Defense Nuclear Facilities Safety Board

Memorandum

May 23, 1996

I. Introduction

As a result of concerns regarding programs to identify and remove suspect/counterfeit parts in safety related systems, I conducted a review of installed electrical equipment of the selected buildings at the Pantex Site from May 13, 1996, through May 15, 1996. During my review, I viewed accessible portions of the safety significant components of electrical systems of these buildings. I found 224 electrical components (see Attachment A) that have been identified as suspect in the NRC Safety Bulletin: 157 installed suspect molded case circuit breakers (MCCB), 66 in stock suspect MCCB, and one suspect time relay. All of these components are classified by Pantex as components of Safety Significant Systems. I was told by one of the Program Managers for Systems Engineering Group for Pantex that efforts to identify and remove suspect/counterfeit parts were limited to fasteners. Further, he stated that installed electrical systems have not been inspected for the presence of suspect/counterfeit parts.

My findings of suspect/counterfeit parts in safety significant related systems at the selected building at Pantex and the statements by the Pantex Contractor contradict assurances provided by EM representatives that suspect/counterfeit parts have been purged from safety related applications at Pantex. The findings also contradict the statement contained in the Secretary of Energy's 1994 Federal Manager's Financial Integrity Act report to the President that substandard and counterfeit products have been purged from critical safety systems.

II. Discussion

I reviewed the electrical one line diagrams, safety class and safety-significant class systems, and selected the potential areas and equipment for walkdown for Buildings 12-84 (Bays), 12-104 (Bays), 12-98 (Cells) and 12-44 (Cells). Selected load centers, motor control compartments, and electrical panels were opened and inspected for the presence of suspect/counterfeit molded case circuit breakers, fuses, switches, and relays.

I found 224 suspect and electrical components: 157 installed suspect molded case circuit breakers (MCCB), 66 in stock suspect MCCB, and one suspect time relay. All of these suspect components are classified by Pantex as components of safety significant systems.

Except for the molded case circuit breaker type EHB-100 manufactured by Westinghouse, none of the suspect components identified in the Attachment A showed any signs of cracked casing, altered rating on the label, tampered wire lugs, the use of screws in lieu of rivets, and nicked or scratched surfaces which would be indications that they might be counterfeit. MCCB, type EHB-100, is rated at 100 Amperes and installed on the Panel, UELP-1, located in the Electrical Equipment Room 1 of the Building 12-104 (East), a High Explosive Subassembly Facility. Later Mason and Hanger (M-H) disassembled the MCCB from the panel and visually inspected it for any signs of altered rating and cracked casing. Identification of the rating on the circuit breaker casing showed signs of being altered and is painted on instead of being impressed into the case. This breaker feeds the branch circuits which provide power to all the emergency lights in this building.

Emergency lights at Pantex are classified as a safety-significant system and are considered critical for safe shutdown of operations and egress in the event of a loss of power. Critical Safety Systems Manual CSSM MNL-1101, Revision 3C, Section B.10, provides the basis for the emergency lighting as follows:

"The basis for emergency lighting is to provide the required illumination automatically in the event of any interruption of normal lighting. This lighting will allow safe shutdown of operations in and egress from the effected facility in the event of a loss of power. The loss of the emergency lighting system could severely hinder evacuation of the facility, potentially lending to many different types of industrial accidents."

Because of the importance of this breaker, M-H plans to replace this breaker with a new one. M-H will also evaluate the performance of this breaker by testing to confirm its conformance with the time-current characteristic curve for this type of breaker.

For the remaining 222 suspect breakers, two possible methods for determining the component's integrity for continued use in the systems were discussed. One was to identify the vendor for these breakers through the procurement cycle and determine if any of the identified components were supplied by a counterfeit vendor. Another was to test randomly selected MCCB at the respective manufacturer's facility in accordance with an established test program to validate the breaker's conformance with its specification. M-H does not have the test equipment to fully test these breakers. Therefore, I have referred M-H to a test program which was recommended by USNRC in its NRC Bulletin No. 88-10 for MCCB, and gave them a copy of this test program for possible use and information. I have also notified Mr. Jim L. Nunley (M-H, Program Manager - Systems Engineering) and Jim McConnell (DNFSB Site Representative) of all suspect/counterfeit parts which I identified.

Attachment A

Electrical Suspect/Counterfeit Parts Identified During the Walkdown of Electrical Significant Systems of Building 12-84, 12-44, 12-98 and 12-104 at Pantex.

SSS = Safety Significant Systems
EPP = Emergency Power Panel
MCCB = Molded Case Circuit Breaker