ML20128C227
| ML20128C227 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1990 |
| From: | Driskill D, Van Cleave V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128C150 | List: |
| References | |
| FOIA-92-231 4-88-028, 4-88-28, NUDOCS 9302030358 | |
| Download: ML20128C227 (28) | |
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CAS E -No. 4-88-ma
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Nuclear! Regulatory Commission
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Report of Investigation 7
S-W CONTROLS:
SUSPECTED iilSREPRESENTATION OF REPLACEMENT VALVE PARTS
.. - Office of Investigations Reported 'oy 01: - R!y
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.4 Titlei S-W CONTROLS, INC.:
SUSPECTED HISREPRESENTATION OF REPLACEMENT-VALVE PARTS
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Licensee:
Case No.:': 4-88-028.
q S-W Controls
- Report Date:. January 9,1990 35980 Industrial Road; Livonia, MI 48150 Control Office:, 01:P.I V '
U Docket No.:- 99901140 Status: CLOSED-P Reported by:
Reviewed and approved'by:
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Virginta-Van Cleave, Investigator
, Donald D.- Driskill, Director 4
Office of' Investigations
- 0ffice of' Investigations-Field Office, Region IV.
Field'0ffice, Region.IV:
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- Participating Personnel:
Joseph J. Petrosino,- Inspector Terrence L. Tinkel, Consultant r
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r SYNOPSIS In November 1988, the Nuclear Pegulatcry)Comission (NRC) requeste company officials knowingly and intentionally provided substandard and/or counterfeit parts to the nuclear industry. A 10 CFR, Part 21 report was filed by Consumers Power Cotrpany (CP), Palisades Nuclear Plant (Palisades), which alleged that parts found in internal Masoneilan-Dresser (M-D) valves had not been manufactured by M-D facilities but had been manufactured by Control Valve Specialists, Inc. (CVS) and Cor-Val. The nongenuine M-D parts were purchased through 5-W, an authorized M-D representative.
The Office of Investigations (01) investigation detennined that S-W knowingly sold secondary source replacement valve parts to Palisades. However, these parts were all for comercial grade items only and none were-purchased by CP for use in safety related systems.
The parts were subsequently dedicated for use in safety related systems by CP without adequate r turance that the parts would perform as required in these systems.
The seco. ary source industry was found to be a widespread one but one which does not constitute an illegal activity. 01 determined that, since secondary sourcing is common, the utilities must accept responsibility for the adequacy of the parts which they purchase both from secondary sources and original equipment manufacturer representatives.
No information was uncovered during the investigation to indicate that 5-W intenticnally attempted to mislead Palisades into believing secondary source parts' were genuine N-D parts.
Neither the parts nor the manila taes attached to them were labelled with the M-D name, logo, or trademark.- The references on S-W's invoices to a M-D part number i.e., 302460-000-163, Hasoneilan Seat:
Ring, was an inadvertent error on the part of the clerk who-input the orders to the computer.
The investigation detennined that two distributors were purchasing secondary source parts with unusual requests on their purchase orders. The requests included a "do not etch" request and a request to sandblast the edges of seat rings to simulate investment casting. Although theso parts were not sold to nuclear power plants, the requests appear to have been made in an effort to mislead the' end user as to the source of the valve replacement parts.
Consequently, this practice is being referred to the Federal Trade Comission for whatever action it deems warranted, r.ea un t.co noo 1
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Case No. 4-88-028 2
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ACCOUNTABILITY'-
The following portions of this Report of Investigation-(Case No. 4-88-028) will not be included in the material placed in the-POR.- They censist of pages 2 through 26.
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9 TAE.LE OF CONTENTS Pagg SYN 0PSIS.......................................................
1 ACCOUNTABILITY.................................................
3 APPLICABLE REGULATIONS.........................................
7 DETAILS OF INVESTIGATION.......................................-
9-Purpose of Investigation..................................
9 Background................................................-
9 Interview with Robert H. M0 ATE, President and Robert C....
9 M0 ATE,'vice President, CVS..............................
9 Interview with ' Willi 6m F. SAMPLE, President, 5-W..........
10 Interview with L inda SICARD, C lerk, 5-W...................
11 Review of S-W Records......................................
12 Interview with Robert J. CAMERON, Senior Attorney, Dresser Industries......................................
12 Interview with Daniel BOURGE0IS, Froduction Panager, ti-D.,
13 Interview with John BUECHLER, Material-Management (Procurement) Superintendent, Palisaces.................
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Feinterview with SAMPLE...................................
15-4 Hee t i ng w i t tfGIM8lGfM F B I A g e n t......................, 15 6 %
NRC Information Notice Nurber 88-57 and Supplement 1......-
15 Review of NRC Vendor Program Branch inspection Report-Number 99900094/88-01...................................
16 Review of hRC Vendor-Program Branch inspection 'leport Number 99901137/89-01...................................
17-Review of NRC Vendor' Program Branch Inspection Report-Nurber 99901139/89 01...................................
17 Interview with Robert L. CARPENTER, President, PV&E.......
18-Review of PVAE Customer Recorcs...........................
-18 Interview with Paul CLARK, President,.HYP.................
19 Rev tew of HYP Cu s tome r Re cord s............................-
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Review of NRC Vendor Program Branch Inspection Report Nurber 99901145/89-01...................................
19 A g e n t ' s A n a ly s i s.......................................... 20-Willfulness / Intent........................................
20 Conclusion................................................
23 SUPPLEMENTAL INF0 PRAT 10N.......................................
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LIST OF EXHIBITS...............................................
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J-APPLICABLE REGULATIONS--
l 10 CFR, Part 50, Appendix B-4 1
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7 DETAILS OF INVESTIGATION Purpose of__ Invest _igation This investigation was initiated to determine whether company officiais at S-W Controls, Inc. (S-W), formerly Sample-Webtrol, Livonia, Michigan',(M-0) knewingly orovided counterfeit and/or substandard Masoneilan-Dresser parts to tie nuclear industry and/or represented the parts to be safety related parts.
Background
On October 21, 1988, a 10 CFR, Part 21 repert was filed with the Nuclear Regulatory Cormission (hRC) by Consumers Power Company (CP)(Exhibit 1).
Palisades Nuclear Plant (Palisades),regardingF-Dvalveparts' deficiencies Palisades had found internal replacement parts in M-D valves which were not.
manufactureo by M-D.
The Part 21 report alleged that parts dedicated for use in basic ccmponents were found to have been manufactured by Control Valve Specialists, Inc. (CVS) and Cor-Val, both located in Houma, Louisiana, and might not meet M-D specifications.
The Part 21 report stated that 12 purchase orders for 63 pieces were identified as procured from 1983 to 1968 as M-D parts, but were found to not be genuine M-D parts. These nongenuine M-D parts were all purchased through S.W, an autn1rized M-D representative, s
On November 18, 1988, a letter was forw rded by H-D to NRC's Office of Nuclear Peactor Pegulation (Exhibit 2).
In tht, letter, William T. ALLEN,' quality nanager for P-D North American operations, identified the valve parts: located at Palisades as counterfeit and manufactured by unauthorized sources. ALLEN further alleged that the parts were not manufactured to M-D standards and hao a potential to malfunction. ALLEN identified counterfeit parts located;at Palisades as:
plug ste<as, stem to plug anti-rotation pins, and seat rings.
He additionally stated that there was a potential for_other counterfeit parts to be located at Palisades such as valve plugs, bushings,- cages, and packing box components. ALLEN further alleged that the counterfeit parts were supplied to Palisades by an authorized M-D representative ~'in violation of.M-D policy.
On November 22, 1988, 01 received a verbal request for investigation from the NRC Vendor Branch regarding allegedly counterfeit valve parts sold to Palisades by S-W.
This was followed by a written request for investigation by-the Executive Director for Operations dated December 27,1988(Exhibit 3).
Interview with Robert H. H0 ATE, President, and Robert C. M0 ATE, Vice President, CV5 The NOATEs were interviewed by NRC Investigator Virginia. Van Cleave,. NRC Vendor Branch Inspector Joseph PETROSINO, and Sonalysts Inc, consultant,
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Terrence TINXEL, on November 29, 1988, at CVS's office in Houma, Louisiana l
(Exhibit 4). When PETROSih0 asked to review CVS's records, R. H. HOATE stated L
that these records were confidential and he would not allow HRC access to them simply on a verbal request.
Case No. 4-88-028 9
R. H. MOATE stated that in approximately June 1973, CVS received authorization from H-D to manufacture replacement valve trim parts. Since that time, according to CVS's president, the company hao also manufactured replacement parts for other manufacturers including Fisher, Copes-Vulcan, Valtek, and Hemel Dahl.
In addition to manufacturing replacement valve parts, CVS repaired and refurbished valves for their customers who were primarily in the petrochemical incustry.
R. H. MOATE stateo that in 1981, M-D terminated its agreement with CVS for the manufacture of replacement valve trim parts.
Although R. H. V0 ATE stated that he returned the original drawings to M-0, he said the termination of this agreement did not prohibit CVS from manufacturing replacements for H-D valve parts and they continued to do so. According to P. H. M0 ATE, S-W was a CVS customer for replacement M-D valve parts prior to and subsequent to 1981.
R. H. M0 ATE said CVS supplied solely comercial grade parts and had never knowingly supplied any valve parts for nuclear safety related applications.
CVS's president recalled only one small order for valve parts supplied to a nuclear f acility - a sale of comercial grade valve parts to Louisiana Power & Light's (LP&L) Waterford 3 plant in approximately 1981.
R. H. MOATE stated that since cany CVS customers were oistributors, it was possible that the distributors sold CVS parts to nuclear plants. He asserted he had r,o way of knowing the final destination of all CVS parts sold by his company.
R. H. M0 ATE stated that CVS's customers usually crdered parts by identifying the name brand manufacturer's part number. CVS manufactured the requested part in accordance with the drawing which was applicable to that specific part number.
R. H. M0 ATE said that it was his understanding that if a techr.ical change was made which required a drawing change the associateo part number was diso changed.
R. H. MOATE refused to provice copies of sales invoices or other documentation relating to CVS sales to S-W.
He referred the investigator to S-W for these records.
Interview with William F. SAMPLE, President, S-W SAMPLE was interviewed by Investigator Van Cleave, PETROSINO, and TINKEL on December 1,1988, at his office in Livonia, Michigan (Exhibit 5). According to SAMPLE, S-W served as the authorized representative for M-D valves in parts of Michigan and Ohio which included two CP nuclear plants - Palisades and Big Rock Point.
SAMPLE stated that S-W also acted as a distributor, which was an-independent business involved in purchasing and reselling parts to customers.
As an authorized M-D representative, 5-V was not allowed to sell valve competitor's product lines, but they could do so while acting as a distributor, according to SAMPLE.
S-W had filled past orders from nuclear power plants by either purchasing from M-D, the original equipment manufacturer, or from a secondary source manufacturer, such as CVS or Cor-Val. Purchase orders identified as safety related or those requiring certification and documentation such as a Certificate of Compliance (C of C) or a Certified Material Test Report (CMTR) were processed by initiating a purchase order to M-D.
No secondary source manufacturers were utilized to fill nuclear safety related orders or orders which required any type.of certification documentation. SAMPLE stated that orders from CP which were for comercial grade items and did not request any Case No. 4-88-028 10
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type of certification were fillec either by M-D or by a secondary source manufacturer such as CVS or Cor-Val. SAMPLE stated that parts purchased from CVS and Cor-Val were never dropshipped to the nuclear plant. Cor-Val or CVS shipped the items to S-W where they were repacked and shipped to CP along with a S-W packing list.
According to SAMPLE, he began purchasing replacement parts from CVS in the early 1970's when CVS was authorized by M-D to manufacture and supply M-D replacement valve trin parts. SANPLE stated that at that time, N-0 told S-W to obtain commercial grade replacement parts from CVS for M-D valve parts.
Although M-D terminated its agreement with CVS in approximately 1981, SAMPLE stated that S-W continued to purchase replacement valve parts from CVS and Cor-Val. SAMPLE reiterated that all parts purchased from CVS or Cor-Val were -
comercial grade and were used to fill purchase orders from CP which did not request any type of certification documentation.
SAMPLE stated that he was unaware if CP realized they were receiving secondary source replacement parts-for M-D valves. SAMPLE said that although S-W did not represent the parts as being manufactured by M-D, ntither did they identify them as manufactured by a secondary source. SAMPLE stated that one could probably not visually distinguish differences in parts manuf actured by P-D and those manufactured by a secondary source manufacturer.
- However, SAMPLE stated that H-D supplied parts were packaged and labeled with a part number and the M-D name and trademark, whereas parts purchased from secondary source manufacturers were simply marked with the M-D part number on a plain shipping tag.
He stated these parts were not marked M-D or identified in any way as M-0 parts.
The NRC representatives were provided with examples of M-D and secondary source valve parts and-found none of the secondary source parts were tagged with a name brand manufacturer's name or trademark.
SAPPLE stated that he had reviewed S-W's records and found that 77 orders from CP were processed by M-D,10 by CVS, and 2 by-Cor-Val. SAMPLE stated that all secondary source manufacturers utilized the same name brand part number in order to identify the part. The s61es invoices prepared by S-W, the final copy of which was the packing list, reflected the secondary source replacement parts to be a N-D part number i.e., 302460-000-163, Masoneilan Seat Ring.
SAMPLE stated that he believed the invoice reflected M-D because in the sumer of 1983, S-W switched to a computer billing system. At that time, it was his-belief the clerks input the part number ard the computer matched the part number with the name brand manufacturer. As a result, according to SAMPLE, since secondary source manufacturers utilized the identical part number, the brand name M-D was printed by the computer.
_Interv_tew with Linda SICARD, Clerk, S-W SICARD was interviewed by Investigator Van Cleave on December 1,1988, at her office in Livonia, Michigan (Exhibit 6). SICARD stated she was the clerk who input invoice information into the computer utilizing the handwritten orders taken by S-W's inside sales representatives.
She stated that she input part numbers into the computer.
If the computer did not automatically print the name brand manufacturer, she said she added the manuf acturer's name "so CP would know that they were getting a M-D part." SICARD oenied knowledge of secondary source purchases and said she did not realize that the parts referenced on the invoices were not always M-D parts. SICARD alleged she Case No. 4-88-028 11
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.a w thought she was providing her customers with the nare of the mapufacturer of the part which they were receiving. She said she would have never intentionally listed a manufacturer's name on an irvoice had she known it was not the company which was supplying the parts that were being purchased.
Review of S-W Records Investigator Van Cleave reviewed purchase orders free CP to S-W; invoices from S-W to M-D).CVS, and Cor-Val; and invoices from Cor-Val and CVS back to (Exhibit 7 purchase crders that were not identifiec as safety related and did not request any type of certification documentation (Exhibit 8). When any certification docurrentation was requested on the purchese order from CP, S-W purchased the items from M-D.
Many of the purchase orders from CP simply referenced a part number and did not specify M-D.
Purchase orders from S-W to CVS and Cor-Val sometines specified M-D and other times simply listed the part number (Exhibit 9). However, invoices from Cor-Val and CVS simply remed the part number and cost and did not irnply that the parts being supplied were M-D parts (Exhibit 10). The invoices from S-W to CF listed the parts as a M-D part number i.e., 302460-000-163, Masonellan Seat Ring (Exhibit 11). These were computer generated invoices, the final copy of which was utilized as a packing slip and sent to'the nuclear plant along with the referenced parts.
[nterview with Robert J. CAMERON, Senior Attorney, Dresser Industries CAMERON was interviewea by Investigator Van Cleave on January 6,1989, at his office in Dellas, Texas (Exhibit 12). CAMERON statea that he was a senior attorney for Dresser incustries and represented M-D which was purchased by Dresser Industries approximately 3 years ago. CAMERON stated that M-D currently utilized no authorized M-D parts _nanufacturers. However, from the early 1970's until approximately 1981, M-D had authorized CVS to manuf acture-parts for M-D.
CAMERON stated that M-D employees in Avon, Massachusetts, were unable to locate the original M-D - CVS contract and consequently they were unaware of its specific terms.
CAMERON stated that although H-D did not like the secondary source manufacturing of its parts, he did not believe it constituted an illegal activity as long as the secondary source manufacturers did not utilize the M-D name or trademark or represent to the public that the parts were genuine M-D parts. CAMERON stated that even if the valve replacement parts:had been patented at one tire, it was his belief that H-D had no patent protection in this area and there was no patent infringement. He stated-he had been told by ALLEN that the parts in question located at Falisades were not marked with the M-D name or trademark. Consequently, CAMERON stated he did not believe there was any violation of criminal or civil law. CAMERON admitted that M-D had utilized the term " counterfeit" in correspondence to the NRC. CAMELN said he believed this to be a misnomer and he did not believe the parts were counterfeit in the legal sense of the word.
CAMERON stated he did not believe S-W violated the contract they held with M-D.
He provided Investigator Van Cleave with a blank copy of the type of sales representation contracts utilized by M-D (Exhibit 13). These contracts authorized companies to act as sales representatives or as distributors.
CAMERON stated that a distributor could not be legally prohibited from selling Case No. 4-88-028 12
ccrpetitive products due to a possible violation of the United States antitrust laws. CAMERON admitted that many M-D representatives, including 5-W, sold other product lines. CAMERON further asserted that to the best of his knowledge the secondary source use of the name brand H-D part number was not a violation of law. He stated the part number was not protected by patent, trademark, or by anything else under U. S. law. He said the part number was simply a way of identifying the item in question and could be utilized by other companies although it might be misleading at times to do so.-
CAMERON further admitted that the secondary source. industry was widespread and Dresser even occasionally purcnased secondary source parts. Although CAMERON asserted that he did not believe there was a violation of criminal or civil law, he said he was still concerned that there might be a potential safety problem because the parts purchased from CVS and Cor-Val might not racet M-D drawing specifications.
1HVESTIGATOR'S NOTE:
On Decembc-22, 1988, CP filed a second 10 CTR, Part 21 report with the NRC (Exhibit 14).
This report stated thLt.6 of 97 valve pins examined by CP were found to be non-conforming in that they had undersized expanded otameters.
Five of these six nonconfortning pins were supplied by M-D's Houston, Texas, facility and the remaining item was supplied by H. H. BARNUM, a previously authorized M-D representative.
in addition to the valve pins, 7 of 51 seat rings inspected were found to be nonccafoming regarding manufacturing tolerances. The manufacturer of five of these seat rings had not been-identified. The two remaf ring seat rings, which were purchased in 1978, were manufactured by CVS, which at that time was an authorized M-D manufacturer.
hterviewwithDanielBOURGE015, Production _Manacer,N-0 BOURGE0IS was interviewed by Investigator Van Cleave on January 26, 1989, at his office in Houston, Texas (Exhibit 15).
BOURGE0IS stateo that the M-D Houston facility supplied conrnercial grade valve parts to customers ano manufacturer representatives, but all orders for nuclear grade items were processed ano filled by M-D's Avon, Massachusetts f acility. BOURGE0IS stateri that the valve pins referenced in the Part 21 report filed by CP in Dececber 1988 could have been manufactured by M-D in Avon, Massachusetts, or could have been a buy out from an authorized manufacturer.
BOURGE0IS stated that without the purchase order number or service order number, he could not trace the origin of the five valve pins in question.
BOURGE0IS accessed M-D's vendor data base to determine if H-D utilized CVS or Cor-Val as an authorized manufacturer of valve parts. Although Cor-Val was not listed on H-D's vendor history data base, the records indicated that M-D's Avon, Massachusetts, facility had placed seven orders with CVS over approximately the last year and a half. These purchases were for carbon tipped parts utilized primarily in the mining industry, which N-D representatives stated M-D was not equipped to manufacture.
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INVESTIGATOR'S NOTE:
Investigator Van Cleave later providgd BOURGE0IS with the CP purchase order number, approximate date of receipt, ano part number of the five nonconforming valve pins. On February 7,1989, BOURGE0IS telephoned Investigator Van Cleave ano told her he was unable to locate a sale to CP or to S W in May or June 1987 of the specific part number provided to him.
InterviewwithJohn_BUECHLEk,_HaterialManagement(Procurement)
},uperintendente Pe l i sa o,e s, BUECHLER was interviewed by telephone by Investigator Yan Cleave on February 2,1989 (Exhibit 16). He stated that he was the contact point and responsible party concerning corrective action by CP as a result of the i
substitute M-D parts received at Palisades. According to BUECHLER, approximately 12 shipments of valve internal parts which CP had believed were mar,ufactured by M-D were actually manufactured by CVS or Cor-hl.- BUECHLER explair.ec that CVS had been an authorized manufacturer of replacement valve trim parts for M-D from ap >roximately 1973 until 1981. However, BUECHLER claimed that the aart whica was initially brought to Consumers Power's attention as not aaving been manufactured by M-D was for a valve which had been designed approximately 5 years ago.
Consequently, the part coulo not have been canufactured by CVS while the company was authorized to manufacture M-D parts. BUECHLER admitted the purchase order for this part was not for safcty related items.
BUECHLER stated that as a result of the discovery of nongenuine M-D parts, CP performed a 100 percent inspection of all M-D parts on hand at Palisades.
As a result of this inspection, CP filed a second Part 21 report with the:NRC.
on December 22, 1988.
Palisades inspection cisclosed that 6.of 97 pins and 7 of 51 seat rings inspected were found to be nonconforming regarding manufacturing tolerances.
BUECHLER stated that in his opinion, the valve pins nonconformance was not significant. According to-BUECHLER, the pins were purchased by Palisades as cornercial grade but were inspected at _ Palisades and put on the shelf as safety related items.. Five of the seat rings were purchased as comercial grade items and never upgraded to safety related. The-remaining two were purchased and placed on-the shelf as safety related items.
The seat rings were purchased from 1976 to 1979.. According to BUECHLER, Falisades had not been able to determine the manufacturer of five of these rings. Two were found to have been tranufactured by CVS, which was an authorized M-D manufacturer durir.g that time period.
BUECHLER stated that they tested all seat rings for leakage, but the leakage found was not any
- worse whether the parts were manufactured by M-D, CVS, or anyone else. In BUECHLER's opinion, the discrepancies found were not' serious and could not be attributed to a specific manufacturer.
BUECHLER stated that purchase orders were recuisitioned_ from CP's corporate office in Jackson, Michigan. The items were shipped directly to Palisades but the invoices were-sent to Jackson for payment af ter Palisades' inspection-and acceptance of the parts. BUECHLER stated he believed that.CP had not asked
.for comercial grade C of Cs because a decision was made that it-was not necessary to obtain them.
BUECH1.ER stated that approximately 63 parts on hand at Palisades were found to have been manufactured by CVS or Cor-Val. According to BUECHLER, neither the-Case No.. 4-88-028-
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- parts themselves nor the manila tags-attached t6 them had the name M-D or M-Djs logo or trademark printed or stamped on them s.The parts had manila tags attached to them on which was handwritten a. generic -parti number. ' BUECHLER -
saio-the parts were so small that even the genuine M-D parts-usually_ were not' stamped with the M-D name, logo, or trademark.
P.einterview with SAMPLE reinterviewed by Investigator Van Cleave by' telephone on SAMPLE was briefly(Exhibit 17). SAMPLE said that altho' ugh S-W never-February 6, 1989 dropshipped items purchased from an outside vendor when S-W was acting as a distributor, items purchased from M-D were dropshipped.- SAMPLE stated that the handwritten purchase order by S-W noted the invoice wasrdropshipped to Jackson, Michigan, because that was'a different address from where the. parts-were shipped. SAMPLE fu' Mer stated that the banowritten rotation-on S-W's-purchase orders to CVS and Cor-Val which occasionally appeared stating -
" Consumers Power," was added only on S-W's ccpy of the purchase orcer for their recorcs, Heeting withdgFBI Acent On February 2.1969, Investigator Van Cleave met with FBI Special' Agent @
v regarding S W (Exhibit 18a). According to@an AssistantLUnited States Attorney ( AUSA) in Michigan reed an a'rticle in the newspaper, which identified
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parts provided by S-W to the nuclear industry as counterfeitD ' He telephoned the local FBI office and requested that the FBl _ investigate the matterJD
,iv was unfamiliar with this subject matter and Investigator Yan Cleave provided: if l
her with aniwers to her questions regardingOthe potential]BI investigation.
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On February 8,.1989, elephoned -Investigator Van. Cleave and stated that '
she hac spoken by telep one with the Michican case agent who said he. believsd the case wculd not be pursued-(Exhibit 18b). Shetstated that the AUSA, af ter did-not-believe prosecution was-being apprised of the actual situation, V thejsarre possible simply on-the basis of the use art number which he -
f believed was probably not-illegal. According to
.the FBI intended to:
close the case on S-W without further action.
NRC Information Notice Number 88-97 and Supplement'l-On December 16,.1988, the NRC publishea en Information Notice 88-77 regarding--
secondary source valve'replacenent parts for M-D valves (Exhibit 19).: The-
'Information Notice, advised that-addressees should review their.' policy tior; acceptance of va.1ve replacement parts, particularly those! purchased for safety related systems,. and contact the appropriate' manufacturers or distributors to confirm authenticity of any; questionable. par _ts.
On April 28,1989, supplement I to:Information Notice 88-77 was-issued by thi E
NRC (Exhibit 20)'.
In this supplement the NRC concluded that potentially substandard valve replacement-parts could enter nuclear. sites either directly from secondary source manufacturers or from. distribution-centers of original equipment manufacturers. The licensee in question ordered parts for safety related applications as comercial grade and failed to verify that-the parts would: perform their required function. The authorized distributor procured the parts from both the original equipment manufacturer and secnndary. sources--
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without ensuring that the parts were equivalent. Additionally,.the original equipment manufccturer purchased parts from subcontractors and did not verify that the parts would fulfill their function.
Review of NRC Vendor Procram Branch inspection Report _ Number _99900094/88-01 This inspection repcrt was prepared by PETROSINO at the conclusion of an inspection of M-D, Avon, liassachusetts, on December 12-16,1988 (Exhibit 21).
During the course of the inspection, PETROSIHO was told that CVS was licensed by and contracted to M-D from approxirnately Septeter 1,1975 until September 14, 1980, as an authorized manufacturer and supplier of H-D products.- M-D representatives stated that they terminated all business relations with CVS in approxinately 1980 and requested the return of all H-D drawings. H-D stated that CVS did not return all M-D drawinos as requested.
It was noted by FETROSINO that H-D continued to routinely procure components from CVS af ter the 1980 contract terminatien date anc was currently procuring carbide tipped valve plugs f rom CVS.
The inspection repcrt stated that the M-D midwest regior.al sales tranager said that CVS was not authorizeo to manufacture and sell valve parts to the nuclear power industry.
He further alleged that H-D sales representatives were not authorized to buy replacement valve parts from CVS for the r,uclear pcwer industry, although M-D was unable to locate a copy of its agreement with CVS.
The M-0 sales manager admitted that occasionally M-D gave tacit approval to its sales representatives to purchase replacement valve parts from secondary scurces when M-D was unable to provide the parts within the timeframe recuired by the custcmer.
M-D representatives indicated that in order for a_ secondary source to have the capability of correctly producing a comercial grace part for a N-D valve in a nuclear application, three items were recuired:
1)sufficienttechnical Information such as detailed crawings and design tolerances; 2) supplemental requirerents applicable to the original nuclear valve order; and 3) a quality program equal to or better than that utilized by.M-0.
Additionally, M-D claimed that some secondary source manufacturers might be using reversed engireered drawings which could lead to differences, particularly for dimensional tolerances.
PElROSIN0 reviewed M-D's standard contract signed by its industrial sales representa;1ves. This contract did not specifically outline a method to be used when processing a nuclear power plant order. li-D's QA manager stated that all sales representatives vere instructed to pass all orders from nuclear power plants to M-D's Avon facility to determine if the part was nuclear or comercial grade. He provided two M-D memos, one dated May 8,- 1986, and one dated August 15, 1988, which stated in part that all inquiries and orders for nuclear related parts were to be directed to Avon. However, PETROSINO stated that the midwest sales manager admitted that it was possible that an experienced H-D sales representative might feel capable of determining if a part ordered by a nuclear plarc -tas for a safety-related system. Should he determine such a part was no; ror a safety-related system, he might fill such an order from his on-hand stock which could contain nonauthorized substitute replacement parts. As a result, according to the midwest sales manager, whether a nuclear plant received an authentic H-D part or a secondary source part was partially dependent on the individual M-D sales representative's Case No. 4-88-028 16
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-._--.--..-.w-a bandling of the specific order. PETROSINO determined that the.M-D - sales representative contract did not in itself preclude the M-D representative from dealing with competitors or secondary source suppliers. PETROSINO concluded that it was possible for an NRC licensee to receive nongent.ine M-D parts from an authorized M D sales representative. He further concluded that the responsibility for assuring the adequacy of purchased matertal and its.
conformance to the procurement docucents rested with the hRC licensee, peview of NRC Vendor Prnaran__ Branch inspection Report Number 99901137/89_-01 This inspection report was written by PETROSINO at the conclusion of his and TINKEL's inspection of CVS conoucted May 31 to June 1,1989 (Exhibit 22).
R. H. P0 ATE did not allow the inspectors to review his general accounts j
imNble records or his customer list and only provided them with records regarding any specific customer about whom they asked him. The NRC inspectors provided R. H. M0 ATE with the names of approximately six material suppliers ano all utilities licensed by the NRC.
R. H. M0 ATE stated that two of the traterial suppliers and two of the utilities were CVS customers. The Purchase Orders (P0s) relating to NRC licenseo plants were for cumercial grade-products and did not mention safety related or nuclear requirements.
During the inspector's review of orders f rom Process Yalve and Equipment Company (PV&E), Chagrin Falls, Ohio, a request was noted on several different documents in 17 PO packages where seat rings were ordered. This request was-for CVS to machine the ears, sandblast to simulate investment type castings, ano polish the surf aces of the seat rings.
R. H. M0 ATE and -R. C. M0 ATE stated that the sandblasting was for cosmetic purposes only, irrelevant, and-not intended to indicate anything of significance.
However, PETROSINO noted that the sandblast effect on the bottom of the seat r_ings indicated that the seat ring was a machined investment casting rather than a fully machined seat ring using bar stock material. During an October 1988 meeting of M-D and NRC perscnnel, M-D personnel stated that the sandblasted surface on seat' rings was an attempt to simulate an investment cast machined seat ring of the type typically produced by M-D.
The inspector noted in the inspection report that
-i PV&E's request for sandblasting the seat rings appeared to be an attempt to simulate genuine investment cast M-D valve seat ring replacements to the end users.
Rev_tew of HRC Vendor Program Branch _ Inspection Report Number 99901139/89-01 An inspection of Gemoco, a division of Sequa Engineered Services, Houma, Louisiana, was conducted by PETROSINO and TlHXEL on June 6-9. 1989
~
(Exhibit 23). The inspection was conducted'as a follow-up to the inspection-of M-D during which Gemoco was identified as a company that advertised replacement parts for M-D valves.
During the inspection of-Gemoto,.
representatives of the company stated that Gemoco vibro-etched each valve trim component that it manufactured with " GEM" or "GEMOC0" and the associated part number. However, Gemoco representatives stated that this procedure was not followed in cases where the customers required no etching or perinanent marking or parts iney were purchasing or in cases where the part was too small to etch.
During the inspection, PETROSINO noted that several internal Gemoco finish work order fonns from Capital Westward Systems (CWS), San Jacinto, California,_
Case No. f.-88-028 17
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and from PV&E stated "do not etch." GemocorepresentativestoldPETROSINO j
that these two companies specifically requested that their ordered parts not be identified with Gemoco markings. The inspector identified eight CWS P0 packages and two PV&E PO packages that ccitained this request.
F..
the PY&E orders the components were actually ordereJ from Gemoco through Midwest Valve Parts Company (MVP). The sales manager for O moco stated he was unaware of any technical reason for requesting that the 6'moco name not be etched on Gomoco parts. He theorized that PV&E and CWS might want to represent Gemoco parts as original equipment manufacturer parts to their customers.
Interview with Robert L. CARPENTER, President, PV8E I
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i CARPENTER was interviewed by Investigator Van Cleave and PETROSINO on June 20 & 21, 1989, at his office in Chagrin falls, Ohio (Exhibit 24).
He
^
stated that PV&E was no lenger affiliated with N-D as an authorized representative and consequently did not provide safety related components and parts to the ruclear industry. They continued to sell parts and components to the fossil fuel industry and cortnercial grace parts to two nuclear plants -
Davis Besse and Perry. He stated that PV&E sells secondary source parts as replacements parts for original manufacturer parts. He stated that if a i
nuclear plant should order a "Q" part, PV&E would purchase the part only from the name brand manufacturer.
CARPENTER said that PV&E requested Gemoco not to etch parts which PV&E ordered from them simply to prevent PV&E's customers from identifying the origin of the parts and crdering directly from Gemoco. CARFENTER stated that he was uncertain why PV&E requestec CVS to round off the seat rings and sandblast q
certain surf aces on items purchaseo from CVS.
However, he believed that most of these orders went to Standard Oil, which wanted their parts to look like j
the original parts. He saic that PVaE did not intentionally attempt to deceive its customers regardiag the origin of the seat rings but admitted his customers were probably unaware of the manufacturer of the valve trim components.
Review of PV&E Customer Records Investigator Van Cleave and PETROSINO reviewed records for all utilities and numerous additional PO packages regarding sales by PV&E (Exhibit 25). They reviewed each of the 17 PV&E P0 packages identified during previous inspections at CVS and Gemoco to contain unusual requests. This review determined that in all 17 cases, with one exception, the parts were not supplied to utilities. The majority of the parts were sold to Standarc 011 Production Ccepany. The one exception, PO #40254, was for parts shipped to Cleveland Electric's Avon Lake fossil plant facility.- It was noted by the investigator that this P0 specifically stated that Cleveland Electric would not accept substitutions for M-D valve trim.
Regardless of this requirement H
on the P0, PV&E provided Cleveland Electric with CVS manufactured seat rings which were sandblasted to simulate M-D seat rings, i
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.i Case No. 4-88-028 18 j
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Although PV&E supplied some of its customers with CVS seat ringt manufactured from bar stock that-were modified to resemble investment cast type seat rines and with unetched Gemoco parts, no examples were identified where PV&E supplied these type parts to any. NRC licensed f acility.
Interview with Paul CLARK, President, MVP CLARK was interviewed by Investigator Van Cleave and PETROSINO on-June 22, 1989, at his of fice in Chesterland, Ohio (Exhibit 26). CLARK stated that MVP was an authorized manufacturer's representative for Gemoco. He saio their territory extended from the New York / Pennsylvania-line _to Wyoming and Colopato with the exception of Illinois and Wisconsin. He said that MVP sold few' parts to nuclear plants and had not sold any parts relating to a-safety system. He said that any parts cold to a nuclear plant were comercial grade.
Pjview of MVP Customer Records investigator Van Cleave and PETROSINO reviewed customer P0 records for all utilities with a neclear plant within MVP's sales region (Exhibit 27). They also reviewed copies of PY&E orders to MVP that requested no etching on its-procured parts, as noted during a previous KRC inspection at Gemoco. During this review, it was noted that MVP provided safety related Fisher Controls and M-D valves and valve parts to the DC Cook Nuclear Plant in 1986 and 1987.
These safety related parts were supplied when MVP was an authorized sales representative for certain original equipment manufacturers.
No deviations were noted regarding these safety related P0s.
The review of the PV8E orders failed to identify any additional P0s with th' e
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"do not etch" request.
The two subject P0s revealed the notation "do not etch" on the interoffice orders. NRC-representatives identified that the valve trim components on these two P0s were shipped to nonlicensees. The review of records at MVP failed to identify any _ sales of secondary source parts or components to the nuclear industry.
Review of NRC Vendor Program Branch inspection Report Nun.ber 99901145/89-01 PETROSINO conducted an inspection of CWS as a follcw-up to the previously' referenced inspection of Gemoco conoucted on June 6-9,1989(Exhibit 28). The-inspection of Genoco identified sales of valve trim components and/or parts to CWS where CWS mandated no etching or permanent markings on parts they were purchasing. Although the CWS P0s did not specifically require this, the internal Gemoco finish work order forms stated "do not etch." :PETROSINO was told by Gemoco officials that CWS specifically requested that their. ordered parts rot be identified with Gemoco markings.
Officials at CWS stated that the company conducted business with only two NRC licensees - Arizona Public Services Company (APS) and Southern California Edison (SCE). NRC inspectors reviewed approximately 260,afety and nonsafety related P0 packages regarding SCE ano APS orders. Also reviewed were CWS PCs to Gemoco from 1985 to the present. The review of CWS P0s to Gemoco identified two orders that were sent to San Onofre Nuclear Generating Station (SONGS) and numerous orders that went to SCE fossil power plant facilities.
The majority of the Gemoco secondary source parts were sold to comercial nonutility customers.
' Case No. 4-88-028 19
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PETROSIN0's review of the SCE and APS document files incicated that CWS 1
procured all parts and/or components that they supplied to Palo Veroe and SONGS from the original equipment manufacturer or its official representative with the exception of two nonsafety related orcers for H-D valve trim parts that were supplied to SONGS. PETROSINO verified with SCE personnel that the parts associated with these P0s were utilized in a nonsafety related system.
PETROSINO concluded that although CWS ordered Geinoco secondary source parts i
and components from Gemoco with the reouest "do not etch," CWS supplied nuclear facilities with original equipment manufacturer parts ano components for both safety and nonsafety related orders with the exception of the consafety orders referenced above.
- k Acent's Analysis This investigation revealed extensive purchases and sales within a secondary source supply market. These secondary source suppliers provide replacement parts for original equipment manufacturer parts and components, usually at a considerably lower price than similar replecement parts could be purchased from the original equipment inanuf acturer.. investigator Van Cleave noted that the mark-up by the intermediary company such as CVS or PV&E was approximately 10-percent for M-D parts; approximately 30 percent for Gemoco parts purchased through MVP; and as much as 100 percent for parts purchased from CVS.
Consequently, there is a financial incentive for the supply houses to ut11fre secondary source materials and/or parts.
Further, there appears to be no prohibiticn in the use of such secondary source parts or cettponents, it is an industry accepted practice to utilize the oricinal equipment manufacturer's part number for simplicity's sake regardless of the-source of the part. M-D's own attorney admitted that he did not believe-this constituteo an illegal practice. The AUSA in Michigan, through-the FBI, also stated he did not believe this was an illegal practice.
Willfulness / Intent A.
A 10 CFR, Part 21 report was filed with the NRC by CP, Palisades, alleging that parts dedicated for use in basic components were not-manuf actured by M-D facilities, were manufactured by CVS and Cor-Val, andmightnotmeetM-D'sspecifications(Exhibit 1).
B.
R. H. H0 ATE stated that he sold CVS secondary source parts to distributors, was unaware of the final destination for these phrts, but had never knowingly sold parts to a nuclear facility for use in a safety related system (Exhibit 4).
C.
The invoices prepared by.CVS to S-W did not' refer to the parts sold to S-W as M-D parts. The parts were referenced with solely a part number, although the part number was the original equipment manufacturer's part number (Exhibit 10).
D.-
SAMPLE stated that he had not sold any secondary source parts to a nuclear facility to fill any safety related orders or any orders requiring any type of certification documentation. He admitted he substituted CVS and Cor-Val parts for H-D parts to fill orders from CP which were for comercial grace items (Exhibit S).
Case No. 4-88-028
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d E.
Sales invoices prepared by S-W reflected the secondary source replacement parts to be a M-D part number 1.e., 302460-000-163, Masonellan Seat Ring.
SAMPLE claimed this was due to a computer billing system that matched a part number with a name brand manufacturer.
None of the secondary source parts themselves were marked with the M-D name or trademark. SAMPLE denied intentionally attempting to mislead the utility into believing it had received M-D parts (Exhibits 5 and 11).
F.
SICARD admitted that she input part numbers into the computer and addea the manufacturer's name so customers would know the name brand of the part that they were receiving. She denied knowledge of secondary source purchases and said she would never have intentionally listed a manufacturer's name on S-W's invoices had she been aware this was not the company which was supplying the parts being purchasec (Exhibit 6).
G.
A review of S-W's records disclosed that all secundary source parts sold to Consumer's Power were related to those P0s which were not identified as safety related and did not request any certification documents.
Additicnally, many of the purchase orders from Consumer's Power simply referenced a part number and did not specifically order a M-D part (Ephibits 7, 8, 9,10, and 11).
H.
CAMERON stated that although M-D did not like the secondary sot ece manufacturing of its parts, the practice did not constitute an illegal activity as long as the secondary source manufacturer did_not utilize the M-D name or tracerark or represent to the public that the parts it was supplying were genuine M-D parts.
It was his belief that M-D had no patent protection in this area and there was no patent infringement.
He acmitted that the parts in question at CP were not marked with the M-D name or trademark. Although M-D had characterized these parts as counterfeit in written connunication to the NRC, this was a misnomer ano the parts were not counterfeit in the legal sense of the word.
He said that he did not believe there were any-violations of criminal or civil law in this specific case.
He further stated that he did not believe the part nurber was protected by patent, trademark, or any U.S.
law. He said he believed the part number could be utilized by other companies although it might be misleading at-tires to do so (Exhibits 12and2).
I.
BOURGE0IS stated that the valve pins provided by his company and referenced in a Part 21 report filed by CP in December 1988 could have been ranufactured by M-D or by a M-D authorized ranuf acturer.
He admitted that M-D purchased carbon tipped parts utilized in the mining industry from CVS since M-D was not ' equipped to manufacture these parts (Exhibit 15).
J.
BUECHLER stated that following the discovery of nongenuine M-D parts at-CP, they performed a 100 percent inspection of all M-D parts on hand at Palisades. This inspection revealed certain non-conforming conditions in some pins and seat rings.
BUECHLER stated in his opinion the valve pin's nonconformance was not significant.
He further alleged that leakage found during tests of seat rings were not any worse whether the seat rings were manufactured by M-D, CVS, or anyone else. BUECHLER admitted that pins and seat rings were purchased by Palisades as connercial grade caw He a-M-0?8 21
- z xxa z=
=:===w
=
4
.y n - 3 but were dedicated in many instances to be used in safety related systems -
after the parts were received at Palisades.
BUECHLER stated that neither the secondary source parts themselves nor the manila tags attached to them had-the name M-D or M-L's trademark or logo printed or stamped on them. The nongenuine M-D parts had manila tags attached to them on which' was handwritten a generic part number (Exhibit-16).
K.
Investigator Van Cleave was notified by the FBI that the AUSA-in Michigan did not believe prosecution was possible-simply on the-basis of the'use of the same part number which he believeo was not illegal. The FBli intended to close the case on S W with no action warranted-(Exhibit 18).
L.
NRC Information Notice 88-97 and Supplement I stated that CP ordered parts for safety related applications as corrinercial grade and failed to verify that the parts ordered would perform their required function.
5-W procured parts from both the original equipment manufacturer and secondary sources without ensuring that the parts were equivalent (Exhibits 19and20).
M.
NRC inspection report 99900094/88-01 stated that M-D continued to routinely procure components from CVS and was currently procuring carbide tip valve plugs from CVS.
The M-D sales manager admitted that occasionally M-D allowed its sales representatives to purchase-replacement valve parts' from secondary sources. M-D representatives further admitted-that it was possible one of their authorized sales
+
representatives might fill an crder for a part for a nonsafety related system from his onhand stock which could contain nonauthorized substitute replacement parts. The M-D sales representative: contract _does not preclude a M-D representative from dealing with competitors c.r secondary sourcesuppliers(Exhibit 21).
N.
An inspection conducted at CVS revealed that PV&E placed 17. orde_rs for seat rings in which they requested that-CVS machine the ears,. sandblast to simulate investment type castings, and polish the surfaces of the seat rings. Although the MOATES asserted that this was not-intended to "t
indicate anything of significance, the-request for sandblasting the seat _
rings appeared to be an att nipt to simulate genuine investment cast M-D valve seat ring replacements to the.end users (Exhibit 22).
O.
An inspection _of Gemoco revealed that two companies, PV8E and CWS, requested that Gemoco not etch or permanently mark its name on parts which they were purchasing. Gemoco's usual. procedure was to vibroetch each part with " Gem" or "Genoco" and the essociated part number.. The sales manager for Gemoco admitted these two companies might wanti to -
represent Gemoco parts as original' equipment manufacturer parts to their customers (Exhibit 23).
P.
CARPENTER stated _his corpany did not. sell parts and components r safety related systems to the nuclear industry. He asserted that PV8E requested Genoco not to etch parts simply. to prevent PV&E's customers from-identifying the origin of the parts and ordering directly.from Gemoco.
He theorized that PY1E requested CVS to round off seat rings and to.-
sandblast-certain surfaces on items purchased frcm them because these parts were for Standard Oil which wanted the parts to look like the Case No. _4-88-028 22 l
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original parts. He denied intentionally attempting to dec,eive his customers regarding the origin of seat rings but acmitted that his robably be unaware of the manufacturer of the valve customerswouldp(Exhibit 24).
trim components Q.
A review of records at PY&E determined that all but one of the oroers with unusual requests made to CVS and Gemoco were sold to non-utility customers.
The one exception was shipped to a fossil plant facility for-Cleveland Electric. Although PV&E surplied some of its customers with CVS seat rings manufactured from bar stock, modified to resentle investner,t cast type seat rings, and with unetched Gemoco parts, PV&E did not supply any of these type parts to any NRC licensed facility (Exhibit 25).
R.
CLARK stated he had not sold any parts relating to a safety system for a nuclear plant since approximately 1987 when MVP was the authorized iepresentative for several original equipment manufacturers (Exhibit 26).
S.
A review of HVP customer records indicated that the two purchase orders f rom PY&E with the notation "do not etch," were shipped to DuPont and Sachs. Records at MVP failed to disclose any sales of any secondary source parts or components to the nuclear industry (Exhibit 27).
T.
An inspection of CWS revealed that although the company purchased seconcary source parts from Gemoco and requested that.Gemoco not etch these parts with their name or part number, none of these secondary source parts were sold to a nuclear plant for a safety relatto system.
In fact, CWS only had two P0s for cor:rercial grace items sold to a nuclearpcwerplant(Exhibit 28).
Conclusion S-W intentionally sold secondary source valve parts to Palisades. However, these parts were all for comercial grade items which were in some instances deoitated at Palisades for use in safety related systems wf thout Palisaces-providing adequate verification that the parts would fulfill their functions in safety related systems.
No information was uncovered during the investigation to indicate that S-W intentier. ally attempted to mislead Palisades into believing secondary source parts were genuine.M-D parts.
Neither the parts nor the manila tags attached to them were labelled with the N-D name, logo, or trademark. The references on S-W's invoices to a M-D part number i.e., 302460-000-163, Masoneilan Seat Ring, was an inadvertent error on the part of the clerk who input the orders to the computer.
Although the use of original equipment manufacturer part numbers is misleading, it is not an illegal practice. The use of secondary sources is prevalent throughout the country in many industries. Consequently, the nuclear power plant must accept responsibility for ensuring that the parts which they order and receive are adequate for the use for which they are intended.
Case No. 4-88-028 23
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SUPPLEMENTAL,INf.0RMATION Severalicompanies,Lsuch as CWS and PV&E,. requested changes on_their'procuredL valve parts _ from secondary sources. These included the request.to not-etch the Gemoco name-on Gemoco parts and the request _ to sandblast!the ears-to -
simulate-casting.- These requests may be an. effort to make it, appear-to the.
O end user that the parts are genuine M-D parts.
Although these parts do_not
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appear to have been sold to _any NRC' regulated utility, the; practice seemed
-questionable to the.investigater.
Investigator Van Cleave informally _ contacted the Federal Onyune:26,1989,(FTC):inDallas, Texas. She spoke with Investigator.Clarie Trade Commission BLALAMAN in an effort to detarmine whether or not this: type of practice might be considered _ illegal-by the FTC.
Investigator BLACKMAN stated ~ that'in. her
' opinion it could be-considered illegal under decepth e; trade practices-provisions-if;the companies were providing these secondary source parts under-false pretenses. She forwarded e copy of the FTC's Act.to Investigator Van
-Cleave and referred her to.Section 5 of this act..!nvestigatorf BLACKHAN: told the HEC investigator that she would be interested to see the completed NRC report and perhaps schedule an interview.between herself, Investigstor Van.
Cleave, and an FTC. attorney to determ!ne_whether the FTC mightiwant to pursue-an investigation of.PV&E and/or CWS unoar-their regulations, q
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LCase No..4-88-028;
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p.
LIST Of EXHlBITS Exhibit No.
Description 1
Consumers Power Contany 10 CFR, Part 21 Report, dated October 21, 1988.
2 Letter from Masonellan-Oresser to NRC, dated Noverber 19, 1966.
3 Executive Director for Operations Request for Investigation, dated December 27, 1989.
4 Report of Interview with R. H. NOATE and R. C. POATE, dated Noverber 29, 1986.
E Report of Interview with SANFLE, dat?d Decertber 1, 19E8.
0 Report of Interview with $1 CARD, dated December 1, 1988.
7 5 W Records Review.
8 Purchase Crders froc.Consuwrs Tower to 5.W.
9 turchase Orders from S-W to CVS and Cor-Val.
10 lovoices from Cor-Val and 'Y$.
11 Invoices from S W to Consurers Power, 12 Report of Intervicw with CAMEF.CN, dated knuary 6,1959.
13 Ceneric Nasonellan-Sales Representathe Contract.
14 Cce.surers Pcwer Corepany 10 CFR, Part 21 Report, cateo December 22, 1968.
16 Report of Interview with BOURGE0IS, dated January 26, 1989.
L 16 Report of Interview with BUECHLER, dated February 2,1989.
17 Heen of Conversation with SAMPLE, dated February (,1989, and February 8,1989, 18 Hemos of Conversation with W dated february 2,1985.
,. '/d.
F:
19 HRC Information Notice Nurber 88-97.
.20 NRC Information Notice Nunber 88-97, Supplement 1.
ram Branch Inspection Report NRCVendorProg/88~01.
21 Number 99900094 Case No. 4-88-028 25
1.
,, o 22 hRC Vendor Program Branch inspection Report Nureer 99901137/89-01.
23 NRC Vendor Program Branch inspection Report Hunter 99901139/89 01.
14 Report of Interview with CARPENTER, dated June 20 & 21, IF#9, 25 Review of PV1E Custoner Records.
26 Report of Interview with Cl. ARK, dated June 22, 1989..
27 Review of HYP (vstoner Records.
28 NRC Vendor Program Branch inspection Report Number 99901145/89-01.
Case No. 4-88 028 26
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