ML16075A285

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

WASHINGTON, DC 20555-0001

July 15, 2016

NRC INFORMATION NOTICE 2016-09: RECENT ISSUES IDENTIFIED WHEN USING 

REVERSE ENGINEERING TECHNIQUES IN THE 

PROCUREMENT OF SAFETY-RELATED 

COMPONENTS

ADDRESSEES

All holders of, and applicants for, a construction permit or an operating license for a non-power 

reactor (research reactor, test reactor, or critical assembly) or a medical isotope production 

facility under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing 

of Production and Utilization Facilities,” except those that have permanently ceased operations.

All holders of an operating license or construction permit for a nuclear power reactor issued 

under 10 CFR Part 50, except those that have permanently ceased operations and have 

certified that fuel has been permanently removed from the reactor vessel.

All holders of, and applicants for, a power reactor early site permit, combined license, standard 

design approval, or manufacturing license under 10 CFR Part 52, “Licenses, Certifications, and 

Approvals for Nuclear Power Plants.” All applicants for a standard design certification, including 

such applicants after initial issuance of a design certification rule.

All contractors and vendors that directly or indirectly supply basic components to U.S. Nuclear 

Regulatory Commission (NRC) licensees under 10 CFR Part 50 or 10 CFR Part 52.

PURPOSE

The NRC is issuing this information notice (IN) to inform addressees of issues that the NRC 

staff has identified concerning the supply of replacement safety-related components. 

Specifically, this IN describes instances where reverse engineering techniques were used to 

manufacture replacement components, and where the components were supplied without first 

verifying the supplied components met all safety-related design requirements. The NRC 

expects that recipients will review the information for applicability to their facilities and consider 

actions, as appropriate, to avoid similar problems. Suggestions contained in this IN are not NRC

requirements; therefore, the NRC requires no specific action or written response.

DESCRIPTION OF CIRCUMSTANCES

During recent inspections, the NRC identified deficiencies in certain aspects of licensees’ and 

vendors’ quality assurance programs. These quality assurance programs are intended to 

ensure that safety-related components can be relied upon to function, as necessary, to meet 
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their intended requirements. In some instances, reverse engineering techniques were used to 

manufacture and supply components without first developing a full understanding of the 

components’ safety-related design requirements.

This IN provides examples where licensees and suppliers used reverse engineering techniques 

to manufacture and supply safety-related equipment, but did not implement sufficient controls to 

verify that equipment was suitable for its intended application. In these examples, the suppliers 

and/or licensees were unable to provide reasonable assurance that the supplied component 

would be capable of operating on demand for the required life of the component and under the 

full range of operating and accident conditions. This led to licensees installing components that 

were not suitable for its intended application or that had indeterminate suitability at the time of 

installation. In one example, this led to a failure of the component to operate on demand during

a plant event.

The list below provides a summary of the deficiencies that NRC inspectors identified as a result 

of the procurement of reverse engineered components:

• not developing a full understanding of design requirements

• assuming that a reverse-engineered component is identical to the original equipment 

manufacturer (OEM) component, even though it was not subject to the same design 

and manufacturing specifications and processes as the original component

• assessing only the physical attributes of the component without properly evaluating

functional design requirements

• not passing on all relevant design requirements to the supplier

• not verifying that all safety-related design requirements have been met, either by 

testing or analysis or a combination of the two

• not clearly establishing which organization is responsible for which portion of the 

reverse engineering process

During recent NRC inspections, inspectors identified the following specific examples of improper

reverse engineering of safety-related components.

1. The NRC identified a non-cited violation of 10 CFR Part 50, Appendix B, “Quality

Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,” Criterion 

III, “Design Control,” at Callaway Plant, Unit No. 1 for failure to assure that the design of 

the replacement reverse-engineered Modutronics controller cards used for the auxiliary 

feedwater control valves were suitable for their application. Specifically, the licensee 

failed to establish suitable interface requirements in procurement documents to Nuclear 

Logistics Incorporated (the vendor). The licensee also failed to verify (or ensure their 

supplier had verified), by either design reviews or testing, that the supplied 

reverse-engineered controller cards were suitable for their application. As a result, the 

replacement cards were supplied with motor field current rectifier bridges that were 

undersized and marginal for their application. Consequently, two of the circuit cards 

failed in service, rendering the associated auxiliary feedwater system valves inoperable. 

Following performance of a root cause analysis, the licensee replaced the deficient 

controller cards with those of a higher current rating. [NRC Inspection Report 

05000483/2015009, dated January 13, 2016 (Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML16013A021)]

2. The NRC identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, 

“Design Control,” at River Bend Station, Unit 1 for the failure to verify the adequacy of 
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the design of replacement accumulators, 18 of which were installed in the control rod 

drive system. The accumulators were reverse engineered, purchased from a 

commercial supplier (Tobul Accumulator), and dedicated for use as a basic component; 

however, the licensee’s technical justification for the acceptability of the 

reverse-engineered component was inadequate. The equivalency evaluation failed to 

verify the adequacy of safety-related design requirements related to the performance of 

the accumulators, such as flow rates, leakage rates, pressure ranges of operation, 

stroke times, temperature ranges of operation, and seismic qualification. [NRC 

Inspection Report 5000458/2015002, dated August 11, 2015 (ADAMS Accession No.

ML15223B344)]

3. The NRC identified a nonconformance to 10 CFR Part 50, Appendix B, Criterion III, 

“Design Control,” at NOVA Machine Products Inc. for its failure to establish adequate 

design control measures to verify and check the adequacy of the design of hydraulic 

control unit (HCU) accumulators used in the control rod drive system of boiling-water 

reactors. Specifically, NOVA reverse engineered and subsequently manufactured 

approximately 881 safety-related HCU accumulator assemblies without proper design 

verification in the form of a design review, use of calculational methods, or through a 

suitable qualification testing program. [NRC Inspection Report 99901052/2015-201, 

dated January 15, 2016 (ADAMS Accession No. ML16006A394)]

In response to the above identified deficiencies, licensees and vendors entered the deficiencies 

into their corrective action programs and took appropriate corrective measures.

BACKGROUND

The regulations in 10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power

Plants and Fuel Reprocessing Plants,” Criterion III, “Design Control,” require that licensees, 

vendors, and contractors establish measures for the selection of parts and equipment essential

to the safety-related functions of structures, systems, and components. Criterion III also

requires that licensees, vendors, and contractors establish measures for verifying the 

adequacy of the design, such as by the performance of design reviews, by the use of alternate 

or simplified calculation methods, or by the performance of a suitable testing program. Vendors

and contractors that supply safety-related components to licensees are required to adhere to

these requirements when imposed on them by NRC licensees through contractual requirements.

DISCUSSION

For various reasons, including obsolescence, cost, and extended delivery schedules, licensees 

and their suppliers are increasingly using reverse engineering techniques to manufacture 

replacement safety-related components. While there is no regulatory definition of reverse 

engineering, it can be considered a process (or set of processes) to help manufacture or 

replicate a component based upon physically examining, measuring, or testing existing items; 

reviewing technical data; or performing engineering analysis.

1

 When all safety-related design 

requirements, are well understood and documented, the process is not unlike a normal 

safety-related procurement for an alternate component. In many cases, licensees use an 

equivalency evaluation process to verify the new proposed component is suitable for its 

application (i.e., meets all relevant safety-related requirements).

 1 Definition taken in part from EPRI TR 107372, “Guideline for Reverse Engineering at Nuclear Power Plants,” 

July 1998.
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In some instances, however, the full scope of the safety-related requirements for the component 

is unknown and has to be regenerated. Various engineering methods can be used to help 

regenerate component-specific requirements. This can be accomplished through a review of 

relevant system and component-level design information, including information obtained from 

original equipment manufacturers (OEM), through the performance of new calculations, or 

through testing and/or examination of the original component.

While physical examination and material analysis of an OEM component may be sufficient to 

define the physical characteristics necessary to create a physically equivalent component 

design, physical examination alone is typically not sufficient to identify all the functional 

requirements. Identifying all functional requirements necessitates a full understanding of the 

intended application of the component, interface requirements, environmental parameters, and 

other design considerations. Although not explicitly required, recipients are encouraged to

review the information and references provided in this IN for applicability and consider actions, 

as appropriate, for their facilities to avoid similar problems. 

CONTACT

This IN requires no specific action or written response. Please direct any questions about this 

matter to the technical contact listed below.

/RA/ /RA/

Michael C. Cheok, Director Louise Lund, Director

Division of Construction Inspection Division of Policy and Rulemaking

 and Operational Programs Office of Nuclear Reactor Regulation

Office of New Reactors

Technical Contact: Jeffrey Jacobson, NRO

Phone: 301-415-2977

E-mail: Jeffrey.Jacobson@nrc.gov

Note: NRC generic communications may be found on the NRC’s public Web site,

http://www.nrc.gov, under NRC Library/Document Collections.
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In some instances, however, the full scope of the safety-related requirements for the component 

is unknown and has to be regenerated. Various engineering methods can be used to help 

regenerate component-specific requirements. This can be accomplished through a review of 

relevant system and component-level design information, including information obtained from 

original equipment manufacturers (OEM), through the performance of new calculations, or 

through testing and/or examination of the original component.

While physical examination and material analysis of an OEM component may be sufficient to 

define the physical characteristics necessary to create a physically equivalent component 

design, physical examination alone is typically not sufficient to identify all the functional 

requirements. Identifying all functional requirements necessitates a full understanding of the 

intended application of the component, interface requirements, environmental parameters, and 

other design considerations. Although not explicitly required, recipients are encouraged to

review the information and references provided in this IN for applicability and consider actions, 

as appropriate, for their facilities to avoid similar problems. 

CONTACT

This IN requires no specific action or written response. Please direct any questions about this 

matter to the technical contact listed below.

/RA/ /RA/

Michael C. Cheok, Director Louise Lund, Director

Division of Construction Inspection Division of Policy and Rulemaking

 and Operational Programs Office of Nuclear Reactor Regulation

Office of New Reactors

Technical Contact: Jeffrey Jacobson, NRO

Phone: 301-415-2977

E-mail: Jeffrey.Jacobson@nrc.gov

Note: NRC generic communications may be found on the NRC’s public Web site,

http://www.nrc.gov, under NRC Library/Document Collections.

ADAMS Accession No.: ML16075A285; *via e-mail

OFFICE NRR/PGCB/LA* Tech Editor* NRO/DCIP/QVIB-1* NRO/DCIP/QVIB-1/BC* NRR/PGCB/PM*

NAME ELee (w/comment) CHsu JJacobson TJackson BHarris

DATE 03/17/2016 03/31/2016 06/06/2016 06/09/2016 06/06/2016

OFFICE NRR/PGCB/LA NRR/PGCB/BC NRO/DCIP/D NRR/DPR/D

NAME ELee (ABaxter) SStuchell MCheok LLund

DATE 06/09/2016 06/09/2016 07/12/2016 07/15/2016

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