ML20010J185
| ML20010J185 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1981 |
| From: | Driskill D, Fox D, Gagliardo J, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010J173 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8109290677 | |
| Download: ML20010J185 (28) | |
Text
hhf
- WNe U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Investigation Report No. 99900400/80-05 Program No. 51100 Company:
Babcock & Wilcox Company Facility:
Nuclear Power Generation Division Investigation at: Lynchburg, Virginia Investigation Conducted:
July 8-11; August 6-9, 1980 investigator:
.>I-d M
% n, squ D. D. Driskill, Investigation Specialist Date Inspector:
4/8/8/
0l.
F.' Fox, Inspector,' Program Evaluation Date Sec1l ion,VendorInspectionBranch Reviewed by:
,//
4 E. Gag}iardo, Director Date' Investiga# ion and Enforcement Staff Approved by:
4 O O, P 4
15 l
U. Potapovs, Chief Date Vendor Inspection Branch Summary Investigation was conducted at Babcock & Wilcox, July 8-11; August 6-9, 1980 and continued at WKM Valve Division of ACF Industries, in Houston, Texas, on August 25-28, 1980.
8109290677 810508~
l i
2 Area Investigated:
Allegations were submitted to NRC that Babcock & Wilcox (B&W) contracted for manufacture of gate valves without conducting a thorough technical evaluation, that valve quality was compromised, that a liquidation of damages penalty dictated delivery of the valves found not technically acceptable for other contracts, and that a safety concern, potential overpressurization of the valve body, was not properly evaluated and satisfactorily resolved.
This investigation involved 276 investigator / inspector-hours on and off-site by one U. S. Nuclear Regulatory Commission Investigator and two U. S. Nuclear Regulatory Commission Inspectors.
Results:
The allegation that B&W contracted for manufacture of "alves without conducting a thorough technical evaluation has merit, based on available information and records, although no items of noncompliance were noted.
There is no indication that valve quality was compromised as a result of the initial B&W technical evaluation.
The allegation that a liquidation of damages penalty dictated delivery of valves found not technically acceptable for other contracts was substantiated, insomuch as the liquidation of damages penalties asso-ciated with the valve contract did create an atmosphere in which delivery of the valves appeared paramount.
Investigation additionally disclosed that the valves were deemed, by B&W, technically unsuitable for use in another similar proposed contract; however, this evaluation appears, based on available documentation, to have resulted more from perceived vendor performance than actual product quality. The allegation that overpressurization of the WKM valve was a safety concern not properly evaluated and satisfactor,ily resolved was, in part, sub-stentiated and resulted in Notice of Violation issued to B&W (99900400/80-03) and Notice of Violation issued to WKM Valve Division, (99900308/80-02) for failure to properly evaluate or report to NRC an identified substantial safety hazard as required by 10 CFR 21.
)
l 3
INTRODUCTION The Babcock & Wilcox Company, Nuclear Power Generation Division, Lynchburg, Virginia, is the designer and supplier of nuclear steam supply systems, nuclear fuel and poison, and repair or spare parts.
REASON FOR INVESTIGATION On January 18, 1980, Mr. R. McGaughy, Chief of Projects Section, NRC, Region I, telephonically apprised Mr. A. D. Toth, Resident Inspector, Washington Nuclear Power Units 1 and 4, NRC, Region V, of allegations that the results of an unfavorable design review regarding B&W decay heat removal system valves pro-vided to Washington Public Power Supply System (WPPSS) Units 1 and 4, were discarded due to financial considerations and that " technically unacceptable" safety-related valves were delivered to WPPSS.
SUMMARY
OF FACTS On January 18, 1980, Mr. R. McGaughy telephonically contacted Mr. A. D. Toth and related verbal allegations received from Individual A.
The allegations reported were:
Allegation No. 1: The B&W contract for WKM valves was released in spite of unfavorable design reviews.
A review of B&W records, such as memoranda, may reveal this fact.
Allegation No. 2: The B&W design review expressed concern over WKM's modified valve design.
WKM's first test results were unsatisfactory.
Allegation No. 3: The B&W design review expressed concern over WKM's valve bonnet design.
The valve bonnet did not use a bolted connection, but rather a type of compression ring.
Supposedly, this makes maintenance under radio-active conditions prohibitive.
Allegation No. 4:
The B&W contract with the licensee (WPPSS) included a
$10,000 per day penalty for each day of delay in delivery of the valves, and that somewhere in B&W a decision was made that a timely alternate source of supply could be obtained, however, the procurement with WKM should proceed.
o 1
4 Between March 31, 1980, and April 3, 1980, these allegations were investigated at WPPSS, WNP sites 1 and 4, where it was determined by a US NRC Region V Investigator that the allegations could not be substanti:ted with information available at the job site.
On May 1, 1980, the allegations were forwarded to US NRC Region IV, Vendor Inspection Branch, for further action.
(It is noted hereinafter that the alleger was interviewed on July 8, 1980, and he clarified the above allegations, which are hereinafter stated as presented by the alleger on July 8,1980.
8 e
1 i
f
e 5
DETAILS SECTION A.
B&W Per;onnel Contacted
- C. A. Armontrout, QA Audit Section Leader
- J. C. DedJen, Acting General Mcnager, NPGD
- E. V. DeCarli, Manager, Quality Assurance
- F. R. Fahland,. Manager, Equipment Engineering H. H. Honig, Principal Engineer A. L. MacKinney, Manager, General Services J. H. MacMillan, Senior Group Vice President, Nuclear Power Group
- 28. D. Nelson, Manager, Contracts-Legal
- P. G. Perry, Manager, QC Surveillance
- D. H. Roy, Manager, Engineering Department
- J. H. Taylor, Manager, Licensing G. T. Urquhart, Manager, Auxiliary Equipment Engineering E. G. Ward, Senior Projects Manager
- Denotes those present at the B&W exit meeting.
WKM Personnel Contacted
- J. R. Brinkley, Chief Engineer
- W. Cook, Supervisor, Quality Control
- R. V. Hopkins, Former Manager, Quality Assurance
- H. M. Jackson, Project Coordinator
- C E. Marcate, Manager, Quality Assurance
- A. M. Williamson, Manager, Operations
- Denotes those present at the WKM exit meeting.
Other Persons Contacted Individuals A, B, C and D
- /segation No. 1 B&W contracted with WKM for the manufacture of nuclear safety class valves without having conducted a thorough engineering review of the proposed valve design; consequently, numerous manufacturing and testing probl:2ms resulted in B&W approving compromises in design and quality of the valves.
6 Investigative Findings On July 8, 1980, Individual A was interviewed regarding his previously reported general safety corcerns relating to nuclear safety class valves manufactured by WKM Valve Division for B&W for use at WPPSS nuclear power plants 1 and 4.
Individual A stated he had personal knowledge that B&W had experienced numerous problems with WKM during their manufacturing ano testing of the valves.
He stated the root cause of B&W's problems with the valves was due to their having not conducted a thorough pre-contract design evaluation of the proposed WKM valves.
Indisidual A stated that B&W was aware, when contracting for the WKM valves, that WKM haci never manufactured valves for nuclear application.
He said B&W contracted with WKM for the production of valves which WKM had formerly manufactured successfully for conventional non nuclear engineering application.
Individual A stated that during the manufacture of the valves, which began in 1977, it became apparent to B&W that various design modifications would be requirea on the valves for their nuclear application.
He stated that during production, these numerous modifications resulted in significantly altering the original valve design to the extent that it was "another valve" design completely.
Individual A furthermore stated that numerous problems were experienced in the final testing of tr.e gate valves insomuch as they deviated from the original valves design operating specifications.
He stated that the testing problems resulted in extensive B&W modification of the design operating specifications in order for the valve to be acceptable (pass tests) and to meet delivery dates.
Individual A stated it was his opinion t..at B&W had compromised good engineering principles in approving many of these design specification changes.
During the interview, Individual A identified the following areas of technical concern related to the WKM gate valves:
1.
Overpressurization protection of the WrJi Pow-R-Seal valves was not provided in the valve open position.
2.
Operability of the WKM Pow-h-Seal valve was not estab7:shed under environ-mental conditions.
3.
Valve stroke (operating) times exceeded specification limits.
4.
Through valve leakage exceeded specification limits.
5.
Undersized actuators prevented valves from fully closing and opening.
l l
6.
Field maintainability vf WKM Pow-R-Seal valves could not be established.
7.
Materials used in WKM Pow-R-Seal valves were not mutually compatible.
8.
WAM Pow-R-Seal valves contained a built-in " crud trap" which could pre-l vent the valve from closing and/or inhibit maintainability of the valve.
I
J 7
9.
Valve quality was degraded due to extensive design changes.
Review of B&W Records On July e-11,1980, and August 6-9, 1980, an extensive review of B&W recoras relating to the B&W procurement of WKM valves for WPPSS and PGE was conducted.
These records disclosed that prior to fabrication of the valves, the required preaward surveys, including a quality assurance audit, of WKM's manufacturing capabity were performed.
B&W placed WKM on their " Supplier's Status List" as "cc ;itionally approved" on November 18, 1974, and as " approved" on Septemoer 17, 1976.
The records review identified documents which reflect that in addition to the initial QA audit being conducted, continued QA audits were conducted throughout the life of the contract.
With respect to Individual A's allegation that no " thorough engineering review of the WKH valve design" was conducted, a November 3,1975, B&W memorandum entitled " Technical Evaluation -
DH Cooler Outlet Valves - Revision 1," containing additional memoranda relating to that topic, was reviewed.
This document with its attachments is hereinafter referred to as Document 1.
Document 1 recommends " purchase of valves from WKM" based on a " thorough evaluation" of the WKM and other sources submitted designs.
Document 1 states the B&W Engineering Department selection of the WKM valve design was based on contacts with a " number" of WKM valve users who "seemed to be satisfied with it performance" and that the valve selected "must be of proven design with a successful operating history." Document 1 also includes the November 3,1975, comments of a B&W senior buyer who states "I have received the requisition to procure the subject valves from WKM, contrary to nty recommended source.
As best as I can ascertain, the basis for engineering's recommendations is twofold:"
1.
"Past operating experience of the WKM valves in similar service."
2.
"A service failure of a valve similar to that proposed by the alter-nate supplier."
l The buyer goes on to state that " numerous questions result from engineering's technical review which indicate to me that a lot of assumptions and opinions have been concluded." No records were available which indicate that B&W's evaluation of the WKM valve proposal included any evaluation other than contacts with other WKM valve users and an initial QA program preaward survey at WKM.
With regard to B&W's allegedly approving compromises in design and quality of the valves, the records review disclosed many documents which addressed production and testing problem areas and which were critical of WKM's performance in the production of the valves.
The first consolidated documentation of problems during production of the WKM Pow-R-Seal gate valves was found in the July 13, 1977, B&W memo entitled " Remotely Operated Valves" (hereinafter referred to as Docu-ment 2), which documents reasons why the WKM valves were determined to be "not l
8 technically acceptable" for use on the Ohio Edison contract.
Document 2 identi-fies the following seven reasons (technical objections), identified during WKM production for the WPPSS valve contract, which makes the gate valves technically unsuitable for the Ohio Edison contract:
1.
Internal relief not proven design.
2.
Iackseat effect in open position could have greater than desirable leakage.
3.
Orientation of drain connection potential interface problem when valve mounted in position other than vertical.
4.
Vaive design has potential crud trap due to transfer of flow into bonnet during valve operation and leakage into bonnet area when valve is open.
5.
Material end QA control on relief unknown.
6.
Three piece valve design - (1) cast and (2) forged parts welded together, not desirable feature.
7.
Software turnaround and submittel by WKM poor.
An August 3,1978 B&W memo entitled " Suitability of WKM Valves for Intended Purpose" (hereinafter identified as Document 3), states "there is substantial and growing concern regarding the quality, capability and availability of WKM valves." Document 3 goes on to address the suitability of the valves as follows:
1.
"WKM has obtained a proven inte'rnal relief valve which has been shown to perform as required to prevent hydraulic lock and/or over-stressing of the valve body-bonnet.
This problem area is considered resolved.
2.
"WKM has modified their standard bolt-bonnet design and now utilizes a pressure seal ring which has to be preformed in order to get the components parts assembled in the valve body. This will increase maintenance time in the field, increase radiation exposure during maintenance, and will require additional special tools not normally required for other pressure seal design valves.
This is apparently a first of a kind pressure seal design.
c
9 3.
"WKM engineering is weak and there are major disconnects in their total organization.
Because of their new pressure seal design, their carting did not have enough material in the bonnet neck.
WKM has had to add a ring forging which is full penetration welded to the body casting.
All of the WKM people who were originally involved in the B&W orders.
are no longer employed by WKM which has caused a lack of continuity.
4.
"QCS considers WKM to be fair from a general quality viewpoint; good in general workmanship and weak in quality control.
There has been constant B&W QC surveillance at WKM for the past six weeks and it is still a problem to get them to move on anything.
The liquidated damages date for delivery of the WPPSS valves passed, as of July 1, and is mainly the result of WKM's lack of performance.
5.
"Because of the discussion set forth above, we han found WKM design to 1
be technically unacceptable for the Ohio Edison evaluation.
At the time of discovery of most of the above it was not practical from a schedule or interchangeability standpoint to switch to another j
supplier.
6.
"In summary, the WKM valves for WPPSS and PGE are unproven, first of a kind designs with which problems are being discovered in the assembly-j testing stage.
Quality is questionable, capability for tight shut-off unproven, and maintaincbility will be more difficult than for a conventional wedge gate valve with a bolted bonnet.
The outlook for high availability from these valves is not encouraging."
On August 21, 1978, B&W proposed to WKM that a design revied meeting be held at B&W, Lynchburg, Virginia, on October 2, 1978, to discuss 19 major areas of concern regarding the valves.
It was requested that WKM be prepared to reach an agreeable, thorough and acceptable response.to each of the items of concern.
Document 4, a September 29, 1978 B&W telex to WKM outlines these 19 areas of con-cern. Document 5, an October 11, 1978 B&W telex to WKM entitled " Preliminary Heet-l ing Minutes," addresses only the following 18 areas of discussion at the meeting:
1.
Valve standardization and plant availability 2.
First of a kind features of valves 3.
Valve body to valve bonnet joint design 4.
Life of seal ring 5.
Addition of ring forging to upper portion of valve 6.
Adapter plate parallelism
10 7.
Interchangeability of valve components 8.
Customer service 9.
Ensuring leak. tightness 10.
Opening and closing of va've 11.
Installati.on of seats 12.
Parallellism of valve bonnet 13.
Future design 14.
WKM manufacturing and in-service experience 15.
Maintenance time 16.
Design features (stem and stem to gate connection) 17.
Leakage 18.
Spare parts Document 5 includes WKM responses to these B&W areas of concern (listed above) in " action items" identified, regarding which WKM was asked to provide addi-tional follow-up information.
On October 10, 1978 a B&W message to WKM (attached to Document 5) states "We assumed th t WKM unaerstood and would be in a position to disarm any concerns or reservations pertaining to the WKM valve design.
This did not happer. and was exemplified by the many action items which evolved from the meeting."
Document 6, a November 28, 1978 B&W memo entitled "WKM Technical Evaluation" was prepared subsequent to the resolution of concerns addressed in Document 4.
Document 6 recommends " Accept the WKM valves as meeting the intent of the equipment specifications, assuming all commitments by WKM to supply supporting information is met and none of the information indicates an unacceptable situation." This evaluation additionally updates several concerns which were formally used, as a basis for finding the WKM valve technically unsuitable.
This evaluation also identified numerous problem arc hich have been resolved and outlines the requirements for resolution of the outstanding few areas cf Concern.
i l
m
11 Document 7, a June 11, 1979, B&W memo entitled "WKM Technical Evaluation" documents the resolution of all former major concerns relating to the WKM Pow-R-Seal gate valves.
It also states "It appears that WKM has satisfied all conditions of the B&W specification and has closed out all of the committed action items except one, i. e., demonstration of the assembly' and discssembly tools.
They plan to demonstrate the tools on July 23, 1979.
Document 7 additionally addresses an overall assessment of W resolved areas of concern.
Document 7 lastly states that "if a greater deg ee of operability assurance is desired than is now available, operational tests must be perforced."
The B&W records reviewed disclosed numerous memoranda and letters relating to WKM's failure to meet software schedules and promised delivery dues.
Various letters from B&W management to WKM management addressed this prvolem area as well as WKM's failuce to meet scheduled production dates.
One of these letters states " delay on the part of WKM has reached the intolerable stage.
B&W's management is most concerned about WKM's performante, and therefore, your ability to obtain and provide timely information that will allow our engineering department to conclusively accept the WKM valve for B&W application."' This December 14, 1979 letter to WKM, addressing problem areas, is identified as Dcoument 8.
This review of B&W records identified no documents which support the allegation that B&W approved compromises in design and quality of the valves.
- However, NRC's B&W Inspection reports, 99900400/80-02 and 80-03, identified that Contractor Variation Approval Requests (CVAR) requesting changes in the design of the WKM valves and/or modification of the specifications and/or procurement requirements were not reviewed and approved in all cases as required by B&W procedures. ~This action appears to have resulted in design changes being affected without their having received the equivalent technical review and approval as the original WKM gatt. valve design.
This formed a basis for an NRC Notice of Deviation being issued to B&W, enclosed with the inspection report 80-02.
Interview of Individual B On Augud 6, 1980, Individual B, a B&W employee associated with the WKM gate valve contract, was interviewed.
Individual B stated, when questioned con-cerning testing of the WKM gate valve, that leakage problems with the valves were resolved prior to delivery of the valves.
He stated that although some of the valves exceeded stroke times required on the original specification, CVARs were used to modify the specification and that all valve stroke times were well within B&W/NRC requirements.
He stated all the gate valves passed tests for operability prior to delivery, and would pass those tests now.
He stated all problems identified during the manufacture of the gate valves were resolved.
UNDER PROPRIETARY REVIEW BY WKM
3 12 ca. --.- - _.: w _-. -,~.;
4 I
I.
o g~
ta 1
.T
- u
- e *
' e '
y-
=
-r
'I=
- -ah
- .s-
..a e
e,
' \\...
g.....
y g,-
.-.- - -,O.
.3.
-e
.. - ; ~
_,..i
- s. +,.=* p
- 4,g_,
.
- 4v.* * ' _*, s.
,7 4
-7~
. - g g
f e
e8
-.i- -,
- g e
1 4
e 9
4" g *~* ~~~~ - - - -
== - -.
h 9
O 4
k G
UNDER PROPRIETARY REVIEW BY WKM 1
9 D
t e--.e m
=e e-e
,m my, 1
i 1
s l
l i
l
\\
1 e
l n
1 I
1 l
l l
l 1
l 13 g._ _ _
_. -.m ~. * ~ - -.,
-_ n a 2,...
__ g _. _ _
m
.r e
I l.
e s
a e
,. ~
'g s
~
g
~
.A..*
-g
- v..,
A,.
i
'r.. '
.' 7.
t *.,.,
s..
a.
s
.a
. ; s, -
s _ <
.s v-
- S
~
g,
, _.., g * * * ' - --
+ =
UNDER PROPRIETARY REVIEW BY WKH l..
e 1
nn
.-.- ~.
- - - - ~ --
1 1
4 F
[
1 e
i I
O t
l l
o i
l 1
14 lmDER PROPRIETARi REVIEW BY WKM
~
Technical Review of' Safety Concerns
~
During the course of this investigation, technical reviews of the safety concerns related to the WKM Pow-R-Seal valves identified by Individual A were conducted.
The following are findings based on those technical reviews.
1.
The lack of overpressure protection, identified by Individual A is addressed as the topic of Allegation 4, ieported herein.
The basis for the concern and effect of lack of over pressure protection is as follows:
The results of the investigation indicate that certain types of gate valves, such as the WKM POW-R-SEAL gate valve, can entrap process fluid in the valve body in the open position as well as in the closed position.
Entrapment of fluid results from the design of the dual sealing gates which isolate the valve body from the process stream in both the valve fully opened and fully closed positions.
Unless overpressure protection is provided for these type valves in both the open and closed position, the potential for over-pressurization and subsequent valve malfunction or failure exists whenever a significant iacrease in system temperature occurs such as during systen.
heat up or during and after LOCA.
I&E Circular 77-05 (Liquid Entrapment in Valve Bonnets) states that "the reported effects of such a pressure rise (on dual seal valves similar in design to the WKM POW-R-SEAL valve) range from inaoility to open the valve, to structural failure of internal parts of the valve or failure of the bonnet.
Consequences range from loss of functicr. of the valve to fluid escape and injury to personnel or damage to equipment in the vicinity."
Some, but not necessarily all, WKM POW-R-SEAL valves have been provided with overpressure protection in both the open and closed positions.
Some sizes or models of WKM POW-R-SEAL valves have an internally mounted pressure relief valves situated so as to relieve excess body pressure directly into the process stream and thus over pressure protection is provided in both the open and closed positions of these valves. Other valves have a pressure relief valve mounted in one of the gates (the " segment" gate) so as to relieve excess body pressure into the process stream in the valve closed position only.
In some, but not all of these valves, over pressure pro-tection in the open position, has been provided by drilling a small radial hole through the side wall of the valve gate "open port" to provide for communication between the valve body and the process stream.
Some valves delivered and installed in the Florida Power and Light Louisiana Power and Light, Nebraska Public Power and San Ondre nulcear power stations may not have valve body overpressure protection in the valve-open position.
l
__,__._m_
.m.__-_________
T 15 Furthermore, some valves delivered and installed in the Louisiana Power and Light, Nebraska Public Power and San Onofre nuclear power stations may not have valve body overpressure protection in either the valve-open or valve-closed positions.
See Inspection Report 99900308/80-02 for additional details.
2.
The results of this investigation indicate that operability test for POW-R-SEAL valves under environmental conditions were not required as a part of the B&W. design specification and/or purchase order.
B&W indicated as early as 1977 that these valves would be physically tested for opera-bility under environmental conditions during the Hot Functional Test of the first plant which utilitzed the valve (probably WPPSS).
Although not contractually required, WKM conducted a mock-up pseudo environmental operability test of a 2 inch Pow-R-Seal valve, at B&W request, in early 1979.
The intent of the test was to prove that the valve would operate properly under normal service environmental conditions It was proposed 6
that the valve temperature would be elevated above 600 and then the valveoperatorwouldbeenergizedtodetermineopgrabilityofthevalve.
However the valve test condition reached only 470.
The valve was stroked at that temperature without any apparent sticking or other malfunc-tion.
B&W concluded that this test provided acceptable "prescreening" evidence that differential expansion of Pow-R-Seal valves at elevated temperatures is not a problem which could prevent the valve from opening or closing when needed.
~
3.
The results of this investigation indicate that POW-R-SEAL valves of early manufacture experienced considerable difficulty in meeting the specification requk nents for stroke (operating) time; however, after modification of the
~desip and improvements of the manufacturing open tions, only 8 of the 46 B&W valves tested had stroke times (thirteen tc, sixteen seconds) in excess of specification limits (ten seccnds).
B&b deemed that these 8 ware acceptable (via a Contractor Variation Apprcval Request) in that their maximum stroke time was less than approximately one-half the time required for ECCS activation flow.
4.
The results of this investigation indicate that POW-R-SEAL valves of early manufacture reportedly exhibited through valva leakage in excess of speci-fication limits.
Subsequent manufacturing improvements and rework of the
" leaky" valves resulted in all but one POW-R SEAL valve meeting the B&W specification limit for leakage.
The one valve which leaked in excess of specification limits war deemed acceptable by B&W (via a Contractor Varia-tion App""al Requett) in that the leakage wrcs through the valve packing and not tr..ough the valve itself and therefore did not impair the intended function of the valve.
r 16 l
5.
The results of the investigation indicated the use of undersized actuators which could not fully open or fully close POW-R-SEAL valves appeared to be limited to valves of early manufacture in the smaller valve sizes.
The initial actuators were ur.dcrsized because the friction and operating characteristics of the smaller valves could not be accurately calculated and thus actual torque requirements of the actuator were higher than pre-dkted. The actuator size was increased and the valve operation character-istics were tested and determined to be within the specification limits (as amended by CVARs) on all valves supplied to B&W.
6.
The results of the investigation indicate that the use of a circular seal ring rather than bolting to achieve the required jointure of the valve body may somewhat increase the difficulty of meintaining and servicing WKM POW-R-SEAL valves under field service conditions.
However, WKM records indicate that they developed and sucessfully demon!tisted to B&W, the special tooling needed fc aintaining and servicisig '.hese type valves under field service cond ns.
7.
The results of the investigation indicated that contiguous materials used in POW-2-SEAL valves appeared to be mutually compatible.
The body and the seat were made of essentially the same type of stainless steel, except for differences in the carbon content, to minimize the effects of differential thermal expansion and galvanic corrosion; the seats and the gate were both hard surfaced stainless steel to provide for smooth operation and resistance to corrosion during the (relative infrequent) operation of the valve; and the valve packing was provided with zinc sacrificial discs t.o reduce the galvanic corrosion that could occur between the packing and the stem of the valve.
8.
The results of this investigation indicate that there is a hollow bell shaped housing at the bottom of the valve into which a portion of the gate (of length approximately equal to the bore of the valve) must slide when the valve is in the closed position.
Conceptually, the void could become filled with crud over a long operating period, which then could prevent the valve from cloe 6.
Furthermore, radioactive materials 9
contained in the crud could reduce maintainability of the valve by limiting personnel access time.
However, the likelihood of the void filling with crud is considered by WKM to be extremely small in view of the fact that the void is essentially isolated from the main process stream in both the valve fully open and in the valve fully closed position.
Other than the small galvanizing flow of process fluid through the overpressurization relief hole, the only time that crud could enter the void from the process strea would be during the trans-ition time (less than 16 seconds) when the va) ' was opening or closing.
9.
The results of the investigation indicate that are may be some overall dyredation in the valve quality due to the many design changes, rework, and/or repairs made to the valves.
There is no evidence however, to indicate that after the identified overpressurization and linear
s 17 indications problems are corrected, that the valves vill not be able to perform their intended service function under both normal and accident conditions during their design service lifetime.
During the investigation, several previously Unidentified (by the alleger) areas of technical concern surfaced.
The concerns and findings are listed herein for the completeness of this report. The identified concerns and findings are as follows:
I Unacceptable c' racks on the interior and linear indications on bcth the 1.
interior and exterior of WKM Pow-R-Seal valves were detected.
Finding:
The results of the invest'gation indicate that the Babcock and Wilcox Company purchasea a total of forty-eight (48) ASME Class 1 and Class 2 valves, in sizes ranging from two and one half inch through fourteen inch stainless steel WKM POW-R-SEAL valves.
distributed among the Power Authority of the State of Ne' iv.k, Portland General Electric Company, Tennessee Valley Authority and the Washington Public Power Supply System for use in safety-related systems of nuclear power stations.
WKM had comp'eted and shipped i
approximately one half of the valves to Portland General Flectric, Tennessee Valley Authority and Washington Public Power Supply Syst i chen the fabri-cation defects were detected in delivered valves.
Linear indications in Class 1 decay heoc amoval system dropline isola-tion valves and " cracking" in a Class 2 core flooding system isolation valve were detected in WKM POW-R-SEAL vcives delivered to WPPSS.
The unacceptable indication: *r the decay heat removal isolation valves are located in the inlet and outlet conduit regions on the inside and outside of the valves.
The " cracks" in the core floodirg system isolation valve are located in the body crotch region above the cent pockets on the inside of the valve.
Records and other information made available during the investigation and the subsequent meeting in Region IV offices, could not substantiate that:
(i) all stainless steel WKM POW-R-SEAL valves supplied for, or to be supplied for, use in safety related systems of nuclear power plants are free of " crack like" defects and other linear indications. (ii)
All past and present purchasers of stainless steel WKM POW-R SEAL valves were advised of the need to evaluate the safety significance of the manufacturing defects with respect to the specific application of the valves in their nuclear power plant safety-related systems, i
1his item has been identified as an unresolved item for additional follow-up in Inspection Report 99fs0308/80-02.
2.
Carbon steel retaining clips were used in place of steinless steel clips to hold some of the "Marotta" relief valves together as an integral unit within Pow-R-Seal valves.
1 f
d
.,.. -.. ~., ~,
, -,, ~,,, -,.. - -. - -
.---g
18 Finding:
The results of the investigation indicates that the initial lot of Marotta relief valves supplied to WKM contained a carbon steel poppet retaining clip rather than the specified SS clip. WKH was notified of the error by Marotta on July 17, 1979.
WKM convened its MRB on July 24, 1979, which deternined that the error caused no safety-related problems with WKM valves.
However, WKM informed Bechtel Power Corporation and Babcock & Wilcox to whom 3'M ha:' shipped. valves with the carbon steel clips.
BPC and B&W were each asked to review those systems ir. which the affected valves were installed to ascertain whether there woult' be any safety related problems that could be caused by the eventual relea4e of the poppet, spring and clip into the process stream.
BPC and B&W responded and each took different actions.
Bechtel request.ed that WKM supply stainless steel plugs with axial flow holes which would r.;ain the relief valve poppet in the event of deterioration of the carbon su el clip.
WKM management stated that some of the plugs were installed by 4KM nersonnel on site, with the remainder installed by Bechtel personnel.
With respect to B&W, WKM management stated that all valves previously shipped to B&W (WPPSS) were returned to WKM for disassembly, replacement of the Marotta relief valve clip with one of the correct material, reassembly and retest.
Review of WKM travelers and shipping records appeared to sub-stantiate the WKM management statement that all remaining valves still within the WKM manufacturing facilities had the stainless steel Marotta relief valve clip irstalled prior to shipment.
3.
Some delivered POW-R-SEAL valves may not have overpressurization protection in either the open or the closed positions.
Finding:
Refer to item 1 of " Technical Review of Se.fety Concern above."
4.
The initial relief valve used for overpressure protection of Pow-R-Seal valves in the closed position was not a "Marotta" valve.
The apparently unsatisfactory non "Marotta" pressure relief valve may exist in other WKM Pow-R-Seal valves ei early manufacture.
Finding:
The results of the investigation indicate that only "Marotta" supplied pressure relief valves were and for overpressure protection in all delivered WKM PCW-R-SEAL valves.
5.
"Marotta" pressure relief valve operating characteristics failed to meet B&W specification requirements.
r
19 Findiag; The results of the investigation indicate that the Marotta relief valve was incorporated into certain WKM POW-R-SEAL valves to relieve excess body pressure when the body pressure exceeds the upstream conduit pressure by 250 psi.
Although inspection records indicate that some installed Marotta valves did not relieve, nor reseat, within the B&W specification limits, the POW-R-SEAL valves were deemed acceptable by B&W via CVARs.
Product acceptance records for uninstalled Marotta valves appeared to meet specification raquirements.
_ ALLEGATION NO. 2 The valves being maw factured by WKM were found to be technically unaccapable for use in anotner wntract proposal, for similar valves used in a sim lar application, being made by B&W at that time.
Investigative Findings On July 8, 1980, Individual A was interviewed and stated that during the summer, 1978, B&W evaluated the WKM gate valves, which were, at that time, being manufactured for WPPSS and PGE, for use on the B&W Ohio-Edison nuclear power plant contract.
Individual A stated the B&W evaluation determined the WKM valves were not technically acceptable for the Ohio-Edison project, wherein the valve applications were similar to WPPSS and PGE.
Review of B&W Records The previously identified review of B&W records disclosed a July 21, 1977 B&W memorandum, subject:
VALVES FOR OHIO-EDISON (hereinafter identified as Document M ) which responds to an apparent inquiry as te the reason for which WKM gate valves were not selected for use at the Ohio-Edison project.
Document 14 states that "In the case of the gate valves, we chose not to order valves froml KM.
This decision was a result of a technical eval stion of valve designs, the pri-l mary considerations of which are documented in.he attached lettar." The memo l
goes on to say "While the technical concerrs iadicated are sufficient to pre-I clude placement of additional orders with WA, they are not, in our opinion, l
sufficient to force replacement of WKM valves in other backlog contracts." The l
memo also states that "Part of what we are getting for the additional dollars is the elimination of these concerns." The memo formerly attached to Document l
14, identified herein as Document 2, cites the following seven reasons why the WRM valve design was "not technically accsptable" for use on the Ohio-Edison contract:
1.
Internal relief valve not proven design....
l 2.
Backseat effect in open position could have greater than desirable leakage.
l l
l
20 3.
Orientation of drain connection, potential interface problem when valve mounted in position other than vertical,
~
4.
Valve design has potential crud trap....
5.
Material and QA control on relief unknown....
6.
Three piece valve design - cast and forged parts welded together, not desirable feature.
7.
Software - turn around and submittal by WKM poor."
This evaluation additionally addresses the expectation that the Nuclear Regula-tory Commission may require more stringent testing, which the chosen vendor would be better prepared to accomplish.
A July 8,1977 B&W memo (hereinaf ter identified as Document IS), addressing meetings with various firms bidding on valve contracts for the Ohio-Edison project relates the following concern regarding the WKM valves:
"Since WKM has been deemed technically unacceptable for the Ohio-Edison gate valves, even though they were considerably cheaper in many instances, particciar attention should oe payed to paragraph 'G' of the WKM meeting report, as sutr.s-full implementation or success of the internal relief valve test program will affect the operability and acceptability of all gate valves to be supplied by WKM to WPPSS, PGE and PASNY.
The performance by WKM in meeting software and hard-ware schedules continues to deteriorate.
I am concerned at the manufacturing progress on the TVA valves and especially the WPPSS valves whicn are ominously cL se to the liquidated damages date.
This will be escalated to WKM management."
i Interview of Individuai C On August 7,1980, a B&W engineering manager, Individual C, was interviewed and stated, in response to questions concerning WNM valves being found not techni-cally acceptable for the Ohio-Edison project, that the determination was based l
on B&W evaluations of WKM performance which are discussed in Dccument 2, the contents of which are reported as findings for Allegation No. 1.
IndiFidual C stated that technical problems experienced in the production of the WKM valves were satisfactorily resolved prior to the delivery of those WKM valves to WPPSS and PGE.
l l
r 21 UNDER PROPRIETARY REVIEW BY WKM q-ys vgess.
- ~ ~ -
ALLEGATION NO. 3 B&W efforts to find another timely qualified source for the gate valves was unsuccessful and a "$10,000" per day liquidation of damages penalty dictated
- ~
acceptance, by B&W, and delivery, to WPPSS and PGE, of the WKM valves.
Investigative Findings On July 8, 1980, Individual A was interviewed regarding the B&W procurement of WKM valves for the WPPSS and PGE nuclear power plant projects.
Individual A stated that B&W's contract with WPPSS, for the valves, included a $10,000 per day liquidation of damages penalty for delivery of the valves past the contracted slate.
Individual A stated the Penalty was a significant commercial consideration for B&W and related directly to B&W's attempts.to expedite completion and tasting approval of the valves.
He stated the penalty was the primary motivating f ctor leading to B&W compromising the quality of the valves.
Individual A
'urther stated that when B&W management realized that WKM might not be able to provide technically acceptable valves during the agreed upon time period, subsequent to which liquidation of damages would be imposed, efforts were made to find another source for the valves.
He stated the efforts were unsuccessful and dictated the WKM valvr.s would be provided to WFPSS.
Review of B&W Records The previously identified review of B&W records disclosed that B&W contracts with WPPSS for valves included a $17,000 per day (not 10,000 per day) liquidation of damages penalty for late delivery of the valves.
Numerous letters and memor-(
anda were observed in B&W procurement and engineering files which related to the necessity of resolving administrative, manufacturing, and testing problems with WKM in order to avoid liquidation of damages penalties.
This review of documents l
noted that between December 1978 and February 1979, the concern regarding the liquidation of damages penalty became a very important consideration associated with the resolution of testing problems with the valves.
During this period letter; from B&W management personnel to WKM management personnel urging the timely employment of every resource available in completion of the valves to l
avoid liquidation of damages.
A February 21, 1979 letter from B&W purchasing management to the Manager of Operations, WKM Valve Division, stated "Even though the possible damages are important, we do not expect the testing for the valves to be compromised in any way whatsoever.
You are expected to supply the total valves suitable for their intended purpose and capable of operating in a dependable and reliable manner."
l
m 22 Internal EiV memoranda were identified which indicates efforts were made during the summer of 1978 to locate an alternate supplier for the WPPSS and PGE valves.
Document 3 states that "Because we had a concern primarily with the delivery schedule of the WKM valves for WPPSS, we investigated the possibility of util-izing an alternate supplier.
An August 3, 1978 B&W management memo, Document 3, indicates that alternate sources for WPPSS valves had been contacted and that
" low level pursuit of backup and alternatives is arpropriate until additional details are available regarding the suitability of WKM valves for their intended purpose."
Intervfew of Individual B On August 7, 1560, Individual B was interviewed regarding B&W efforts to locate an alternate valves source for the WPPSS valve contract.
Individual B stated
~
that such measures were taken and that it is B&W policy to do so when it appears that a supplier will not have a product completed by the agreed upon delivery date.
Individual B stated although efforts were effected to locate an alternate supplier for the WPPSS gate valves; none were found who could provide the valves prior to the date in which B&W had agreed upon.
Individual B stated tr.st these efforts coincide with the preliminary technical ev61uations which had indicated WKM's valves were technically unsuitable for the WPPSS application.
Individual B pointed out that the " unsuitability" evaluation was not due to WKM's technical ability to provide a suitable valve, but was the cause of their unexcusable delays in resolving problem areas in the manufacture of the valves.
Individual B stated that efforts to locate an alternate supplier are mandatory B&W policy, vnen a liquidation of damages penalty is involved in the B&W/ licensee contract.
He stated that any 'such damages incurred can be legally mitigated based on B&W's efforts to locate an alternate supplier.
Individual B stated the technical problem areas with the valves and WKM were overcome and all contractually agreed upon valves were supplied to WPPSS without any liquidation of damages penalty being imposed.
~ ~ ~ ~.
e b
k UNDER PROPRIETARY REVIEW BY WKM t
.,,,,.w..
~ " * * ^
.w4
-6=m.-
e o
6
4
~
1 23
--v.
2
_ m m- - > -
-_ = ~. _ _ ~
=
m
~
a
. u _._.__4 _.. ~ _-
i I
'o e
F
.y e
N s
Em 9
a.
g
_g
,,4
[s ts
,,. e 'l,.
,, s
.*h 3
w..
9
.g9' \\,
g f.., O
,g Y,, '
6 fe
' s;. g*
4
% )'
-1
-- *;..-e-
.-s.
e,
- g.!*
3-
- ,'g*,'
a
- 1,
=
p A
- 96,
\\
N,.*
'I 4,
a
- 8
.g
+
3 b
e g
e 4*
, e _ g
,g 9
9 e
UNDER PROPRIETARY REVIEW BY WKM eu.
g w
e 4
m
- em-.-
m esuum e,,
-s ese -
G e
e d
E IJ q
(\\
,/
24 ALLEGATION NO. 4 That overpressurization of the WKM core flood and decay heat removal valve was a safety concern which was not properly evaluated and satisfactorily resolved.
Investigation Findings On July 8,1980, Individual A was interviewed at which time he stated the major problem identified during B&W's procurement of safety-related gate valves from WKM was the potential for overpressurization of the decay heat removal valves.
He stated that when the problem was identified, WKM agreed to install an internal chet.k valve, in the gate of the valves being manufactured, which would eliminate this problem.
Individual A stated, however, the check valve originally proposed and tested by WKM failed operability tests.
He stated WKM then obtained internal check valves from "Marotta" which passed the required tests.
Individual A was again interviewed on August 4,1980, at which time he stated the overpressuri-zation of the gate valves was an issue which he did not feel B&W had properly evaluated and could be a serious potential safety problem with the valves.
Revies of B&W Records During the previously identified review of B&W records, numerous documents were identified which addressed various aspects of the potential overpressurization of the WKM Pow-R-Seal gate valve.
Investigator's Note:
The overpressurization concern identified by Individual A was found to be related to the possibility of overpressurization of the gate valve in the closed position. This review of B&W records additionally disclosed an overpressurization concern identified during October 1978 which related to the potential for overpressurization of the gate valve in the open position.
The previously identified Document 6 (page 2) provides the following chrenpine;;
related to overpressurization of the gate valve in the closed position:
1.
Place purchase order - relief valve not known to be required.
2.
Two years into the order - discussion of operation of the main valve indicates a relief valve required.
3.
WKM indicates relief valve is normally mounted on outside of main valve.
l 4.
B&W or WKM suggests this location is not satisfactory because of seismic considerations (this is not documented).
5.
W m decides on internal location of relief valve.
6.
B&W argaes against internal relief valve suggesting a drilled hole.
I 7.
WKM tests first relief valve.
Tests end in failure.
8.
WKM tests "Marotta" relief valve - results are okay.
25 9.
B&W questions location of relief valve because it does not operate when the main valve is in the open position.
- 10. WKM explains that because of the leakage in the open position, the valve does not require operation in the relief valve.
- 11. October 27, 1973, WKM reverses earlier statements "the valve body is completely isolated from the flow stream in the open position."
The B&W flow calculations which judge the "Marotta" relief valve ability to provide adequate overpressurization protection were obtained and will be maintained in NRC Region IV investigative files.
Document 6 goes on to relate, as a safety concern, that the " valve body can be overpressurized in the open position or valves can be rendered inoperable." Document 6 identifies the means accomplished, during production, to resolve this safety concern stating "a hole drilled in the gate allows communication between flowing fluid and valve body.
The 2 inch and 4 inch Class 1 valves will not be drilled, instead the relief valve will be mounted in tne body for relieving in either the open or closed position of the main valve."
In accordance with B&W procedures, B&W conducted a formal evaluaticn of the safety concern posed as a result of the potential for overpressurization of the WKM Pow-R-Seal valve in the open position.
The safety concern was identi-fied by B&W to be reportable as a significant deficiency (as defined by 10 CFR 50.55(e) and not under the requirements of 10 CFR Part 21).
This determination and the evaluation are identified as Document 18, dated December 5,1978.
Docu-ment 19is a B&W letter to WPPSS concerning the reportable safety concern.
It is noted that WPPSS reported this safety concern, as required by 10 CFR 50.55(e),
to the Nucleer Regulatory Commission, Region V, telephonically on February 9, 1979, and per letter dated March 9,1979.
(Note:
Failure by B&W to report this significant safety' deficiency under the provisions of 10 CFR Part 21 was identified as a non-compliance with regulations.
See NRC Inspection Report 99900400/80-03 for details).
.. - -L.-
-~
~7~
e UNDER PROPRIETARY REVIEW BY WKM
.e..-
em - = + =
~ ' '
k e
26 s
UNDER PROPRIETARY REVIEW BY WKti Technical Review of Overpressurization Concerns A technical review of the potential for overpressurization of the WKM Pow-R-Seal valves in both the open and closed positions was conducted during the course of this investigation.
It has been determined that the installation of the "Marotta" relief valve in the gate of large valves should provide adequate overpres-surization protection for the WKM POW-R-SEAL valve in the closed position.
Internally mounted "Marotta" relief valves are situated in the POW-R-SEAL valves 4 inches (NPS) or less in a location,,hich should provide over-pressure protection in both the open and closed positions.
Overpressurization protection for large gate valves could be provided in the open position by the small holes drilled in the upstream higher pressure side gate of the dual gate valve which provide communication between the valve body and the process stream and should relieve any pressure that could build up in the body of the valve due to temperature differentials.
It appears, based on a review of drawings, travelers, and interviews of B&W, WKM, WPPSS, and PGE personnel that all affected valves ordered by B&W were modified so as to provide overpressurization relief protection.
l l
1
CAPTIONED DOCUMENTS Copies of all documents, identified herein, which relate to the foregoing allegations, are maintained in the,n~RC, Region IV office.
A signed statement, executed by individual A on July 8,1980 and numerous other documents provided during the course of this investigation by B&W and WKM are also maintained in NRC Region IV files.
Tne following is a list of documents utilized and identi-fied in this report:
Document 1 - 11/3/75.B&W memo, with attact.ments, entitled, " Technical Evaluation - DH Cooler Outlet Valves - Revision 1" Document 2 - 7/14/77 B&W memo, with attachments, entitled, " Remotely Operated Valves" Document 3 - 8/3/78 B&W memo, with attachments, entitled " Suitability of WKM Valves for Intended Purpose" Document 4 - 1978 B&W Proposed Meeting Plan, with attachments Document 5 - 10/10/78 B&W Telex, with attachments, entitled " Action Items from Design Review Meeting Held in Lynchburg, Virginia" Document 6 - 11/28/78 B&W memo entitled "WKM" Tec..aical Evaluation" Document 7 - 6/11/79 B&W memo, with attachments, entitled, "WKM Technical Evaluation" Document 8 - 12/14/78 B&W letter to WKM Document 9 - 6/9/77 B&W memo, entitled " Pump CVAR's" Document 10 - 1977 WKM Handwritten Memo, with attachments Document 11 - 1/25/77 WKM memo, entitled " Babcock & Wilcox - Liquidated Damages" Document 12 - 1/2/79 WAM mcmo, entitled " Babcock & Wilcox - letter of 12/14/78" Document 13 - 1/19/79 WKM memo, with attachment Document 14 - 7/21/77 B&W memo, entitled " Valves for Ohio Edison" Document 15 - 7/8/77 B&W memo, with attachments, entitled " Meetings with WKM, Borg-Warner and CCI" Document 16 - 6/23/78 WKM letter to B&W entitled " Schedule Delays" Document 17 - 5/25/79 WKM memo
l Document 18 - 12/5/78 B&W memo, with attachment, entitled " Report of Safety Concern, PSC 16-78" Document 19 - 12/12/78 B&W letter to WPPSS, entitled " Report of Safety Concern PSC 16/78" Document 20 - 10/20/78 WKM Telex to Bechtel Power Corporation with attachments entitled "WKM Gate Valves - Internal Pressure Relief"
~
9 l
r
.