ML19310A546
| ML19310A546 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1980 |
| From: | Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19310A543 | List: |
| References | |
| REF-QA-99900308 99900308-80-1, NUDOCS 8006200135 | |
| Download: ML19310A546 (14) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900308/80-01 Company: ACF Industries, Inc.
WKM Valve Division 16500 South Main Street Missouri City, Texas 77459 Inspection Conducted: March 5-7, 1980 Inspector:
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,o Wm. D.~Kelley, Contractor Inspector Date ComponentsSection I Vendor Inspection Branch A
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D. E. Whitesell, Chliif Date ComponentsSection I Vendor Inspection Branch Summary Inspection on March 5-7, 1980 (99900308/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B and applicable codes and standards by review of two 10 CFR 50.55(e) reports and one 10 CFR 21 report and vendor's corrective action. Also performed review of vendor's activities and conducted exit interview. The inspection involved thirty-cwo (32) inspec-tor hours on site by two (2) NRC inspectors.
Results:
In the four (4) areas inspected, no deviations were identified.
Unresolved Item: The vendor has insufficient information concerning the i
application of each valve to perform a meaningful evaluation as to the safety significance of the customer reported defects and plan the positive corrective action to be taken (Details, paragraph E).
800620013 5
2 DETAILS SECTION A.
Persons Contacted ACF Industries - WKM Valve Division (WKM)
- J. R. Brinkley - Manager, Product Engineering
- W. C. Cook - Supervisor, Quality Control
- R. V. Hopkins - Special Assistant to Director of Engineering
- E.
M.
Hughes - QA Supervisor
- H. M. Jackson - Project Coordinator Special Products
- J. D. Jackson - Director of Special Products
- J. S. John - Manager of Engineering Information Services
- 0. McDaniels - Supervisor Contracts Administration
- C. Morcate - Manager Quality Assurance D. Thawani - QA Engineer
- Denotes those persons who attended the Exit Interview (See paragraph F).
B.
General Review of Vendor's Activities 1.
The ASME issued the following Certificates of Authorization to WKM to use their symbol:
Certification No.
Symbol Product N-1942 N
Class 1, 2, & 3 valves N-1943 NPT Class 1, 2, & 3 valve parts and piping subassemblies 1
These certificates expire on November 18, 1980.
2.
The authorized inspection agency is la:rtford Steam Boiler Inspection and Insurance Company. The authorized nuclear inspector is an itin-erant inspector.
3.
WKM's contribution to the nuclear industry represents approximately one percent (1%) of its total workload.
4.
WKM is not actively soliciting new contracts for valves intended for nuclear service.
C.
Follow-up on 10 CFR 50.55(e) Report by Southern California Edison Company 1.
Background Information
3 The Southern California Edison Company (SCECO) reported in their letter of November 14, 1979, to NRC IE RV that they had identified the condition of incorrect material used for a retaining clip in the thermal pressure relief in certain WKM gate valves installed in certain safety systems of San Onofre Nuclear Generating Station, Units 2 and 3, and they considered the item reportable in accor-dance with 10 CFR 50:55(e).
2.
Objectives The objectives of this area of the inspection were to ascertain whether SCECO's report of the defect was adequate and in conformance with the requirements of 10 CFR 50.55(e). Also to ascertain the generic implications of this problem and whether the corrective actions taken by SCECO and WKM were appropriate and had been completed and documented.
3.
Method of Accomplishment The objectives of this area of the accomplished by:
Review of the following documents:
a.
(1) SCECO's letter of December 12, 1979, to NRC IE RV Subject " Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3" (2) SCECO's " Final Report on Improper Retainer Clip Material in Thermal Pressure Relief Valves Installed in WKM Gate Valves - San Onofre Nuclear Generating Station, Units 2 and 3" (3) NRC-IE:RV's letter dated December 28, 1979, to SCECO, Subject " Final Report on Improper Retainer Clip Material in Thermal PRVs installed in WKM Gate Valves San Onofre Nuclear Generating Station, Units 2 and 3 (your letter of December 12, 1979)"
(4) WKM's letter dated September 6, 1979, to Bechtel Power Corporation.
Subject - None (5) Marotta Scientifies Controls, Inc.'s (MSCI) letter of July 17, 1979 to WKM, Subject, " Replacement of Retaining Ring Part 4190801-5009" l
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-Review of these documents was made to ascertain whether the i
reporting of the defect was in compliance with 10 CFR l
50.55(e), accurately described the defect and included i
all pertainent information, and whether the timing of the report was consistent with the requirements.
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4 b.
Review of the following documents:
(1) MSCO's letter dated July 17, 1979, to WKM Subject,
" Replacement of Retaining Ring Part 4190801-5009" (2) WKM's letter dated August 21, 1979, to Babcock and Wilcox Subject, "Marotta Relief Valve Retaining Ring" (3) WKM's letter dated September 6, 1979, to Bechtel Power Corporation Subject - None.
(4) WKM Sales Order Summary o
(a) 38301 Southern California Edison (b) 34661 Southern California Edison (c) 25058 Babcock and Wilcox PGE (d) 25061 Babcock and Wilcox WPPSS (e) 14909 EBASCO Florida Power and Light (5) WKM's Nonconformance Report 1674 dated 7-24-79 Description "Marotta Pressure Relief Element Assy. No. 284921-9001" (6) WKM approved Vendor's List Review of these documents was made to ascertain whether WKM, upon notification of the incorrect material by MSCI, evaluated the report in accordance with their procedure for evaluating and reporting defects in accordance with 10 CFR 21.
Discussed with WKM cognizant personnel concerning the cause, c.
effect, and evaluation of the safety significance of the defect.
4.
Findings From the documents reviewed and discussions with cognizant a.
personnel, the following was determined.
(1) MSCI, the supplier of the pressure relief valve, had been surveyed by WKM quality assurance department and was an approved supplier. Also, MSCI has a valid ASME Certi-ficates of Authorization for use of the "N" and "NPT" stamps.
5 (2) MSCI notified WKM by letter dated July 17, 1979, that in error they had supplied a carbon steel Retaining Ring, Part No. #4190801-5009 in lleu of the correct part number
- 4190801-2009 which is corrosion resistant.
(3) WKM issued nonconformance. report NCR No. 1674 on July 24, 1979, and the Material Review Board evaluated the substitu-tion of carbon steel part on August 3, 1979, as not report-able under 10 CFR 21 because it "Will not create substantial safety hazard in valve. Ask customer to evaluate effect and advise."
l (4) WKM notified Bechtel Power Corporation (BPC) by letter dated 1
September 6, 1979, and B&W in telephone conversation and by letter on August 21, 1979, that they had been advised by
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MSCI of the substitution of the carbon steel part in valves that had been delivered to them on sites.
(5) SCECO issued a 10 CFR 50.55(e) report to NRC-IE:RV on November 14, 1979, and the " Final Report on Improper j
Retainer Clip Material in Thermal Pressure Relief Valves 5
Installed in WKM Gate Valves, San Onofre Nuclear Genera-tion Station, Units 2 and 3," on December 12, 1979. The report identified the valves requiring corrective action y
and type of acceptable correction action.
(6) WKM supplied to BPC parts for the corrective action on SCECO's San Onofre Nuclear Generating Station and BPC completed the correction action under their site quality assurance program nonconformance report system.
(7) WKM requested B&W to ship the valve at the Washington Public Power Supply System site to their plant for correc-tive action. WKM's correction action was to amend the travelers to record the replacement and inspection of the replacement of the carbon steel retaining clip. The retain-ing clip wa.s replaced with the correct stainless steel retaining clip and the traveler was signed off by the WKM inspector, the customers representative and the authorized nuclear inspector.
(8) WKM modified their travelers identifying the correct part number.for the valves in production for B&W (Pacific Gas and Electric Co.) and Ebasco (Florida Power ano Light) and the correct part was installed in these valves.
b.
Within this area of the inspection no deviations or unresolved items were identified.
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Corrective Action WKM met with MSCI tc review the cause and corrective action and MSCI's quality control system and their conclusions were:
(1) Human error was involved in that a carbon steel retaining ring which was used in the prototype and the improper part number was transferred to the final production drawing.
(2) MSCI followed their quality assurance program but the error was not caught.
(3) The retaining rings were commercially obtained parts and since the part number suffix was in error, the wrong material was received. Material traceability of this part was not required.
(4) MSCI has rechecked the design and their bill of materials and they are currently correct.
4 D.
Follow-up on 10 CFR 50.55(e) Report by Washington Public Power Supply System i
1.
Background Information The Washington Public Power Supply System (WPPSS) reported in a telecon of February 4, 1979, to NRC-IE RV that they had identified a
the possibility of the WKM Pow-R-Seal parallel seat gate valve body cavities becoming over pressurized in the open position with an increase in fluid temperature and they evaluated the condition as a reportable deficiency in accordance with 10 CFR 50.55(e).
2.
Objectives The objectives of this area of the inspection were to ascertain whether the WPPSS's report of the defect was adequate and in conformance with the requirements of 10 CFR 50.55(e). Also to ascertain the generic implication of this problem and whether the corrective actions taken by B&W, WPPSS, and WKM were appropriate and had been completed and documented.
4 3.
Method of Accomplishment s
The objectives of this area of the inspection were accomplished by:
Review of the following documents:
a.
(1) Babcock and Wilcox's (B&W) letter of December 12, 1978, 3
to WPPSS subject "WPPSS Nuclear Project 1/4, Report of Safety Concern, PSC 16-78"
7 (2) WPPSS's letter of March 9, 1979, to NRC IE RV Subject "WPPSS Nuclear Project Nos. 1/4, Docket Numbers 50-460 and 50-513, Reportable Condition 10 CFR 50.55(e), WKM Valve Overpressurization."
Review of these documents was made to ascertain whether the report of the defect was in compliance with 10 CFR 50.55(e),
accurately described the defect and included all pertinent information, and whether the timing of the report was con-sistent with the requirements.
b.
Review of the following documents:
(1) B&W Field Change Authorization 620, 04-3030-00 dated November 6, 1978, Title " Gate Modification" (2) B&W Purchase Order 033703LF dated March 27, 1979, Change Order #1 to WKM for Field Services (3) WKM Sales Order A-15445 dated May 7,1979, for modifi-cation of B&W purchase valves (4) WKM drawing RS-241262 Revised September 17, 1979, titled "4 Class 1600 Model M-1 Pow-R-Seal" (5) WKM drawing RS-241259 Revised September 17, 1979, titled "14 X 12 X 14 Class 1500 Model D-2 Pow-R-Seal" (6) WKM Invoice No. 1143227 dated May 15, 1979, to B&W Review of these documents was made to ascertain whether WKM, upon notification by B&W of the possibility of the overpres-surization of the Pow-R-Seal gate valve body cavity, with the valve in the open position and an increase in fluid temperature, evaluated the problem as reportable in accordance with the requirements of 10 CFR Part 21.
Also, to ascertain if the generic implication of this problem had been evaluated and whether the corrective actions taken by B&W, WPPSS, and
'iKM were appropriate and had been completed and documented.
Discussions with WKM cognizant personnel concerning the cause, c.
effect, and evaluation of the safety significance of the WPPSS reported deficiency in accordance with 10 CFR 21.
4.
Findings From the documents reviewed at the WKM plant and discussions with WKM cognizant personnel and the documents reviewed at IE
8 RIV office, the following was determined:
a.
A meeting between representatives of B&W and WKM was held at the WKH's Missouri City, Texas plant on November 3, 1979, to discuss the possibility of the over pressurization of the Pow-R-Seal valve cavities in the open position.
B&W's " Report on Safety Concern" states that WKH had claimed that ample pressure relief was provided when the valve was in the open position by leakage between the mating surfaces of the segment and the gate; however, they could not guarantee that there was ample leakage to prevent pressure buildup.
b.
WKM convened their Material Review Board (MRB) and evaluated the B&W concern of possible pressurization of the valve cavity and concluded that it was not an item reportable in accordance with the requirements of 10 CFR Part 21.
Also, the MRB concluded that the possible pressurization was not a generic problem.
c.
B&W transmitted their Field Change Notice 04-3030-00 to United Engineers & Constructors Inc. (UE&C) by their letter dated November 13, 1978, instructing them to modify the following WKM valves in the field.
Valve Tag No.
WKM Valve Size Serial No.
CF-VIA 495389 14X12X14 CF-VIB 495390 14X12X14 DH-VIA 495399 12X8X12 DH-VIB 495400 12X8X12 DH-VIIA.
495403 12X8X12 DH-VIIB 495404 12X8X12 DH-V12B 495408 12X8X12 The modification required a 1/16 inch diameter hole to be drilled through the bottom of disc opening with a counter bore of 3/16 inch in diameter.
The field change was to be coordinated by B&W's Erection Consultant.
1
9 d.
B&W notified WPPSS by letter dated December 12, 1978, that the B&W Licensing Section had made the determination that the WKM Pow-R-Seal gate valves did nce. have positive pro-visions to prevent pressurzation of the valve cavity with the valve in the open position and an increase in fluid temperature.
The B&W Licensing Section report states, "The basis for reportability is that, as defined by the regulations, there potentially is a significant defi-ciency in the final design approval and release for construction, and that the deficiency, wera it to remain uncorrected, could adversely affect safe operation of the plant."
WPPSS notified NRC IE:RV in a telecon on January 10, 1979, e.
of a potential reportable item in accordance with the requirements of 10 CFR 50:55(e) concerning the WKH Power-Seal valves having a tendency to over pressurize the body cavity during heatup with the valves in the open position.
5.
Corrective Action After the meeting with B&W personnel on November 3, 1978, in a.
which the possibility of the overpressurization of the valve cavity was discussed. WKM convened their haterial Review Board (MRB).
The MRB evaluated that the possibility of the overpressurization of the valve cavity was not a safety item nor a generic problem for the Pow-R-Seal valves that had been shipped or were in the process of man facturing, assembly, and/or testing; therefore, it was not reportable under either 10 CFR 21 or 10 CFR 50:55(e) and no corrective action was required.
b.
B&W issued their Purchase Order 033703LF dated March 27, 1979, Change Notice #1 to WKM to provide their field service per-sonnel to accoc:plish the modification of the WKM Pow-R-Seal valves in accordance with their Field Change Authorization 04-3030-00.
c.
On February 12, 1979, WPPSS in a telephone conversation with NRC IE:RV confirmed that the possibility of the overpressuration of the body cavity was a reportable item.
i d.
B&W issued their Purchase Order 033703LF dated March 27, 1979, with Change Order #1 to WKM to furnish their field services on site for the modification of the affected valves. WKM completed the modification of the eight (8)
10 valves and issued Invoice Number 1443227 to B&W on May 15, 1979, for payment.
The WKM shop travelers was for an addition fifteen valves in the plant were revised and the valves modified in accordance with B&W requirements during the normal course of manufacturing.
e.
Within this area of the inspection no deviations or unresolved items were identified.
E.
Defects in Safety Related Valves 1.
Background Information
_ On February 26, 1980, TVA t'elephoned NRC RII to report that they
'had been notified by Babcock and Wilcox (B&W) of defects found in a safety related valve which had been purchased by B&W for Washington Public Power Supply System (WPPSS).
Since similar valves had been purchased from WKM by B&W for TVA's Bellefonte, these valves are now suspected of containing similar defects.
These defects were identified by WPPSS during the ASME Section XI preservice base line survey.
The indications were identified in the decay heat removal system isolation valves, two (2) in Uait I, and four (4) in unit 4.
These valves are Class 1 valves.
Rej ectable indications were also identified by WKM inside the body of a Class 2 core flooding system isolation valve which had been returned to them for the rework of an internal relief valve (reference paragraph C above).
2.
Obj ectives:
The objectives of this area of the inspection were to ascertain the following:
Why these defects were not identified during in-process a.
inspection (s).
b.
Corrective action taken to return to code requirement.
The;cause of the defect and corrective action to prevent c.
recurrence.
d.
Generic impact.
Safety evaluation to determine reportability under 10 CFR 21.
e.
3.
Method of Accomplishment To accomplish the preceding objectives, the following records were reviewed.
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l 11 a.
The Processing Check List Index, to ascertain the identifica-tion of the foundry furnishing the castings, the identifica-tion of the foundry's serial number (S/N) for the casting furnished, and the type, grade and heat number of the material furnished. The following information was obtained:
(1) The foundry was PRL Industries, Inc. (PRL) of Cornwall, Pennsylvania, FRL's S/N 289; ASME SA 351, grade CF8M, Heat No. 70716 F-2 (2) PRL CMTR for the material and for upgrading the castings to comply with ASME Section III for Class I castings.
(3) PRL Radiography Inspection Report, dated 3/29/78, which reported rejectable indications had been identified in 5 l
film areas of the 10 film areas required for the 100%
volumetric examination.
(4) PRL Penetrant Examination Report dated 3/14/78 which identified 57 indications of which 18 were reported to be major and the balance minor indications.
There was no documentation to explain the classification of defects as being major or minor but did identify the defects as being linear, dirt, or gas.
(5) Review of PRL Processing Sheets for Pattern No. 252589.
(6) Review of CMTR for the weld metal used in the weld repairs.
(7) PRL Heat Treat Report, dated 4/21/78, for the solution annealing of SA351 grade CF8M materials Heat no. 70716F-2 used in casting S/N289.
(8) The WKM Penetrant Examination sheets on WKM S/N 495-407, Tag No. V12A purchased by B&W for WPPSS.
Acceptance criteria to Procedure 73-0014/M906, Paragraph 10.2 PE Report for the following surfaces:
Body, dated 7/7/78 Body Lug Area, dated 7/7/78 Body Lift Eye, dated 7/7/78 Body Machined Surface, dated 7/7/78 Body Machined Weld Prep, dt.ted 7/2/78 Body Lower Girth Weld, dated 6/26/78 Machined upper Girth, dated 6/21/78 Machined lower weld prep, dated 6/19/78 m,2
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Machined Upper end weld prep, dated 5/26/78 Upper Section Weld prep, dated 5/18/78 Lower Section Weld prep, dated 6/1/78 Lower Section Weld support ring, dated 5/20/78 Drain Plug Machining, dated 8/5/78 1
Bonnet Machining, dated 6/19/78 l
Bonnet Machining, dated 5/19/78 Gate and Segment Machining, dated 7/3/78 It was observed that all of the foregoing examinations recorded the part(s) to be acceptable and had been veri-fied, stamped and dated by both the level II examiner and B&W, the customer.
(9) Radiography Inspection Reports as follows:
Body, accept Girth Welds, Upper, accept Girth Welds, Lower, accept Power Seal, Upper, accept Power Seal, Lower, accept Bonnet Assy., accept 8" Gate, accept It was observed that the foregoing reader sheets were properly signed by the Level II Examiner and verified by B&W and the ANI, for valve S/N 495407 (10) The Dimension Check Reports of valve S/N 495407, for the upper and lower sections of the Body, and for the Bonnet.
All measurements were recorded and the minimum thickness (tm) was given for each measurement made.
It was noted that all of the actual dimensions exceeded the required dimensions.
(11) Review of the Hydrostatic Pressure Test Report dated 11/2/79.
The report identified Procedure No. 36-0105, Revision N663, and identified by serial number the gages used for the tests, and the test media to be water at a temperature of 60 F t.
The results were as follows:
Shell Test, 6000 psi for 40 minutes.
No leaks.
Seat Test, 4000 psi for 5 minutes. No leaks in either direction.
It was noted that the ANI had documented his
13 witnessing the tests by his signature and date. Also the test was verified by WKM QNQC personnel and the customers source inspector.
(12) The Performance Test for S/N495 407 which recorded the travel distance and the opening and closing times.
b.
Discussions with the Vendor's cognizant personnel.
4.
Findings No irregularities were noted in the available casting suppliers a.
QA/QC documents reviewed.
However, the radiographs, welding, i
heat treat, and nondestructive examination procedures and quali-fications, and the qualification of personnel concerning the casting supplier's upgrading of the castings were not available for evaluation, b.
No irregularities or deviations from the QA program requirements, were noted in the WKM manufacturing, inspection and test docu-ments reviewed.
c.
The cause of the problem has not been determined. However, B&W's report, pursuant to 10 CFR 21, documents that the probable cause is currently being investigated by B&W, the Licensee, and WKM.
d.
WKM stated that until the probable cause is identified, it can-not intelligently determine whether the problem is generic to any nuclear customer other than B&W., and develop appropriate procedures to correct the problem and to implement action to prevent recurrence.
WKM provided, for the NRC inspector's review, a copy of the B&W's e.
written report, to NRC, dated December 17, 1979, referenced in C above.
The report submitted by B&W in compliance with 10 CFR 21, correctly describes the problem.
WKM stated that B&W had notified all Licensee's to which the suspected valves had been shipped and notified them that they will be kept informed as to the process of the investigation to determine cause and the selected fixes.
f.
WKM also committed to keep the VI Branch, RIV updated on the progress of the investigation to determine the cause and the appropriate fix.
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F.
Exit Interview At the conclusion of the inspection on March 7, 1980, the inspector met with the company's management, identified in paragraph A, for the purpose of informing them as to the resuli of the inspection. During this meeting management was informed no deviatons were identified, however, one unresolved item was identified.
The company's management acknowledgad the inspector's statement and had no additional comments.