ML20040F618
| ML20040F618 | |
| 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 | |
| ML20040F399 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8202090413 | |
| Download: ML20040F618 (28) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT J
REGION IV Investigation Report No. 99900400/80-05 Program No. 51100 Company:
Babcock & Wilcox Company Facility:
Nuclear Power Generation Division
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Investigation at: Lynchburg, Virginia Investigation Conducted:
July-8-11; August 6-9, 1980 Investigator:
aIdM h a n,sqsg D. D. Driskill, Investigation Specialist Date Inspector:
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D,. T.' Fox, Inspector,' Program Evaluation Date lSec1Jion,VendorInspectionBranch 0
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N Reviewed by:
A E. GagTiardo, Director Date' Investiga# ion and Enforcement Staff Approved by:
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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 Industriet,.in Houston, Texas, on August 25-28, 1980.
8202090413 810722 PDR GA999 EMVACF 99900400 PDR
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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 investig " ion involved 276 investigator / inspector-hours on and off-site by one U. S. Nut. ear Regulatory Commission Investigator and two U. S. Nuclear Regulatory Commission Inspectors.
Results:
The allegation that B&W contracted for manufacture of valves 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 satisfactorily resolved was, in part, sub-stantiated 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.
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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 W..M'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.
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 substantiated 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.
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DETAILS SECTION A.
E&W Personnel Conta tg g
- C. A. Armontrout, QA Audit Section Leader
- J. C Dedden, Acting General Manager, 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
- B. 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. Morcate, 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 Allegation 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 problems resulted l
in B&W approving compromises in design'and quality of the valves.
1 I
6 Investigative Findings On July 8, 1980, Individual A was interviewed regarding his previously reported
-general safety concerns 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 and testing of the valves.
He stated the root cause of B&W's problems with the valves was doe to their having not conducted a thorough pre-contract design evaluation of the proposed WKM valves.
Individual A stated that B&W was aware, when contracting for the WKM valves,-that WKM had 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 required 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 the 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.
lodividual A stated it was his opinion that B&W had compromised good engineering principles in approving many of-these design specification changas.
During the interview, Individual A identified the following areas of. technical concern related to the WKM gate valves:
1.
Overpressurization protection of the WKM Pow-R-Seal valves was not provided in the valve open position.
2.
Operability of the WKM Pow-R-Seal valve was not established 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.
6.
Field maintainability of WKM Pow-R-Seal valves could not be established.
7.
Materials used in WKM Pow-R-Seal valves were not mutually compatible.
8.
WKM Pow-R-Seal valves contained a built-in " crud trap" which could pre-vent the valve from closing and/or inhibit maintainability of the valve.
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7 9.
Valve quality was degraded due to extensive design changes.
Review of B&W Records On July 8-11, 1980, and August 6-9, 1980, an extensive review of B&W records 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 capability were performed.
B&W placed WKM on their " Supplier's Status List" as " conditionally approved" on November 18, 1974, and as " approved" on September 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 WKM 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 I 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 my 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."
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 I
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
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p technically acceptable" for use on the Ohio Edison contract, focument2identi-fies the follewing 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:
g 1.
Internal relief not proven design.
2.
Backseat effect in open position could have greater than desirab1'e leakage.
N 3.
Orientation of drain connection potential interface problem whin valve mounted in position other than vertical.
4.
Valve 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 and 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 submittal by WKM poor.
4 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 internal relief valve which has been shown to perform as required to prevent hydraulic lock and/or over-l 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.
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"WKM engineering is weak and there are major disconnects in their total organization.
Because of their new pressure seal design, their casting 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 tha WKM people who were originally involved in the B&W orders o
are no longer employed by WKM which has caused a lack of continuity.
4.
"QCS consibers WKM to be fair from a general quality viewpoint; good in general workmanship and weak in quality control.
There has been constant,B&V 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 fovth above, we have found WKM design,f_u be technically unacceptable for the Ohio Edison evaluation.
At the time of discovery of most of the above it wasinot practical from a schedule or interchangeability standpoint to switch to another 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-testing stage.
Quality is questionable, capability for tight shut-off unproven, and maintainability will be more difficult than for a U
conventional wedge gate valve with a bolted bonnet.
The outlook for high availability from these valves is not encouraging."
On'A'ugust 21, 1978, B&W proposed to WKM thht a design review meeting be held at-S&W, Lynchburg, Virginia, on October 2, 1978, to discuss 19 major areas of
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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 Meet-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 i
6.
Adapter plate parallelism l
10 7.
Interchangeability of valve components 8.
Customer service 9.
Ensuring leak tightness 10.
Opening and closing of valve 11.
Installation of seats 12.
Parallellism of valve' bonnet-13.
Future design 14.
WKM manufacturing and' in-service experience 15.
Maintenance time.
16.
Design, features (stem an'd stem to gate connection) 17.
L'eakage 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 WXM (attached to Document 5) states "We assumed that WKM understood and would be in a position-to cisarm any concerns or reservations pertaining to the WKM valve design.
This did not-happen and was exemplified by the many action items which evolved from the meeting."
Document 6, a November 28, 1378'B&W memo entitled "WKM Technical Evaluation" was prepared subsequent to the resolution of concerns addressed in Document 4.
L Document 6 recommends " Accept the WKM valves as meeting the intent of the i
equipment specifications, assuming all commitments by WKM to supply supporting l
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 valse technically unsuitable.
.This evaluation also identified numerous problem areas which have been resolved and outlines the requirements for resolution of the' outstanding few areas of concern.
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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 disassembly tools.
They plan to demonstrate the tools on July 23, 1979." Document 7 additionally addresses an overall assessment of the resolved areas of concern.
Document 7 lastly states that "if a greater degree of operability assurance is desired than is now available, operational tests must be performed."
The B&W records reviewed disclosed numerous memoranda and letters relating to WKM's ft.ilure to meet software schedules and promised delivery dates.
Various letters from B&W management to WKM management addressed this problem area as well as WKM's failure 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 performance, 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 comp _romises 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 precurement 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 gate 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 August 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 cf 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.
Review of WKM Records Between August 25-28, 1980, an extensive review of WKM records relating to the B&W (WPPSS and PGE) gate valve contracts was conducted in an effort to obtain
12 information pertinent to allegations and technical concerns presented by Individual A.
Initial review efforts failed to disclose any documents relating to B&W's original request for bids for the gate valve contract or WKM informa-tion provided to B&W in response to such request.
WKM records reflect internal WKM efforts during 1976 and early 1977 to effect Pow-R-Seal gate valve design and analysis efforts and completion of mechanical drawings, for B&W approval, for the WPPSS and PGE nuclear application of the valve.
An undated, handwritten, 1977 WKM memo, which contained several attached memoranda and which responds to a B&W request for an explanation as to why changes were made in the Pow-R-Seal gate valve drawing states "The reason the drawings were changed was to make them correct.
The first set of drawings wcre WKM guesses, just to meet sales order commitment dates as close as possible.
Due to WKM management failures to provide personnel required in a time frame required, engineering was required to guess. We guessed fairly well.
However, the correct designs modified the guesses. What kind of answer can you give them?" The memo goes on to state "I am tired of WKM management forgetting their failure and trying to make it my problem... no matter how much we want to lie to customers, I refuse to lie to WKM people." This memo and related attachments are identified as Document 10.
WKM records reflect that WKM management recognized in January 1977 that their contract commitments to B&W were not being met and that increased efforts were going to have to be made.
A January 25, 1977 WKM memo, entitled " Babcock and Wilcox - Liquidated Damages "(hereinafter identified as Document 11) states "for WKM to earn additional orders, it is imperative that we perform to meet the commitments we have made relative to existing orders.
There is a good bit of unrest at Babcock and Wilcox along the lines that we are not going to meet our final promised shipping date and that we are not performing in accordance with the schedules we have established for submittal of software and other data."
WKM records indicate that schedule and production delays continue throughout the life of the contract.
A January 2, 1979, WKM Executive Management memoran-dum, hereinafter indentified as Document 12, states, "The dates that WKM gave B&W... were believed to be realistic at the time that they were given.
- This, once again, points out our inability to really reccgnize the real position that our nuclear power program is in."
Document 12 goes on to discuss B&W's position as a nuclear steam specialty supplier (NSSS) as related to other major NSS firms and states "Further, they made a serious mistake in that they took a chance on the unproven WKM nuclear gate valve (their comment, not mine),
and now they find that they ha*/e made an inadequate technical justification of our product.
After we shipped the initial eight 8" and 12" nuclear gate valves, they found that they must rejustify, on a technical grounds, our equipment. We are now caught in the backlash of the situation.
We have attacked it with openness and full cooperation with B&W, but to be quite frank some of the things they are worried about, o,3 in our eyes, inconsequential."
Document '2 goes on to discuss technical concerns identified by B&W and states, regarding -he internal relief valve topic "In our three day workshop with the l
13 B&W personnel back in November, we did find some calculation inaccuracies that amounted to seven B&W concerns, in reference to the Marotta relief valve stress reports. We have never used the Marotta relief valves before and part of our. contract with Marotta required their furnishing us with a complete stress report. We found that their ability to do a good stress report was lacking. However, the concern that B&W mentioned would in no way have affected the performance of the WKM gate valve for its intended function.' I think this is extremely important and points out that the paperwork is the only thing that is important and that the hardware, in fact, can be substandard."
While no evidence of intentional comprcmises in product quality were observed during the review of WKM records, documents were identified which indicate WKM and B&W utilized CVARs to obtain relief from original design specifications when those specifications could not be met.
A WKM view regarding CVARs is expressed in a January 19, 1979 WKM memorandum, Document 13, which states, "A CVAR (Contractor Variation Approval request) is prepared by WKM and submitted to B&W for approval.
Basically, it is a way of telling B&W formally that a WKM product does not meet B&W specs, and asking B&W to accept a product anyway."
A number of WKM telexes to B&W were observed identifying various test procedures on the gate valves which did not meet contract specifications and which request a determination as to whether a CVAR should be used to amend the specifications to effect satisfactory performance of the gate valve on the respective test procedure.
Interview of Individual C
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On August 26, 1980, Individual C, a WKM Contact Coordinator was interviewed.
Individual C stated he became involved with the B&W contract in about mid 1977.
He stated he does not have, nor has he ever seen, the B&W request for bid.
Individual C stated he would find it difficult to believe that B&W had not conducted a thorough engineering design review of the valves proposed by WKM prior to entering into a contract for production of the Pow-R-Seal valves.
Individual C stated that WKM was initially responsible for lengthy delays in beginning production of thc valves.
He stated this problem was the result of iaanufacturing priorities at WKM.
He stated the final design reports for the gate valve were not completed and approved by B&W until mid-summer 1977 and the delivery dates for the first eight gate valves was August 1, 1977.
Indi-vidual C stated the WKM foundry, where the castings for the gate valves were made, gave the B&W contract a low priority which also resulted in a late start on production of the gate valves.
Individual-C stated that due to the late start in production of the gate valves and the liquidation of damages penalty, related to B&W's contract with WPPSS, the production phase of the valves was a "real rush a panic." He stated that although testing problems did exist with the valves, the problems were resolved in WKM engineering and correction of specifications were effected with CVARs.
Individual C stated the WKM
14 quality control department would not have accepted any compromises in quality of the valves and that there were, to his knowledge, no compromises whatsoever by either WKM or B&W during production of the gate valves.
Individual C stated he thought any allegation to the contrary was untrue.
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, reported 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 pctential for over-pressurization and subsequent valve nalfunction or failure exists whenever a significant increase in system temperature occurs such as during system 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 inability to open the valve, to structural failure of internal parts of the valve or failure of the bonnet.
Con.;equences range from loss of function 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 racial 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 Onofre nulcear power stations may not have valve body overpressure protection in the valve-open position.
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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 ef_ 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 235 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 valve operator would be energized to determine opgrability of the valve.
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 requirements for stroke (operating) time; however, after modification of the design and improvements of the manufacturing operations, only 8 of the 46 B&W valves tested had stroke times (thirteen to sixteen seconds) in excess of specification limits (ten seconds).
B&W deemed that these 8 were acceptable (via a Contractor Variation Approval 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 valve 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 was deemed acceptable by B&W (via a Contractor Varia-tion Approval Request) in that the leakage was through the valve packing and not through the valve itself and therefore did not impair the intended function of the valve.
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16 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 undersized 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-dicted.
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 maintaining and servicing WKM POW-R-SEAL valves under field service conditions.
However, WKM records indicate that they developed and sucessfully demonstrated to B&W, the special tooling needed for maintaining and servicing these type valves under field service conditions.
7.
The results of the investigation indicated that contiguous materials used in POW-R-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 to 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 positior..
Conceptually, the void could become filled with crud over a long operating period, which then could prevent the valve from closing.
Furthermore, radioactive materials contained in the crud could reduce maintainab','lity 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 stream would be during the trans-ition time (less than 16 seconds) when the valve was opening or closing.
9.
The results of the investigation indicate that there may be some overall degredation 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 j
17 indications problems are corrected, that the valves will 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 ceport.
The identified concerns and findings are as follows:
1.
Unacceptable cracks on the interior and linear indications on both the interior and exterior of WKM Pow-R-Seal valves were detected.
Finding:
The tesults of the investigation indicate that the Babcock and Wilcox Company purchased 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 New York, 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 completed and shipped approximately one half of the valves to Portland General Electric, Tennessee Valley Authority and Washington Public Power Supply System when the fabri-cation defects were detected in delivered valves.
Linear indications-in Class 1 decay heat removal system dropline isola-tion valves and " cracking" in a Class 2 core flooding r.ystem isolation valve were detected in WKM POW-R-SEAL valves delivered to WPPSS. The unacceptable indications in the decay heat rnmoval isolation valves are located in the inlet and outlet conduit regions on the inside and outside of the valves. _The ".: racks" in the core flooding system isolation valve are located in the body crotch region above the seat 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.
This item has been identified as an unresolved item for additional follow-up in Inspection Report 99900308/80-02.
2.
Carbon steel retaining clips were used in place of stainless steel clips to hold some of the "Marotta" relief valves together as an integral unit within~ Pow-R-Seal valves.
1
r
~
3 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. WKM was notified of the error by Marotta on July 17, 1979. WKM convened its MRB on July 24, 1979, which determined that the error caused no safety-related problems with WKM valves.
However, WKM informed Bechtel Power Corporati'on and Babcock & Wilcox to whom WKM had shipped valves with the cainon steel clips.
BPC and B&W were each asked to review those systems in which the affected valves were installed to ascertain whether there would be any safety related problems that could be caused by the eventual release of the poppet, spring and clip into the process stream.
BPC and B&W responded and each took different actions.
Bechtel requested that WKM supply stainless steel plugs with axial flow holes which would retain the relief valve poppet'in the event of deterioration of the carbon steel clip. WKM management stated that some of the plugs were installed by WKM personnel 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 installed 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 Safety 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 of 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 POW-R-SEAL valves.
5.
"Marotta" pressure. relief valve operating characteristics failed to meet B&W specification requirements.
j m -
- - - - - - - ~
e
~
19 Finding; 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 requirements.
ALLEGATION NO. 2 The valves being manufactured by WKM were found to be technically unacceptab'e for use in another contract proposal, for similar valves used in a similar 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 to 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 evaluation of valve designs, the pri-mary considerations of which are documented in the attached letter." The memo goes on to say "While the technical concerns indicated are sufficient to pre-clude placement of additional orders with WKM, they are not, in our opinion, sufficient to force replacement of WKM valves in other backlog contracts." The 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 14, identified herein as Document 2, cites the following seven reasons why the Wi(M valve design was "not technically acceptable" for use on the Ohio-Edison contract:
1.
Internal relief valve not proven design....
2.
Backseat effect in open position could have greater than desirable leakage.
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 expecta; ion 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 (hereinafter identified as Document 15), addressirg 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, particular
-attention should be payed to paragraph 'G' of the WKM meeting report, as sucess-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 schedulup continues to deteriorate.
I am concerned at the manufacturing progress on tiie TVA valves and especially the WPPSS valves which are ominously close to the !!quidated damages date.
This will be escalated to WKM management."
Interview of Individual C On August 7, 1980, a B&W engineering manager, Individual C, was interviewed and stated, in response to questions concerning WKM valves being found not techni.
cally acceptable for the Ohio-Edison project, that the determination was. based on B&W evaluations of WKM performance which are discussed in Document 2, the contents of which are reported as findings for Allegation No. 1.
Individual 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.
y:
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m-21 Other Investigative Aspects During the previously identified August 25-28, 1980 review of records and interviews. conducted at WKM Valve Division, Houston, Texas; no documents or
-statements were made which indicated WKM personnel were aware that B&W had found WKM. gate valves technically unacceptable for use in the Ohio-Edison
. project.
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 liqui _dation of damages penalty for delivery of the valves ~past the contracted date.
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 testing approval of the valves. -He stated the penalty was the primary motivating factor leading to B&W compromising the quality of the valves.
Individual A further 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 valves would be provided to WPPSS.
1 Review of B&W Records I
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 l
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 L
l necessity of~ resolving administrative, manufacturing, and testing problems-with WKM in order to avoid liquidation of damages penalties._
Thistreview of documents noted that between December 1978 and February 1979, the concern regarding the liquidation of damages penalty became a very-important considaration associated l
with the resolution of testing problems with the_ valves.
During this period letters from B&W management personnel to WKM management personnel urging the timely employment of every resource available in completion of the valves to i
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."
t 22 Internal B&W memoranda were identified which indicates efforts were made during the summer of 1978 to locate an alternate supplier for the WPPSS and PGE v6'ves.
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 appropriate until additional details are available regarding the suitability of WKM valves for their intended purpose."
Interview of Individual B On August 7, 1980, Individual B was intervie'.. d 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.
I.'dividual 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 that these efforts coincide with the preliminary technical evaluations 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 c'elays 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, when 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 liquidatiol of damages penalty being imposed.
Review of WKM Records During the aforementioned review of WKM records, various B&W and WKM documents were identified which addressed B&W's being subject to liquidation of damages penalties for late delivery of WKM valves to WPPSS.
Internal WKM documents, such as formerly identified Document 11, addressed the B&W liquidated damages concern and "doing all practically possible to make the dates we have committed to."
Documentation was observed which related an ever growino concern regarding the liquidated damages as WKM delays in manufacturing problems continued.
Futhermore, letters to B&W were observed which identified the causes for delays such as snow storms, equipment failures, and labor strikes which impacted upon delivery dates and liquidation of damage dates.
A May 2, 1978 WKM letter to B&W regarding delays due tc snow storms and equipment failures contained a file copy notation stating, "... this does not necessarily get B&W off the hook for the 22 days we mentioned.
In fact, the three days lost due to snow storms may be the only thing they can salvage from WPPSS, if that.
Also, it does not get WKM off the hook or relieve us of deliverying the valves by 7/1/78."
B
@ER E7.9Q Id] INFORMATION 23 A June 23, 1978 WKM letter to B&W entitled " Schedule Delays'," hereinafter identified as Document 16, responds to a B&W 1etter which purportedly st.ated WKM would be held accountable for any damages incurred by B&W due to late delivery of the valves.
Document 16 states "This is to notify Babcock & Wilcox
)
that WKM will not accept any back cIiarges from Babcock & Wilcox because of late deliveries."
It goes on to state that "WKM intends to continue expediting all possible-to maintain, to improve existing scheduled delivery dates and will work with_ Babcock & Wilcox to supply any additional support that may be used by Babcock & Wilcox to gain relief from scheduled dates that Babcock & Wilcox had committed to Washington Public Power Supply System."
(the foregoing quote is reported, with an apparent error, as presented by Document 16) A May 25, 1979 i
internal WKM memorandum, hereinafter identified as Document 17, which, among other topics, discusses the priority to be placed on a B&W contract for valves to be supplied to PGE, states "I believe that in this situation of limited resources, etc., that those customers who actually have a crying need for the valves should get the priority at WKM.
Af ter all we neglected other customers to get the B&W's WPPSS valves out in time for B&W (and WKM) to avoid liquidated damages of
~
$17,000 per day."
Document 17 goes_on to state "In my opinion, when WKM got B&W off the hook on liquidated damages with WPPSS, we regained some measure of their confidence (even tho' ugh we had scared the hell out of them).
I, too,*would 4
like to get it all back.
In general B&W is a superior customer."
WKM records review disclosed no documents which identify or propose compromises in quality or good engineering practices to effect meeting of delivery dates and avoiding liquidation of damages penalties.
Interview of Individual D On August 26, 1980, Individual D was interviewed.
As previously stated (in-Allegation 1, Investigative Findings) Individual D stated that the actual manu-facturer's process for the WPPSS gate valves ordered by B&W was a "real rush" situation.
Individual D stated the high priority eventually given to the pro-duction of these valves was primarily a~ result of the liquidation of damages penalties associated with B&W's contract with WPPSS.
Individual D stated B&W pointed out this fact repeateoly to WKM and finally threatened to make WKM j
responsible for the damages.
10 CFR PART 2.'790 INFORMATION DELETED j Individual D stated he persona 17y had worked closely with B&W contract representatives in order to effect a better working relationship with B&W and get the valves
. delivered prior to the assessment of liquidated damages.
Individual D stated his efforts were successfully accomplished.
Individual D stated positively that there was no compromise of the. valves to avoid liquidation of damages penalties.
I 1.0.CFR 2.7.90..(d) INFORMATION W
pgg7cnATG ORIGI M L Cc'M d
24 ALLEGATION NO. 4
-That overpre'ssurization of the WKM core flood and decay heat removal valve was r safety concern which was not properly evaluated and satisfactorily resolved.
Investigation Findings OnJuly8,198b,IndividualAwasinterviewedatwhichtimehestatedthemajor problem identified during B&W's procurement of safety-relateri 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 check 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.
ReviewofB&WRecog 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 chronology-related to overpressurization of the gate valve in the closed position:
1.
Place purchase order - relie.f 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.
4.
-B&W or WKM suggests this location is not satisfactory because of seismic considerations (this is not documented).
-5.
WKM decides on internal location of relief valve.
6.
B&W argues against internal.elief valve suggesting a drilled hole.
7.
WKM tests first relief valve.
Tests end in failure.
8.
WKM tests "Marotta" relief valve - results are okay.
f~
~
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 operatior. in the relief valve.
11.
October 27, 1978, 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 the 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 evaluation 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 1etter to WPPSS concerning the reportable safety concern.
It is notedThat WPPSS reported this safety concern, as required by 10 CFR 50.55(e),
to the Nuclear Regulatory Commission, Region V, telephonically on February 9, 1979, arid per letter dated March s, 1979.
(Note:
Failure by B&W to report this significant safety deficiency under the provisions of 10 CFR Part 21 was identified n a non-compliance with regulations.
See NRC Inspection Report 99900400/8u-03 for details).
Review of WKM Records The previously identified review of WKM records disclosed much of the same docu-mentation (primarily consisting of letters and telexes) by B&W and WKM relating to the overpressurization issues.
WKM records reflect that no technical evalu-ations of either of the overpressurization concerns identified by B&W, were conducted by WKM.
Except for the following WKM did not cause the other pur-chasers of POW-R-SEAL valves to evaluate the safety significance of the lack of overpressure protection in the valve open (or closed) position.
An October 23, 1978, WKM telex to Bechtel Power Corporation, addresses the identification of the potential for overpressurization of the POW-R-SEAL valve in the open position and states "WKM cannot advise you whether this release is positively required or not unless we know your exact process
_l
r 26 conditions for each valve location." This document proposes three alternatives, any one of which, if incorporated into the Bechtel valve being manufactured by WKM, which would relieve the overpressurization of the valve in the open position.
This telex and subsequent letters to and from Bechtel, which initiate a remedy for the overpressurization concern, are identified as Document 20.
(Note:
Failure by WKM to report this significant safety deficieiicy under the provisions of 10 CFR Part 21 was identified as a non-compliance with regulations.
See NRC Inspection Report 99900308/80-02 for details).
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 which 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.
r CAPTIONED DOCUMENTS.
Copies of all documents, identified herein, which relate to the foregoing allegations, are maintained in the NRC,-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..The following is a' list of documents utilized and identi-
.fied in this report:
Document 1 - 11/3/75 B&W memo,'with attachments, entitled, " Technical Evaluation - DH Cooler Outlet Valves - Revision 1" Document 2 - 7/14/77 B&W memo, with attachments, ertitled, " Remotely Operated Valves" Document 3 - 8/3/78 B&W memo, with attachments, entitled "Suitsbility 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".. Technical 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 WKM memo, entitled " Babcock & Wilcox - letter of 12/14/78" l
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, j
Borg-Warner and CCI" Document 16 - 6/23/78 WKM letter to B&W entitled " Schedule Delays" i
Document 17 - 5/25/79 WKM memo i
r 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 1etter 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"
.