ML20036C437

Forwards Synopsis of Findings Re Insp Rept 99900404/89-01 & OI Rept 3-89-013.Enforcement Conference Scheduled for Near Future

ML20036C437
Person / Time
Issue date:	06/10/1993
From:	Zimmerman R Office of Nuclear Reactor Regulation
To:	Caso C WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
REF-QA-99900404 NUDOCS 9306170054
Download: ML20036C437 (9)

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Docket No. 99900404 Mr. Carlo L. Caso, General Manager Nuclear and Advanced Technology Division Westir e nuse Flectric Corpcration Post Office Box 355 Pittsburgh, Pennsylvania 15230

SUBJECT:

NRC INSPECTION REPORT 99900404/89-01 AND NRC 0FFICE OF INVESTIGATIONS (01) REPORT 3-89-013 The U.S. Nuclear Regulatory Commission (NRC) has completed its investigation of the circumstances surrounding the Copes-Vulcan Company (CVC) valve weight and center of gravity (CG) issue discussed in NRC letters to the Westinghouse Electric Corporation (WEC), dated November 16, 1989, and February 27, 1990.

These letters concerned the subject NRC Inspection Report. A synopsis of the NRC Office of Investigations findings is enclosed with this letter. As a result of the inspection and investigation activities, it appears that:

1)

In 1980, the WEC Safety Review Committee (SRC) did not conduct an adequate evaluation (as required by 10 CFR Part 21) in reaching the conclusion that none of the Copes-Vulcan Company (CVC) valve assembly drawing errors of which WEC had been made aware caused a " substantial safety hazard" to exist at facilities to which WEC supplied these valves.

The evaluation was inadequate because WEC did not have knowledge of the specific licensee applications and, therefore, could not judge their potential safety significance.

In addition, although WEC indicated to the NRC that it was only informed of 42 valve drawing weight and center of gravity deviations, WEC records indicated that, at the time of the SRC meeting, WEC had information that the problem was more extensive and a number of other plants would also be affected. The likely extent of this problem should have prompted WEC to perform a thorough SRC evaluation.

2)

In WEC's 1980 notification letter, WEC did not adequately inform its customers, especially operating nuclear plants, of all weight and/or CG deviations for CVC valves that were provided by WEC to customers for non-NSSS system applications.

3)

WEC letter NS-TMA-2236 to the NRC, dated April 24, 1980, contained factual errors and omissions.

WEC recently identified to the NRC, in letter NAIDCLC-93-01 of January a, 1993, errors that it found in letter NS-TMA-2236, as a result of an NRC question that was posed to WEC on January 14, 1992; however, NRC staff had previously found additional concerns with the 1980 letter.

For example:

9306170054 930610 PDR GA999 EMVWEST 99900404 PDR

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Mr. Carlo L. Caso 2

The NRC staff determined that the 42 valve drawings identified to

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WEC by' Bechtel Power Corporation (Bechtel) in a Bechtel letter of October 17, 1979, represented 33 different valve identification (ID) nu.bers.

The staff further determined that approximately 13 of the 33 valve 10 numbers that were provided to WEC by Bechtel were omitted from letter NS-TMA-2236. For example, valve ID number l-RA36RDS which was supplied to a number of plants including the Prairie Island facility, was one of the valve ID numbers that was omitted from the list attached on letter NS-TMA-2236.

WEC stated in letter NS-TMA-2236 that "the discrepancies in valve weight are small with only 5 valves being overweight by more than 20 percent." However, the 1989 WEC task force found that actually 9 valves were overweight by more than 20 percent; 6 additional valves were overweight by more than 19.4 percent; and the maximum deviation in valve weight that WEC was aware of was in excess of 43 percent.

Although the letter indicated that additional information would be provided to the NRC as it became available, the NRC was not made aware of any other WEC activities subsequent to the NS-TMA-2236 letter, nor was NRC advised that the initial list of 42 valve drawings was not complete, after WEC became aware of that fact in the 1980-1982 time-frame.

4)

Northern States Power Company's (NSP's) June 21, 1988, letter to WEC identified 14 CVC valve ID numbers, with associated valve drawing numbers where discrepancies had been identified regarding center of gravity and valve weight. This letter requested WEC to provide correct weights and cgs. NSP's letter also informed WEC that NRC Region III had i

requested information within 30 days regarding whether this was a 10 CFR Part 21 issue and requested that WEC provide an explanation of any additional or generic concerns regarding this issue. WEC's reply dated July 8,1988, included a list of corrected valve weights and indicated j

that only one of the 14 valve types were supplied to other facilities by WEC, and this valve drawing had been reconciled by WEC. ihis data that was supplied by WEC was then submitted to the NRC Region III Regional Administrator, by NSP letter dated July 21, 1988.

However, it would appear that WEC did not adequately evaluate this deviation or inform its customers as required by 10 CFR Part 21.

The NRC staff review of the associated WEC records appears to indicate that i

the Prairie Island, D.C. Cook, Salem, Diablo Canyon, and Zion facilities all received many of these same 14 valves from WEC on WEC multi-plant purchase order (PO) No. 546-CAH-91662 to CVC. Additionally, the NRC review of WEC's records indicated that some of the 14 valve types listed in NSP's June 21, 1988, letter were also supplied to approximately 10 other plants through three different WEC multi-plant P0s:

Specifically, PO 546-CAH-66164-BN, 546-CCP-157320, and 546-CCP-183620-XN.

It appears that the facilities identified above were not informed of this deviation, nor was the deviation evaluated for these facilities.

t' Mr. Carlo L. Caso 3

i 5)

Although we recognize that a number of appropriate follow-up and corrective. actions were undertaken by WEC in response to the CVC issue since 1980, we also note that it appears that WEC made incorrect statements to the NRC staff in letter NATD-CLC-136 of December 28, 1989.

f or enaple; Letter NATD-CLC-136 stated that for older-vintage plants,

"[a]lthough not a technical requirement in Westinghouse procurement documents (equipment specifications), drawings issued by Copes-Vulcan for pre-Pump & Valve Code (i.e. pre-1971) valves purchased by Westinghouse frequently included weights and/or cgs."

However, the records reviewed by NRC staff appear to indicate that valve assembly weight was included as a technical requirement in WEC procurement documents for pre-1971 plants.

For example, WEC's PO 546-CAH-66164-BN, dated December 16, 1966, to CVC for approximately the first half of WEC's pre-1971 built plants, required that outline drawings suitable for piping layout be submitted to WEC showing dry weight.

WEC's PO 546-H-91662B, dated March 4, 1968, with its associated equipment specification to CVC for the remainder of WEC's pre-1971 built plants, similarly required weight of the valve assembly to be shown on the valve drawings.

Additionally, although WEC staff stated to the NRC thct weights and cgs of valve assemblies were not applicable to. pre-1971 plants, the staff noted that Chapter 3, " Expansion and Flexibility," of Section 6, " Fabrication Details," of USAS B31.1, " Code for Pressure Piping-1955," required, in part, that significant piping system loadings creating stresses of different types and patterns, such as valve weight, needed to be considered. The staff further noted that the associated equipment specification for the P0s identified above referenced this requirement.

Furthermore, based upon NRC interviews and record reviews, it appears that the results of the WEC 1989 task force review were not fully factored into letter j

NATD-CLC-136.

For example, letter NATD-CLC-136 stated that WEC's " assessment of this alleged issue indicates that the information contained in letter NS-TMA-2236 was indeed accurate, complete, and represented the best information available at that time." However, as discussed in item 3 above, your 1989 task force determined that letter NS-TMA-2236 contained factual errors and omissions.

In summary, we are concerned with the implementation of your process to meet the requirements of 10 CFR Part 21 prior to our June 1989 inspection regarding this issue, and are concerned with your subsequent actions related to your review of the circumstances surrounding this CVC issue.

Although many of the weaknesses noted are somewhat historical and corrective actions and enhancements to your process have been performed, our review raises questions

Mr. Carlo L. Caso 4

regarding the quality of other 10 CFR Part 21 evaluations completed around the same time-frame.

Additionally, we are concerned with the apparent omissions and inaccuracies in WEC correspondence which have been associated with this issue.

As discussed by telephone with Mr. Tritch of your staff on June 10, 1993, an enforcement conference to discuss the findings from the NRC review of this matter will be scheduled in the near future. This conference will be conducted at our office in Rockville, Maryland. The purpose of the conference is to discuss the findings delineated in NRC Inspection Report 99900404/89-01, related to the CVC weight and CG issue and the concerns identified in this letter.

This conference will provide you the opportunity to point out any errors in our inspection report or investigation report synopsis, to present your perception of the effectiveness of your corrective actions, and to discuss any other information that will help us determine the appropriate enforcement actions we should take in accordance with the NRC Enforcement Pol i cy.

Subsequent to this forthcoming conference, you will be advised by separate correspondence of the results of our deliberations on this matter.

No response regarding these findings and conclusions is required at this time.

Sincerely,

[

p P. Kim erman, Deputy Director 1 vision of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation l

Enclosure:

As stated l

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SYNOPSIS On October 5,1989, the U. S. Nuclear Regulatory Ccomission (NRC) Executive Director for Operations requested the NRC Office of Investigations (01) initiate an inve'stigation into (1) whether Westinghouse Electric Corporation (WEC) willfully failed to notify its customers of " deviations" for which WEC does not have adequate information to evaluate pursuant to 10 CFR Part 21, (2) whether Wtl staff was instruclea or guided to cunsider commercial contractual considerations first in performing 10 CFR Part 21 evaluations of hardware deviations, and (3) whether WEC intentionally supplied incomplete, inaccurate and misleading information regarding characterization of a valve weight data problem in its April 24, 1980, latter to the NRC, No. NS-TMA-2236.

During the conduct of the investigation an additional allegation surfaced and was investigated; (4) whether WEC deliberately made material false statements to the NRC in their December 28, 1989, letter to the NRC and supporting attachment.

In that letter, WEC told the NRC that equipment specifications for pre-ASME and Pump and Valve Code (pre-1971) built plants did not require weight and center of gravity (CG) information, and the WEC assessment of the issue, indicated that the information contained in letter NS-TMA-2236, sent to the NRC on April 24, 1980, was indeed accurate and complete.

Jn late 1979, Bechtel Power Corporation (Bechtel) discovered Copes Vulcan Company (CVC) valve weight and CG deviations while performing an NRC IE Bulletin No. 79-14 related review of the Joseph M. Farley Nuclear Plant (Farley) balance of plant (B0P) piping systems.

Since WEC supplied those CVC valves to Farley, Bechtel requested WEC to provide corrected weights and cgs for 42 CVC valve drawings. After a preliminary review by WEC engineers and a WEC Safety Review Committee (SRC) decision that the issue was non-reportable under 10 CFR Part 21, WEC organized a task team to investigate the problem.

That preliminary review by WEC engineers and the task team resulted in WEC requests to CVC for weight and CG verification for approximately 280 CVC valve drawings which identified numerous CVC drawing revisions that were applicable to various WEC customer's nuclear facilities. The task team's findings which revealed the CVC valve drawing deviations regarding weight and CG corrections were not, however, adequately expressed and disseminated to all of the WEC customers affected by those CVC valve deviations.

This investigation has developed evidence suggesting that WEC with careless disregard, contrary to 10 CFR Part 21, failed to adequately inform its customers, especially operating nuclear plants, of weight and/or CG deviations relative to valves that were provided to these nuclear plants fcr their B0P 4

systems. Additionally, the WEC SRC concluded that none of the errors would cause a substantial safety hazard to exist even though it did not have knowledge af the specific licensee applications for the valves nor of the j

entire scope of the problem.

Further, at least four of the WEC staff that attended the SRC meeting had knowledge that a number of other plants would probably be affected by the CVC valve weight deviations. However, from April 11, 1980, when the WEC valve engineering group compiled and transmitted Case No. 3-89-013 1

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a preliminary list of other plants possibly affected by the CVC deviations, to CVC, until June 1989, WEC failed to either evaluate the additional errors that were continuing to be identified, or to inform the applicable operating nuclear plants so that these nuclear plants could evaluate the circumstances pursuant to 10 CFR Part 21.

For example, the" valve drawing for valve 1-RA36RDS was identified to WEC by Bechtel in 1979 as a farley valve that had drawing weight and CG deviations.

1-RA36PDS was also supplied by WFC to D.C. Cook Unitt 1 ami 2, Diablo Canyon Units 1 and 2, Prairie Island Units I and 2, Salem 1 and 2, Zion 1 and 2, V.C. Summer, Trojan, Byron, and Harris nuclear plants.

However, these plants were not informed by WEC that the CVC drawings for 1-RA36RDS contained incorrect data.

While this investigation developed some evidence to suggest that commercial considerations may have been a factor in the approach that WEC took with regard to which valve drawings CVC was directed to revise, the evidence developed was still not sufficient to substantiate the allegation that

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commercial considerations were the only factor; in WEC's 10 CFR Part 21 reportability decision.

This investigation has also developed evidence to show that with careless disregard, WEC made false and misleading statements to the NRC in the WEC letter to the NRC dated April 24, 1980.

In that letter WEC stated to the NRC that in regard to a CVC valve problem ir.volving discrepancies with valve weights and cgs, " Westinghouse has informed all of our customers of the existence of this discrepancy." The statement that all of the WEC customers were notified is, in fact, false since plants built using pre-ASME code requirements (pre-1971) were with careless disregard, mislead during the notification process.

Evidence developed during the investigation found that i

WEC in its April 24, 1980, letter to both the NRC and its licensees, provided an incomplete list of valve identification (10) numbers.

Cechtel originally in its October 17, 1979, letter to WEC, identified 42 CVC drawings which Bechtel suspected may have contained inaccurate valve data. According to WEC records, however, the 42 drawings corresponded in reality to only 33 CVC valve identification numbers.

However, in the WEC April 24, 1980, letter to the NRC, even though WEC delineated 41 individual valve identification numbers, due to a repetition of several valve ID numbers, in actuality, of the 33 CVC valve identification numbers identified to WEC by Bechtel, only 21 of these 33 valve ID numbers were ever transmitted to the NRC. Of the 12 valve ID numbers left off the WEC April 24, 1980, letter, several were supplied and installed in operating i

nuclear plants (e.g., D.C. Cook 1 and 2, Farley 1, Ginna, Indian Point 2, Point Beach 2, Prairie Island I and 2, Robinson 2, Salem 1, Trojan, Turkey Point 3, and Zion 1 and 2).

Consequently, as a result of the incomplete information contained in the April 24, 1980, letter, several operating nuclear plants were never made aware of potential over-stress conditions in their piping systems.

Case No. 3-89-013 2

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g Finally, this investigation has developed evidence indicating that WEC with careless disregard, made false statements in their December 28, 1989, letter to the NRC in response to Vendor Inspection Branch (VIB) inspection findings regarding the CVC valve issue.

In their letter WEC stated that pre-1971 WEC equipment specification used to purchase valves for customers (i.e., Prairie Island) did not require a valve weight and CG on the valve drawings. Contrary to that statement, however, the equipment specification for most, if not all, of the pre-ASME Code WEC designed plants did, in fact, require by equipment specif h at ion and associated procoru,ent docu =er,ts, weight cf the valve assembly on the drawing. The WEC letter also stated that their (WEC's) assessment of the issue indicated that the information contained in letter NS-TMA-2236, sent to the NRC on April 24, 1980, was indeed BCCJrate and complete.

This assertion also was untrue.

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Mr. Carlo L. Caso 4

l regarding the quality of other 10 CFR Part 21 evaluations completed around the same time-frame.

Additionally, we are concerned with the apparent omissions and inaccuracies in WEC correspondence which have been associated with this issue.

As discussed by telephone with Mr. Tritch of your staff on June 10, 1993, an enforcement conference to discuss the findings from the NRC review of this matter will be scheduled in the near future. This conference will be conducted at our office in Rockville, Maryland. The purpose of the conference is to discuss the findings delineated in NRC Inspection Report 99900404/89-01, related to the CVC weight and CG issue and the concerns identified in this 1

letter. This conference will provide you the opportunity to point out any errors in our inspection report or investigation report synopsis, to present your perception of the effectiveness of your corrective actions, and to discuss any other information that will help us determins the appropriate enforcement actions we should take in accordance with the NRC Enforcement Policy.

Subsequent to this forthcoming conference, you will be advised by separate correspondence of the results of our deliberations on this matter.

No response regarding these findings and conclusions is required at this time.

Sincerely, original signed by i

Roy P. Zimmerman, Deputy Director Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation

Enclosure:

As stated i

See next page for distribution and concurrence.

i i

Mr. Carlo L. Caso 5

QISTRIBUTION:

JSniezek JFouchard FMiraglia JGoldberg SHLewis JGluehman VIB R/F FMiraglia EPawlik DRIL R/F MPSiemien RIDS-IE:09 JGavula RFortuna RHoefling JFair GLongo AGallow Docket File 99900404/89-01 Central Files PDR CONCURRENCE:

0FFICE I:RIS-2:VIB SC:RIS-2:VIB BC:VIB:DRIL DD:DRIL:NRR TECH ED NAME JJPetrosino GCCwalina LJNorrholm RZimmermanf8 7 DGable DATE 05/13/93

• 05/13/93

• 05/13/93

• 06/10/93 05/12/93 *

[

COPY YES YES YES YES NO DOC 0FFICE ADT:NRR DIR:DRIL:NRR DE OGC 01 b#

NAME WTRussell

[1 CERossi JLieberman RKHoefling BBHayes DATE 06/01/93

• 06/10/93 06/01/93

• 06/10/93

• 06/01/93

• COPY YES YES YES YES YES NO DOC OFFICE BC:EMEB NAME JANorberg DATE 06/03/93

• COPY YES YES NO YES NO YES NO YES NO DOC r

• See previous concurrence.

i 0FFICIAL RECORD COPY DOCUMENT NAME:

CAS0LTR.PZ4 l

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