INP 143 T 215 T

DESCRIPTION

2 pole - 50 amp.

Tumbler, ft. op.


- Model1151 GP - Model 1151 DP

10 H.P.

A-16

SUPPLIER.



California Break=, Inc,


ANTI THEFT Systems, Inc (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

Platt Electric Supply Co.

Gen. Motors, Electro-Motive Design

Venetech


HLC Electric Supply

california Breakers, Inc,


REFERENCES

NRC LN. 88-46, Supp. & Attach.

SENS ID #16 1-27-92

Office of Nuc Safety 93-24 & 93-27

E.L. Wilmot letter dated 5-1-91

H. Richardson letter HR-81-91, dated 8-15-91

NRC I.N. 88.46, Supplements and Attachments

ANTI THEFT Systems, Inc. (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

--. . . -_I_

COMPONENT

Relays .

TABLE-I = SUSPECT COMPONENT LIST

I DEscRIPmoN MANUFACTURER/ TYPE

Potter & Brumfield (Component Examples)

MDR-138-8,173-1, 134-1,1421

Teledyne All qualified to MIL-R- 28776 a d MIL-R- 39016

G.E. & Exide (Component Examples)

I Overload & Aux.

* 12HGA-llS52 * Nx400

Manufacturer not provided Not Provided

* FSG5945

Amerace (or Agastat) (Component Examples)

Models: E7024 E7022 A through L Series Model 7032

Electro Pneumatic T i i g Relays

PRB

SUPPLBR

Stokely Enterprises

Not Provided





ANTI THEFT Systems, Inc (DBA) ATS Circuit Breakers

Electrical Supply

Stokely Enterprises

a d AC Circuit Breaker -

Amerace

Control Components Supply

~

REFERENCES

NRC I.N. 90-57 & Attach.

DOE-ID Wilmot letter 7-16-91

NRC I.N. 8846, Supp. & Attach.

DOE Letter 8-26-91 Reprinted "NuVEP Bulletin 7-26-91

~ ~~~~~

SENS ID #111-1-91

NRC I.N. 9224

A-17

,

COMPONENT

Fuses

Controllers


MANUFACTURER/ TYPE

Bussman Co. (Component Examples)

REN 15 & NOS-30

Class 1E

Manuhcturer Not Listed (Component Examples)

FSC 6110


DESCRIPTION

15A-250V & 30AdOOV

AU Supplied by PMS

Motor Controllers

Not Provided

SUPPLIER





ANTI THEFT Systems, Inc @BA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

Preventive Maintenance Systems (PMS)

Stokely Distributors & Stokely Enterprises Inc





ANTI THEFT Systems, Inc (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

REEERENCES

NRC LN. 88-46, Supp. & Attach.

NRC I.N. 88-19

DOE letter 8-26-91 & NUVEP Bulletin 7-26-91

NRC I.N. 88.46 Supp. & Attach.

A-I8

TABLE-I. SUSPECT COMPONENT LIST ,

MANUFACTURER/ TYPE

UnknoWn


* A2OOMICAC * m1KIcA * A2OlK2Ca * AN13A

Siemen & AUis (Component Examples)

DESCRIPTION

All

Not Provided

Not Provided

#OO-737-637-118 215 T

A-19

SUPPLIER

Impala Electronics


HLC Electric Supplyl



ANTI THEFTSystems, Inc (DBA) ATS Circuit Breakexs and AC Circuit Breaker - Electrical Supply

Rosen Electric Co.,

REFEWNCES

NRC I.N. 91-01

NRC I.N. 88-48

NRC I.N. 88.46 supp. & Attach.

COMPONENT

Mercury Lamps

Electriml Frames FEUlleS

Pushbutton Station

Overload Relay Thermal unit


MANUFACTURER/ TYPE

spectro Inc (Component Examples)

V00014


KB325OF

CrouseHinds (Component Examples)

NO-737437-118

Square. D (Component Examples)

DESCRIPTION

Not Provided

Not Provided

Single gang, push button

Not Provided

B19.5, B22

A-20

SUPPLIER





ANTI THEET Systems, Inc (DBA) ATS Circuit Breakem and AC Circuit Breaker - Electrical Supply

General Circuit Breaker & Electrical SuppIy,




ANTI THEFl? Systems, Inc (DBA) ATS Circuit Breakers and AC Circuit Breaker - Electrical Supply

Platt Electric Supply Co.

Not Provided

REFERENCES

NRC I.N. 88-46

NRC I.N. 88-46

SENS Report ID #16 1-27-92

NRC I.N. 88-46

TABLE-I, SUSPECT COMPONENT LIST

Tube-line

Ray Miller Inc

Piping Supplies, Inc & West Jersey Mfg. & Chews Landing Metal Mfg.

CMA International IMA

I COMPONENT

NRC IEB 83-06 NRC I.N. 89-18 NRC IEB 83-07 NRC I.N. 83-01

NRC Bulletin 88-05 & Supplements

NRC I.N. 88-48 &

Piping, Fittings, Flanges, and Components

l'IT Grinnell Valve Co., Inc

~~

Piping, Fittings, Flanges, and Components

4"-1500 psi, pressure Sealed Maintenance Co.,

Southern Cal. Valve

Amesse Welding Service & CMA Int.

I'IT Grinnell Valve Co. Inc, Div. of Diaffo & IlT Engineered Valves

Diaphragm valves

Valves

Crane, Pacific, Powell, Walworth & Lunkenheimer

Pacific

MfWUFACRJRER/ TYPE

Gate Valves CoffeyvilIe Valve Inc

8" & 3" Globe Valve CMA&IMAValve

Tube-line Corp. Ray Miller Inc

Crane Chapman

Pacific

Piping Supplies, Inc & West Jersey Mfg. & Chews Landing Metal Mfg.

Refurbiher Supp. & Attach.

24" Check Valve' CMA&IMAVahre I NRC I.N. 8848 Refurbsher Supp. & Attach.

Check Valve CMA&IMAValve NRC I.N. 8848 Refurbiiher Supp. & Attach.

VOGT

1 DESCRIPTION

~ Subassemblies, fittings, I flanges & other

components

SUPPLIER I REFERENC-

(Carbon and Stainless Steel components)

Carbon and Stainless Steel Fittings and Flanges

Full port design %inch Model SW-131118~ Supplements I I I 1023

Crane NRC I.N. 91-09

- NRC a m p . Bulletin 87-02

NRC I.N. 92-56

NRC I.N. 88-48,

A-21


COMPONENT MANUFACTURER/ TYPE

DESCRIPTION SUPPLIER REFERENCES

Valves KerotFt 8" Valve CMA&IMAValve Refurbisher

NRC I.N. 88-48 supp. & Attach.

Pacific 4" Gate Valve CMA & IMA Valve Refurbisher

NRC I.N. 88-48 Supp. & Attach.


Lunkenheimer CMA&IMAValve Refurbiiher

6" Model 1542 20" Model 3013

Crane All CMA & IMAValve Refurbisher

NRC LN. 88-48 Supp. & Attach.

NRC I.N. 92-68 and Attachments

China Ding Zinang Nan Xi Li Flange Co. Shou Gang Mach. Eng. Co.

Flanges, ASTM Al05, ASME SA105

Billiongold Co. LTD. Tain Gong Co. Shanxi Province Overseas Trading Corp. Office of Nuclear Safety

9225,9323, and 92-35

Valve Replacement Parts

Masoneilan-Dresser Industries Plug stem, stem to plug anti-rotation pin, seat ring, valve plugs, bushings, cages & packing box components

Cor-Val, Control Valve Specialists, H.H. Bmum & M.D. Nonvood


Pumps & Replacement Parts

Hayward Vler Pump Co. HTPC ASME Nudear Hayward Tyler Pump Co. Code I IEB 83-05 &

Attachments

Channel Members unistrut Corp. Continuously slotted channels, structural framing members, fasteners, nuts, fittings,

unistrut Corp. NRC I.N. 91-25

Ripe clamps I I Fm Barriers Thermal Science Inc Thenno-Lag 330 None Listed ES&Q Update #18

NRC I.N. 92-55

Valve Actuator L i to rque Eyebolts on housing cover

None Listed Office of Nuc Safety 93-25

I I NRC I.N. 93-37

A-22

COMPONENT

Steel

Fasteners (Bolts, Screws, Nuts, and Washers)


MANUFACTURER/ TYPE

AUoy & Carbon Steel Co. Inc, Atlantic Steel Co., Levingston Steel Co., & Copperweld Steel Co.

{parentheses designated head mark}

&hi (A) Daiichi (D) Daiei (E) Fastener Co. of Japan 0 Hinomoto Metal (H.) Jin Her (J) Kyowa (K) Kosaka Kogyo (KS) Kyoei (KY) Minamida Seiybo (h4) Mnato Kogyo (MS) Nippon 0

Tsukimori (S) Unytte 0 Yamadai (Y) Ivaco, Infasco (hollow triangle0

0

~~

DESCRIPTION

Plate Angle Flat Bar Bar

* Those with suspect suppliers or manufacturers

- Those that are improperly marked

- Those of foreign manufacture that do no meet Public Law 101-592, The Fastener Quality Act.

~

Meridith Corporation Pressure Vessel Nuclear AUoy & Carbon Steel Co., Inc

Note: Listed suppliers may also be manufacturers.

Lawence Engineering &

Metal Building Bolts Nichimin Corp. UNICO Ace Cop. E. IC Fasteners, Inc H. Y. Port Fasteners Co. Kobayashi Metals, LTD. Takai Screw Mfg. Co. LTD. Yamaguchi Sesakusho Co. LTD. Highland Bolt & Nut Porteous Fastener Co. Northwest Fasteners Ziegler Bolts & Parts Co. Edgewater Fasteners, Inc Reynolds Fasteners A&G Engineering

supply 02

REFERENCES

NRC I.N. 89-56, Attachments and Supplements

Commercial Carrier Journal Articles for: 6/88,1/90,2/90,3/90, 4/90,6/90,7/90,12/90.

INEL Suspect Headmark List.

SENS Report # 5 245191.

SENS Report #13, 11/6191.

HR 3000, U.S. House of Representatives, July 1988.

J. A. Jones Ltr, 9/23/92

Memo from L. Kubicek 3128/91.

Memo from D. Sanow 3/8/91.

Fastener Technology IiUemdoml, Feb., April., and June 1993.

Rep. J. Dingell Ltr to Comm. Dept. & NRC, June 18,1993

Office of Nuc Safety 93-26,93-22, 93-11

A-23

COMPONENT

Fasteners (Bolts, Screws, Nuts, and Washers)

h4ANlJFACTURER/ TYPE

NUCOR


DESCRIPTION,

1-1/4" X 2" Zinc Chromate plated surface Hexhead cap screws

A-24

SUPPLIER

Cordova Bolt Inc

Aircom Barnett Bolt Works Bolts & Nuts, Inc Glasser &Assoc Knoxville Bolt & Screw Metal Fastener Supply Phoell Mfg. Co. Service Supply Co. Southeastern Bolt & Screw Sure Loc Victory Bolt

REFEpENCES

SENS ID#13 11-6-91

NRC Compliance Bulletin 87-02 NRC I.N. 89-59

TABLE 2

SUSPECT INDICATIONS LIST

Note: Additional detection characteristics are presented in Chapter Two.

Also, refer to the '!Fastener Head Mary shown in Fwe 1 on page 3 in the IntroductioIL

A-25

TABLE-2. SUSPECT INDICATION LIST

L PIPINGAND PIPINGCOMPONENTS ~CLUDINGMECElANICALANDMFTAL ' PRODUCTS)

-. Components with the following indications are considered suspect, unless otherwise noted.

A General Indications:

Used component appearance Unusual or inadequate packaging Foreign newspapers used as packaging Scratches on component outer surface Evidence of tampering Components with no markings Pitting or corrosion External weld or heat indications Questionable or meaningless numbers Typed labels Evidence of hand made parts Painted stainless steel Ferrous metals that are clean and bright Ecess wire brushing or painting Ground off casting marks with' stamped marks in the vicinity Signs of weld repairs Threads showing evidence of wear or dressing Inconsistency between labels Old or worn nameplates Nameplates that look newer-than the component Missing manufacturer's standard markings and logos Traces of Prussian Blue

B. SDecific Indications:

No specification number No size designation Missing pressure class rating Other missing designations per the specification

A-26


I. PIPING AND PIPING COMPONENTS - CONlTNUED

A.

B.

General Valve hdications

Wrench marks on valve packing glands, nuts, and bolts Nameplates attached with screws rather than rivets Poor fit between assembled valve parts Dirty internals Scratched or marred fasteners or packing glands Gate valve: gate off-center when viewed through open end Fresh sand blasted appearance of valve bodies, eye bolts, fittings, stems, etc Loose or missing fasteners Different types of handwheels are on valves of the same manufacturer Some parts (e.g., handwheels) look newer than the rest of the valve Improper material (e.g., bronze nut on a stainless stem)

S d c Valve Indications Valves produced by the following manufacturers generally have the following features and are considered suspect if they are missing these features.

Crane Valva:

Cranename Pressure rating Pattern number

Body Cast or Forged Markings:

- Nameplate Information: Made from stainless steel (silver color) with black lettering Attached by drive screws OR Attached on valve stem underneath handle Valve size Pressure class, operating pressure at temperature Body material Seat material on valve body and valve seat Stem trim material and heat treat conditions Certification data Military specification if applicable Drawing number Shop Order Number (SO#)

A-27


J

L PIPNGAND PIPING coMPONENI[s - CONTIJWED , . . .

- .

Specific Valve Indicatiom - continued

Body Cast or Forged Markings including the name "Powell" Valveclass Valvesize - Grade of steel Melt number

Nameplate Information: Riveted to valve body OR attached to valve stem underneath handle Attached with single end welded wire (small valves) Serial number Valve size Figure number Body style Valve stem, disc, and seat type Strength at temperature Strength at 100°F "The WM. Powell Co. Cin., Oh. Made in USA"

Vo& Hem Machine CO, Inc.:

Body Cast or Forged Markings: The name "Vogt" - Pressurerating - Pattern number Size - Material Specification Two code ID - 3 letter code and a 4 digit code (For example ABC and R-1421)

.I

--


L PIPING AND PIPING COMPONENTS - CONTINUED

S d c Valve Indications - Continued Vogt, H e m Machine Co.. Inc. - continued

Nameplate Information:

Valve size

Body material

- Stem trim material Specification Number Drawingnumber - PressureRating

Made from aluminum with electro-chemical etched lettering Attached on valve stem underneath handle

Pressure class, operating pressure at temperature

Internal seat .material or internal H.F.

Body Cast or Forged Markings: The name "Walworth" - Pressureclass size Heat code Serial number (stamped)

Nameplate Idormation Made from aluminum Attached by drive screws

Valve size Attached to cover at times

Pressure class and operating pressure at temperature Body material Internal seat material or H.F. Stem trim material and heat treat conditions Figurenumber Serialnumber Location of manufacture Item code number


L PIPING AND PIPING COMPONENTS - CONTINUED

Specific Valve Indications - continued

Masoneilan or Wortbington Controls stamped on nameplate MN or Masoneilan on valve body

IL ELECI'RICAL, COMPONENTS Components with the following indications are considered suspect.

A General Indications:

Screwdriver marks on terminals Different screw types or materials on terminals Handwritten or typed rather than stamped tags Missing tags (usually U L approval tag) Pitted or worn contacts and lugs Not in manufacturer's box or container Signs of paint or smoke InSufEicient nameplate information Missing terminals Screws used in place of rivets Body worn or discolored Rough metal edges Scratched or marred surfaces Metal color inconsistencies Modified or re-stamped nameplates Improper fastening of nameplates Plastic parts of different colors Discolored or faded manufacturer's labels

A-30


IL ELEcrRIcm COMPONENTS - CONTINUED

B. S-c Indications:

Molded Case Circuit Breakers:

Handle modified to change Ampere rating Style is no longer manufactured Unusual packaging: bulk packaging, generic packages, and "cheap" appearance Refurbisher's name on breaker Broken seal between halves Contradicting amperage ratings

Label missing or weathered Wear marks on bases

Power (Draw Out) Circuit Breakers:

Different color or shape of over current devices Suspicious looking auxiliary trip devices

Motor Starters:

- Poor fitting or wrong voltage rated operating coil

Motor Control Centers:

Breakers that are not easily opened or closed with compartment door closed Ekposed busswork with compartment doors open


Electro-mechanicd Relavs:

Poor or loose fitting relays

Potter-Brumfield Relav:

Sloppy coil lead solder joints Painted relay base grommets (normally clear) Terminal strips fastened with eyelets Painted rivets fastening the terminal strip to the relay housing Termination Screws in brown paper bags (should be in clear, heat sealed plastic bags) Use of bubble wrap (plastic with Styrofoam should be used) Repainted inner bell surface Missing or inconsistent date codes, inspection stamp, and test stamp Incorrect shaft relay cover clearance, shaft play, and lack of bearing lubricant Tops of rotor shafts painted a color other than black Nonuniform numbers stamped on the contact decks, indicating decks made up from various relays. Incorrect coil (i.e., 125 VDC relay with 200 VDC coil)

General Indications:

No manufacturer’s or grade mark (unless certified to a specification not requiring marking) Evidence of machining marks Poor thread form, evidence of wear, evidence of dressing Head marks shown on the Suspect Fastener Head Mark List (Fig. 1) Foreign manufacturer not meeting Public Law 101-592 No markings for nuts or washers packaged with labels indicating that they were manufactured to a code or MIL6PEC which requires making Head markings are marred, missing, or appear to have been altered Head markings are inconsistent with a heat/lot

A-32


IV. DOCUMENTATION AND CERTIFICATION:

General Indications:

Use of correction fluid or correction tape Type style or pitch change is evident Documentation has missing (or illegible) signature, initial, or data Document is excessively faded or unclear Inconsistent technical data Certification or test results are identical between items when normal variations should be expected Document is not traceable to the items procured Technical data is inconsistent with code or standard requirements Documentation is not delivered as required on the purchase order, or is in an unusual format Lines on forms are bent, broken, or interrupted indicating data has been deleted or exchanged by "cut and paste" Handwritten entries are on the same document where typed or preprinted data exists Data on a single line is located at different heights