EH-92-4 DOE Quality Alert
                       ENVIRONMENT, SAFETY & HEALTH
                                 BULLETIN

Assistant Secretary for                         U. S. Department of Energy
Environment, Safety & Health                    Washington, D.C.  20585

DOE/EH-0266                     Issue No. 92-4                 August 1992


                             DOE QUALITY ALERT

Counterfeit Parts

This Bulletin provides 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 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 in excess of 1,000,000
suspect/counterfeit bolts and over 700 suspect/counterfeit circuit
breakers to the Department.

Counterfeit/Substandard 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 (IFI) reported finding substandard, mismarked, and/or
counterfeit, high-strength Grade 8 bolts in the United States commercial
marketplace.  In 1988, IFI reported that counterfeit medium-strength 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.
Identifying, 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.

Fatalities From Substandard Bolts

A Report of the Subcommittee on Oversight and Investigations of the
Committee on Energy and Commerce of the U.S. House of Representatives
entitled The Threat from Substandard Fasteners:  Is America Losing Its
Grip? dated July 1988 stated the following under the heading "Saturn
Corporation, Tennessee":

      A death has occurred, in part, because a bolt...broke as an iron
      worker was tightening it.  The iron worker lost his balance and
      fell, missing the safety net.  The bolt, 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
      officials determined were caused by defective fasteners...the nuts,
      bolts and screws that hold together an aircraft.  The National
      Transportation 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.

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

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 fire aboard a Navy destroyer that killed two sailors 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 connecting a high-pressure steam line
      sheared...a closer analysis of the bolt...showed it hadn't been sold
      to the Navy by any known domestic company, and sources speculate
      that it might have been a foreign-made fastener.

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 (SNMG) will amend the guidance
issued March 12, 1992.

DOE contractors have reported suspect/counterfeit bolts in several
different ways.  Some have weighed 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.

Indicators - Headmarks

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 six 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.

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
certificates--documentation 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 require everyone in the
distribution chain to ensure bolt traceability.

Current Activities

SNMG 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, viz., (1) to determine the
scope of the problem and to take immediate corrective actions as
appropriate, and (2) to provide guidelines for strengthening the
procurement process so as to preclude the acceptance of counterfeit parts
in the future.

Consistent with SNMG guidance, each site should:

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

2.    Continue review and revise procurement and quality assurance
      procedures so that the problem does not recur, and

3.    Continue to detect any new attempts by unscrupulous vendors to
      supply substandard parts.

Precautions

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

1.    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 tests.

2.    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 any 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.

Disposition

Consistent with SNMG guidance:

1.    Segregate and retain 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 on 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 organizations no longer need them as
      evidence.

2.    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
      Reporting and Processing of Operations Information, Attachment 1,
      "Categorization of Reportable Occurrences."  The reports should
      include identification of the particular headmark, the number of
      bolts found with that headmark, and the supplier.

3.    Report to the Office of Inspector General cases where there are
      indications that suppliers knowingly supplied items and services of
      substandard quality.

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

As appropriate, DOE contractors should also report on the SPMS which
provides more detailed information.  To obtain a password for access to
this system, contact Rick Edwards (208)526-1099.  Suspect Equipment
Reports (SER) can be found in the Supplier Evaluation and Suspect
Equipment (SESE) data base on the ES&H News menu of the SPMS.  Only SER
representatives can enter data into SER.  If there is no SER
representative at your site, or if you wish to have data entry access,
contact Janet Macon (301)903-6096.

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 (UL) for the refurbishing of
      molded-case electrical circuit breakers, nor are there any
      "authorized" refurbishers of molded-case circuit breakers.
      Therefore, "refurbished" molded-case circuit breakers should not be
      accepted for use in any DOE facility.

2.    One source of refurbished molded-case circuit breakers is from the
      demolition of old buildings.  Some refurbishers 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 fine.

3.    NRC published Information Notice No. 88-46 dated July 8, 1988, on
      the investigation findings 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.

4.    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 traceability of the
      circuit breaker itself.  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:

o     The style of breaker is no longer manufactured.

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

o     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.

o     The original manufacturer's labels and/or the Underwriters
      Laboratory (UL) or Factory Mutual (FM) labels may have been
      counterfeited or removed from 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.

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

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

o     Wire lugs (connectors) show evidence of tampering.

o     The surface of the circuit breaker may be nicked or scratched yet
      have a high gloss.  Refurbishers 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 cases of new
      circuit breakers often have a dull appearance.

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

o     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, refurbishers have been known to file down the surface of the
      handle to remove the original rating and hand-paint the desired
      amperage rating.

Testing

In a news release dated February 6, 1989, the National Electrical
Manufacture's Association (NEMA) announced the cancellation of its
Publication AB-2-1984 entitled, "Procedures of 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 breakers that had been
      originally tested and calibrated in accordance with NEMA Standards
      Publication AB 1 or Underwriters Laboratories Standard UL 489, and
      not subsequently opened, cleaned or modified....  Therefore the
      Standards Publication contained none of the destructive test
      procedures...necessary to verify the product's ability to withstnad
      such conditions as full voltage overload or short circuit.  Without
      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's position that
      regardless of the results of electrical testing, refurbished
      electrical circuit breakers 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
x
1.    Segregate and retain 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 them 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 or Issues."  The description of cause section in
      the ORPS report should include 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.

Additional Information

The Office of Nuclear Energy has the responsibility for resolving the
suspect/counterfeit parts issue in the Department.  Further guidance as it
is developed will be disseminated to the Field Offices.



This Bulletin is one in a series of publications issued by EH to share
occupational safety information throughout the DOE complex.  To be added
to the Distribution List or to obtain copies of the publication, call
(615)576-3482.
For additional information regarding the publications, call Barbara
Bowers, Safety Performance Indicator Division, Office on Environment,
Safety and Health, U.S. Department of Energy, Washington DC  20585,
(301)903-3016.

**NOTE** Figure  1 is not contained in this document.