United States Nuclear Regulatory Commission - Protecting People and the Environment

Bulletin No. 88-10: Nonconforming Molded-Case Circuit Breakers

                                                       OMB No.:  3150-0011
                                                       NRCB 88-10


                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                      OFFICE OF NUCLEAR REACTOR REGULATION
                             WASHINGTON, D.C. 20555

                                November 22, 1988


NRC Bulletin No. 88-10:  NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS 


Addressees: 

All holders of operating licenses or construction permits for nuclear power 
reactors. 

Purpose: 

The purpose of this bulletin is to request that addressees take actions to 
provide reasonable assurance that molded-case circuit breakers (CBs), in-
cluding CBs used with motor controllers, purchased for use in safety-related 
applications without verifiable traceability1 to the circuit breaker manu-
facturer (CBM) (1) perform their safety functions. 

Description of Circumstances: 

NRC Information Notice No. 88-46, "Licensee Report of Defective Refurbished 
Circuit Breakers," dated July 8, 1988 and Supplement 1 thereto, dated July 21, 
1988, discussed a report by Pacific Gas and Electric Company that indicated 
that its Diablo Canyon Nuclear Power Plant was supplied 30 CBs by Anti-Theft 
Systems, Inc. through a local electrical distributor.  These CBs (Square D 
molded-case, type KHL 36125) were intended for use in non-safety-related 
applications at the Diablo Canyon Nuclear Power Plant.  Square D Company 
reported that an inspection and testing of these breakers determined that the 
CBs were refurbished Square D Company equipment.  Furthermore, Square D 
reported that several of the circuit breakers tested did not comply with 
Square D or Underwriters Laboratories, Inc. (UL) specifications for all of the 
electrical tests performed.  Information Notice No. 88-46 also listed several 
California companies that were involved in supplying surplus refurbished and 
possibly defective refurbished electrical equipment to the nuclear industry. 

During recent NRC inspections, additional examples were identified that 
indicate a potential safety concern regarding electrical equipment supplied to 
nuclear power plants.  The NRC is concerned that equipment being procured as 
new and assumed to meet all applicable plant design requirements and/or 
original manufacturer's specifications may, in fact, not conform to these 
requirements and specifications. 

                         

(1).  Refer to Attachment 2 for Definition of Terms 

8811180315
.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 2 of 7 


The actions requested in this bulletin are limited to molded-case CBs.  
Molded-case CBs are tested and calibrated at the manufacturer's plant in 
accordance with recognized industry standards, such as UL-489, "Molded Case 
Circuit Breakers and Circuit Breaker Enclosures," and National Electrical 
Manufacturers Associ-ation (NEMA)-AB1, "Molded-Case Circuit Breakers."  Since 
molded-case CBs have factory-calibrated and sealed elements, any unauthorized 
modification or refurbishing of these CBs could jeopardize their design 
capability and reliability. 

The NRC is concerned that the reliability and capabilities of refurbished CBs 
purchased as commercial grade (non-Class 1E) for later upgrading to safety-
related (Class 1E) applications may not meet the minimum commercial grade 
standards.  In addition, the NRC is concerned about the reliability and capa-
bilities of commercial grade CBs upgraded to safety-related because of some 
observed inadequacies in the dedication process and numerous failures found 
during the testing of some of these CBs.  In order to properly dedicate 
electrical items procured as commercial grade for subsequent use in safety-
related applications, the dedication process should build from the commercial 
grade quality, include a proper evaluation of seismic and environmental quali-
fication, confirm critical parameters, and include testing as appropriate. 

Molded-case CBs purchased from the CBM or that can be traced to the CBM are of 
lesser concern than other molded-case CBs because CBs from the CBM, whether 
safety-related or commercial grade, are manufactured under controlled 
conditions to conform to a proven design.  Safety-related CBs purchased as 
Class 1E from the CBM are controlled under quality assurance (QA) programs 
that conform to Appendix B of 10 CFR Part 50.  While upgrading programs may 
vary in quality, the controls exercised by the CBM over the manufacturing 
activities provide reasonable assurance that improperly refurbished components 
have not been introduced and passed through the upgrading process.  
Furthermore, the redundancy of safety systems and the in-service use of CBs 
provide a reasonable basis for accepting installed replacement CBs that have 
been procured from the CBM or that can be traced to the CBM. 

The NRC currently believes that the concerns addressed in this bulletin do not
apply to electrical equipment (safety-related and commercial grade) originally 
installed in plants.  This equipment appears to have been procured during 
plant construction from CBMs with full certification.  The large quantities of 
electrical assemblies or components procured under bid packages during plant 
construction reduce the possibility of any original plant equipment being sup-
plied by vendors doing refurbishing. 

Although the actions requested in this bulletin only apply to safety-related 
molded-case CBs, the NRC intends to monitor industry programs to ensure that 
other molded-case CBs, which may have been installed as replacements, 
installed during modifications, or are being maintained as stored spares, are 
suitable for their intended service.  Addressees are encouraged to participate 
in a joint program.  If industry programs are either not timely or not 
sufficient, additional regulatory actions will be taken, as appropriate. 
.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 3 of 7 


The NRC requested and received comments from the Nuclear Management and 
Resources Council (NUMARC), the National Electrical Manufacturers Association 
(NEMA), and the Underwriters Laboratories, Inc. (UL), during the preparation 
of this bulletin. These comments were considered and some were appropriately 
incorporated into this bulletin. 

NEMA has commented to the NRC that determination of the critical performance 
characteristics of durability and short-circuit capabilities of CBs requires 
destructive testing of selected breakers that are representative of CBs to be 
placed in service.  Because a refurbished breaker may not have been 
refurbished under controlled conditions to conform to a proven design, 
destructively testing selected breakers will not infer anything about a 
refurbished CB.  UL provided specific comments on the tests in Attachment 1 of 
this bulletin.  In addition, they stated that, "it is UL's opinion that the 
test program is not adequate to provide assurance that the tested, 
non-traceable, circuit breakers would be suitable for their intended purpose."  
Although the test program described in Attachment 1 of this bulletin does not 
provide complete verification of all the performance requirements and 
characteristics of molded-case CBs (such as seismicity or fault clearing 
capability), the NRC considers the test program to provide a reasonable 
assurance of performance requirements and characteristics most important to 
ensuring reactor safety.  This, considered in conjunction with (1) the limited 
number of nonconforming CBs that may remain installed in safety-related 
systems following implementation of the actions requested by this bulletin, 
(2) the existence of redundant safety-related systems in nuclear power 
reactors that are required by NRC regulations, (3) the license required 
inservice testing of installed CBs performed to demonstrate the CB's 
functional performance, and (4) the low frequency of occurrence of seismic 
events and severe electrical faults, provides a reasonable assurance that 
nuclear power reactors can be operated without undue risk to the health and 
safety of the public. 

The NRC investigation of this issue is not complete.  A supplement to this 
bulletin may be issued to include other electrical equipment or a longer pro-
curement review period if warranted by the results of the ongoing evaluations 
or the results of testing requested in this bulletin. 

Actions Requested:

1.   All addressees are requested to perform the following review by March 1, 
1989:

     a.   Identify all molded-case CBs purchased prior to August 1, 1988, that
          are being maintained as stored spares for safety-related (Class 1E) 
          applications or commercial grade CBs that are being maintained as 
          stored spares for future use in safety-related applications; this 
          includes CBs purchased from a CBM or from any other source.  If the 
          number of these stored spare CBs is less than 50 at a nuclear plant 
          site, then randomly select CBs purchased between August 1, 1983 and 
          August 1, 1988 that have been installed in safety-related applica-
          tions as replacements or modifications to form a minimum sample of 
          50 CBs per nuclear plant site.
.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 4 of 7 


     b.   Verify the traceability of these CBs.  

     c.   Identify the number, manufacturer, model number, and to the extent 
          possible the procurement chain for all those CBs identified in (1a) 
          that cannot be traced to the CBM.  For installed CBs, also identify 
          each system in which they are/were installed.

2.   All holders of operating licenses who identify installed CBs per item 1 
     above or item 4 below that cannot be traced to a CBM are requested to 
     prepare, within 30 days of the completion of each item, an analysis 
     justifying continued operation until items 1 through 5 of the actions 
     requested in this bulletin have been completed.

3.   All addressees who identify 80 percent or more CBs traceable to the CBM 
     per item 1 above are requested to test the CBs that are not traceable to 
     the CBM in accordance with the test program described in Attachment 1.  
     Any installed CBs that fail any of these tests should be replaced with 
     CBs that meet the criteria of item 7 of the actions requested or CBs that 
     pass all tests in accordance with the testing program described in 
     Attachment 1.  If more than 10 percent of the CBs tested fail any of the 
     tests described in Attachment 1, continue with item 4; otherwise, proceed 
     to item 6 of the actions requested.  
          Holders of operating licenses are requested to complete this testing 
     program before startup from the first refueling outage beginning after 
     March 1, 1989.  Holders of construction permits are requested to complete 
     this testing program before fuel load. 

4.   All addressees who identify less than 80 percent of the CBs traceable to 
     the CBM per item 1 above or who identify a failure rate of more than 10 
     percent for the CBs tested per item 3 above are requested to perform the 
     following actions: 

     a.   Identify all molded-case CBs that have been purchased between August 
          1, 1983 and August 1, 1988, and installed in safety-related 
          applications as replacements or installed during modifications. 

     b.   Verify the traceability of these CBs.  

     c.   Identify the number, manufacturer, model number, system in which 
          they are/were installed, and to the extent possible, the procurement 
          chain for all those CBs identified in (4a) that cannot be traced to 
          the CBM. 

5.   All addressees who identify installed CBs that cannot be traced to the 
     CBM per item 4 above are requested to replace these CBs with components 
     that meet the criteria of item 7 of the actions requested or to test them 
     in accordance with the program described in Attachment 1; CBs that fail 
     any of these tests should be replaced with CBs that meet the criteria of 
     item 7 of the actions requested or CBs that pass all tests in accordance 
     with the test program described in Attachment 1.
.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 5 of 7 


     Holders of operating licenses are requested to replace or to test at 
     least one-half, or all if the total number is less than 75, of these 
     installed CBs before startup from the first refueling outage beginning 
     after March 1, 1989.  The remaining CBs should be replaced or tested 
     before startup from the second refueling outage beginning after March 1, 
     1989. 
     
     Holders of construction permits are requested to replace or to test these 
     installed CBs before fuel load.

6.   Information generated while performing the actions requested in items 1, 
     2, 3, 4, and 5 above should be documented and maintained for a period of 
     5 years after the completion of all requested actions. 

7.   With the exception of actions taken in response to items 3 and 5 of the 
     actions requested above, molded-case CBs installed in safety-related ap-
     plications after August 1, 1988 should be:
     
     a.   Manufactured by and procured from a CBM under a 10 CFR 50, Appendix 
          B, program; or

     b.   Procured from a CBM or others with verifiable traceability to the 
          CBM, in compliance with applicable industry standards, and upgraded 
          to safety-related by the licensee or others using an acceptable 
          dedication program.  The NRC encourages addressees to significantly 
          upgrade their dedication programs through a joint industry effort to 
          ensure their adequacy and consistency.  The NRC will monitor these 
          industry initiatives and if they are not sufficient or not timely, 
          or if problems with the dedication of commercial grade equipment for 
          safety-related use continue, the NRC will take appropriate 
          regulatory actions.

8.   Addressees that cannot meet the schedule for the actions requested above 
     and/or the corresponding reporting requirements below, should justify to 
     the NRC their proposed alternative schedule.

Reporting Requirements:

1.   All holders of operating licenses are required to provide a written 
     report by April 1, 1989, that:

     a.   Confirms that only molded-case CBs that meet the criteria of item 7 
          of the actions requested are being maintained as stored spares for 
          future use in safety-related applications.

     b.   Summarizes the total number, manufacturer, model number, and to the 
          extent possible the procurement chain of those CBs that could not be
          traced to the CBM in items 1 and 4 of the actions requested.  For 
          installed CBs, also identify each system in which they are/were in-
          stalled.  If item 4 of the actions requested has not been completed 
          
.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 6 of 7 


          by April 1, 1989, due to the schedule for tests in item 3 of the 
          actions requested, this information should be updated within 30 days 
          of the completion of item 4 to address those additional CBs that 
          could not be traced to the CBM.
     
     c.   Confirms that items 1, 2, 3, 4, 5, 6 and 7 of the actions requested 
          have been completed or will be implemented as requested.

2.   All holders of operating licenses are required to submit a report that 
     summarizes available results of tests conducted in accordance with items 
     3 and 5 of the actions requested within 30 days after startup from the 
     first and second refueling outages beginning after March 1, 1989.  For 
     CBs that pass these tests, the only information required is the number, 
     manufacturer, model number, and to the extent possible the procurement 
     chain of CBs tested (summary report format is acceptable).  For CBs that 
     fail these test(s), these reports should indicate the test(s) and the 
     values of test parameter(s) at which the failure(s) occurred, as well as 
     the corresponding manufacturer, model number, and to the extent possible, 
     the procurement chain.

3.   All holders of construction permits are required to provide a written 
     report by April 1, 1989, that:

     a.   Confirms that only molded-case CBs that meet the criteria of item 7 
          of the actions requested are being maintained as stored spares for 
          future use in safety-related applications.

     b.   Summarizes the total number, manufacturer, model number, and to the 
          extent possible the procurement chain of those CBs that could not be 
          traced to the CBM in items 1 and 4 of the actions requested.  For 
          installed CBs, also identify each system in which they are/were 
          installed.  If item 4 of the actions requested has not been com-
          pleted by April 1, 1989, due to the schedule for tests in item 3 of 
          the actions requested, this information should be updated within 30 
          days of the completion of item 4 to address those additional CBs 
          that could not be traced to the CBM.

     c.   Confirms that items 1, 3, 4, 5, 6 and 7 have been completed or will 
          be implemented before fuel load. 

4.   All holders of construction permits are required to submit a report that 
     summarizes the results of tests conducted in accordance with items 3 and 
     5 of the actions requested within 30 days after fuel load.  For CBs that 
     pass these tests, the only information required is the number, 
     manufacturer, model number, and to the extent possible, the procurement 
     chain (summary report format is acceptable).  For CBs that fail these 
     test(s), the report should indicate the test(s) and the values of test 
     parameter(s) at which the failure(s) occurred, as well as the 
     corresponding manufacturer, model number, and to the extent possible, the 
     procurement chain.

.                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 7 of 7 


The written reports required above shall be addressed to the U. S. Nuclear 
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, 
under oath or affirmation under the provisions of Section 182a, Atomic Energy 
Act of 1954, as amended.  In addition, a copy shall be submitted to the ap-
propriate Regional Administrator. 

This request is covered by Office of Management and Budget Clearance Number 
3150-0011 which expires December 31, 1989.  The estimated burden hour is 1000 
to 10,000 man-hours per plant response, including assessment of these require-
ments, searching data sources, testing, and analyzing the data, and preparing 
the required reports.  Comments on the accuracy of this estimate and 
suggestions to reduce the burden may be directed to the Office of Management 
and Budget, Room 3208, New Executive Office Building, Washington, D.C., 20503, 
and to the U.S. Nuclear Regulatory Commission, Records and Reports Management 
Branch, Office of Administration and Resource Management, Washington, D.C., 
20555. 

If you have any questions regarding this matter, please contact one of the 
technical contacts listed below or the Regional Administrator of the 
appropriate NRC regional office. 




                              Charles E. Rossi, Director 
                              Division of Operational Events Assessment 
                              Office of Nuclear Reactor Regulation 

Technical Contacts:  Paul Gill, NRR
                     (301) 492-0811

                     Jaime Guillen, NRR
                     (301) 492-1170

Attachments:
1.  Test Program for Molded Case Circuit Breakers
2.  Definition of Terms
3.  List of Recently Issued NRC Bulletins

.                                                            Attachment 1 
                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 1 of 4 


                 TEST PROGRAM FOR MOLDED-CASE CIRCUIT BREAKERS 


1.0       Test Program Objectives 
     
          The objective of this proposed test program is to verify the reli-
          ability and capabilities of molded-case circuit breakers (CBs). 
     
          For the safety of personnel and others involved with the activities 
          related to these proposed tests, appropriate safety practices, such 
          as ANSI/NFPA 70E, "Electrical Safety Requirements for Employee 
          Workplaces," Part II, should be followed. 
          
          These proposed tests have been based on tests described in industry 
          standards, such as NEMA AB-1, "Molded-Case Circuit Breakers," NEMA 
          AB-2, "Procedures for Field Inspection and Performance Verification 
          of Molded-Case Circuit Breakers Used in Commercial and Industrial 
          Applications," UL 489 "Molded Case Circuit Breakers and Circuit 
          Breaker Enclosures," and NETA STD ATS-1987, "National Electrical 
          Testing Association, Acceptance Testing Specifications."

2.0       Test Procedures for CBs 
     
          The following tests should be performed in the sequence listed.  CBs
          failing any of these tests should be considered unacceptable for 
          safety-related applications.

2.1       Mechanical Test 
     
          The CB should be operated, reset, and closed a minimum of five 
          times, to ensure that the latching surfaces are free of any binding.

2.2       Individual Pole Resistance or Millivolt Drop Test 
          (Ref. NETA STD ATS-1987 & NEMA AB-2) 
     
          The contact resistance of each pole of the CB should be measured at 
          ambient temperature.  Three readings of each pole should be taken 
          with the CB operated without load between each reading.  The average 
          of three readings for each pole should be calculated and compared 
          with the manufacturer's contact resistance data or with those values 
          of similar CBs from the same manufacturer.  Also, the average value 
          for each pole should be compared with the average of the other poles 
          and the difference between the pole values should not exceed 50 
          percent of the lowest value; or

          A millivolt drop test may be performed by applying a direct current 
          across the closed CB contacts and measuring the voltage drop due to 
          the contact resistance.  The millivolt drop test should be performed 
          at room temperature.  Direct current should be applied across each 
     .                                                            Attachment 1 
                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 2 of 4 
     
     
          pole and the millivolt drop and test current recorded for each pole.
          Three readings of each pole should be taken with the CB operated 
          without load between each reading.  The average of the three 
          readings for each pole should be calculated and compared with the 
          manufacturer's value for acceptance of the breaker.

2.3       Rated Current Hold-In Test (Ref. NEMA AB-1 & UL 489) 
     
          This test should be conducted at 100% rated current and at an 
          ambient air temperature of 25øC ñ 3øC, and followed by a test at 
          135% rated current and at an ambient temperature of 25øC ñ 3øC. 
          
          Equal 100% rated currents should be applied to all poles of the CB. 
          The CB must not trip within 1 hour for CBs rated 50 amperes or below
          or within 2 hours for CBs rated over 50 amperes during this test.  
          At the end of the 100% rated current test, the current should be 
          increased to 135% and the CB should trip within 1 hour for CBs rated 
          50 amperes or below or within 2 hours for CBs rated over 50 amperes.

2.4       Overload Test (Ref. NEMA AB-1 & UL 489) 
     
          This test consists of one operating cycle (i.e., closing action 
          followed by an opening action) of the CB at 600% rated current.  
          This test may be conducted at low voltage.  There should be no 
          electrical or mechanical breakdown of the CB during this test.

2.5       Instantaneous Trip Test (Ref. NEMA AB-1 & UL 489)

2.5.1     Fixed Instantaneous Setting CBs 
     
          Each pole of the CB should be tested for pickup of the instantaneous 
          unit.  Each pole must be between 75% and 125% of the instantaneous 
          trip rating.  The trip time should not exceed 0.1 seconds (6 
          cycles).

2.5.2     Adjustable Instantaneous Setting CBs 
     
          This test is the same as that in Section 2.5.1 except that each pole 
          must be tested at the lowest and highest settings. 
     
          The trip value for the lowest setting should be between 75% and 125% 
          of the lowest setting, and the highest setting should be between 80% 
          and 120% of the highest setting.

2.5.3     Short-Time Trip Setting Test 
     
          This test is applicable only if the CB is equipped with the short-
          time delay trip.  This test should be conducted at an ambient air 
          temperature of 25øC ñ 3øC.  The operation of the short-time delay 
          unit should be within 90% and 125% of the overcurrent setting of 
          the CB as shown on the manufacturer's time-current curves. 
     
.                                                            Attachment 1 
                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 3 of 4 


2.6       Time Delay Overcurrent Trip (Ref. NEMA AB-2) 
     
          This test should be conducted at an ambient air temperature of 
          25øC ñ 3øC. 
     
          A current of 300% (at low voltage) of the marked rating should 
          be applied to each pole of the CB.  The trip time for each pole 
          should be compared with the time shown in the CB manufacturer's 
          time-current curves.  If the test trip times obtained for each pole 
          are not within the time band shown on the CB manufacturer's time-
          current curves, then the test trip must not exceed the time 
          specified in Table 1 and the acceptance of the CBs must be evaluated 
          with the criteria listed below:


                                     TABLE 1
                        VALUES FOR OVERCURRENT TRIP TEST
            (AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)
                                (REF. NEMA AB-2)


   Breaker                      Range of Rated 
   Voltage                    Continuous Current              Maximum Tripping 
    Volts                          Amperes                    Time In Seconds 

    240                              15-45                           50 
    240                             50-100                           70 

    600                              15-45                           70 
    600                             50-100                          125 

    240                            110-225                          200 
    240                            250-400                          300 

    600                            110-225                          250 
    600                            250-400                          300 
    600                            450-600                          350 
    600                           700-1200                          500 
    600                          1400-2500                          600 
    600                          3000-5000                          650 

          Minimum Tripping Time:     If the minimum tripping times are lower 
          than indicated by the manufacturer's time-current curves for the 
          CB under test, the CB should be retested after it has been cooled 
          to 25øC.  If the values obtained are still lower after retest, the 
          coordination with upstream and downstream CB should be evaluated.  
          If no problem with coordination is indicated, then the CB is ac-
          ceptable. 
     
     
.                                                            Attachment 1 
                                                            NRCB 88-10 
                                                            November 22, 1988 
                                                            Page 4 of 4 


          Maximum Tripping Time:   If the tripping time exceeds the maximum 
          tripping time shown on the manufacturer's time-current curves but 
          is below the time shown in Table 1, check the CB time against the 
          protection requirements of the circuit (such as cable, penetration, 
          etc.) to ensure that the CB provides the protection, as well as the 
          coordination with upstream and downstream CBs.  If the CB provides 
          the necessary protection and coordination, then the CB is 
          acceptable.

          Maximum Allowable Time:  If the tripping time of the CB exceeds the 
          trip time shown in Table 1, the breaker is unacceptable for Class 1E
          applications.

2.7       Dielectric Tests (Ref. NEMA AB-1 & UL-489) 
     
          The dielectric test should be conducted at an ac test voltage of 
          1760 volts (80% x [2 x rated voltage + 1000 volts]), or at 2500 
          volts dc for 1 minute withstand.  The dielectric test should be 
          conducted for (1) line to load terminals with CB open, (2) line to 
          line terminals with CB closed, and (3) pole to ground with CB open, 
          and (4) pole to ground with CB closed.


.                                                            Attachment 2 
                                                            NRCB 88-10 
                                                            November 22, 1988 


                               DEFINITION OF TERMS


CIRCUIT BREAKER MANUFACTURER (CBM) 

The manufacturing facility that actually produced the circuit breaker being 
purchased. 

VERIFIABLE TRACEABILITY 

Documented evidence such as a certificate of compliance that establishes 
traceability of purchased equipment to the CBM.  If the certificate of 
compliance is provided by any party other than the CBM, the validity of such 
certificate must be verified by the licensee or permit holder through an audit 
or other appropriate means. 

DEDICATION PROCESS 

The process by which commercial grade (non-Class 1E) equipment is upgraded to 
safety-related (Class 1E) and is thereby considered qualified for use in 
safety-related applications.  The dedication process must include: 

a.   A technical evaluation to determine the characteristics critical 
     to fulfilling the safety function(s). 

b.   An acceptance process to ensure that those critical characteristics 
     are met. 
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