Nuclear Diaphragm Valve Product Line

Nov 7: Here is the update.

As with VY’s SRV’s actuator seals, a formulation had gone obsolete...so they replaced it with lesser materials.

So 10% of their customers need an equivalent or similarly durable material...ITT just threw these guys under the bus.   

What sticks out is how amazingly complex a issue this is over a simple diaphragm. Think about this with millions of components in the industry...

And a limited cycle rate or life time is mind blogging complex problem when you consider the 18 month operating time of our reactor and the limited opportunities to replace these guys while up at power in a radiation field.

How many venders are throwing the whole nuclear industry under the bus...

While the Ml test program was considered a success and the new compound was launched in 2008, there were still 10% of those conditions for which ITT was unable to meet the full qualification target of 7,500 cycles, and this was a source of some concern for certain ITT customers. Those customers had purchased the previous MI diaphragm made from the polymer that had gone obsolete, and they would contact ITT for replacement valves or diaphragms subject to those conditions. ITT would note that while the data did not permit the diaphragm to be sold for that condition, the diaphragm could be used at a restricted service life base on the limited data that did exist. This was a common practice that had been used successfully with the previous MI formulation, and customers with those certain operating conditions agreed to use the diaphragms with a specific reduced life.

May 15:
Yea, can you even imagine what a phone call by the NRC to ITT raising questions on the diaphragms. No matter what was said, it would imply the NRC is taking a interest in it and it's going into a  official investigation. They would be doing back flips trying to prepare for the upcoming investigation.

?

May 14:

I talked to two part 21 NRC specialist today. They were very friendly. They could have talked for months about the part 21 process. I told them I am not concerned with the radiation qualification of the diaphragms. I showed them what I thought were shortcomings in the part 21 process.     

I explained this is what I am concerned about:

Code Case N31 (250?F and 220 psi with 40 year radiation exposure of 1E8 Rad).

1)      What is code case n31?

2)      The high rads imply the diaphragms are going into containment and the 250 degrees is incongruent with containment.  More like 370 degrees.   

3)      Specifically what does 250?F mean.

4)      The fundamental question,  is there non-qualified diaphragms in containment.

Basically they told me that I should trust the process, they do…I told them where there are current holes in the agencies part 21 process…so I am testing you guys.

They explained we need to wait until the 60 day update…that is when they will specify what valves and plants are involved. They seem really hesitant to call ITT. They didn’t seem concerned the 1E8 rads and 250 degrees in the containment didn’t mix.  But they said they would get answers for me. They said they will call me back when the update came in.

I just was surprised they couldn’t immediately tell me these valves don’t go into containment or nobody knows what the 250?F means, but all diaphragms are good to 370 degrees. The best they would say is we don’t know what "code case n31 (250?F and 220 psi with 40 year radiation exposure of 1E8 Rad)” means. I was surprised they couldn’t throw some facts back at me to blow me out of the water.

May 3: SO, a Watts Bars inspector called me up about the ITT diaphragm issue.

I told him this reads as qualified for class 1 nuclear safety components and 1E8 implies it is near the core. The "250?F" implies that is the highest temperature rating. Told him it should be 370 degrees qualified. Reminded him about the Fort Calhoun, Peach Bottom and Vermont Yankee issue with putting in intentionally improper material in valves. This looks to me like to me they are putting improper diaphragms in nuclear plant containments in general. He told me they have rules and regulations to prevent this, besides it was caught in a surveillance. I told  him that was a hell of a way to run a Navy.

The only way the agency is going to Catch it is by doing a inspection on containment diaphragms and the NRC then asking a set of utilities if all containment diagrams are fully environmentally qualified. 

"It only applies to those that were sold for a particular service condition of Code Case N31 (250?F and 220 psi with 40 year radiation exposure of 1E8 Rad)."

But he seem more interested on how I got the phone number of the first inspector. It must be a secret phone number or such. This is two NRC officials that seemed to be really interested in how I got this special phone number.

He wasn't even familiar with what ASME code case N31 means...

I think it defines the quality of class I, II and III elastomer 3 or 4 inch diaphragms......Big picture, based on the VY safety relief valves threaded seals and current events in the industry, the NRC lost control of maintaining the design quality and environmental considerations within the containment to withstand the worst accident of design. They don't know how the plants will respond in a accident with their containment at 370 degree to 400 degree. And this is all wrapped up the TVA Watts Bar's commercial dedication crisis...the inability of vendors to provide quality replacement parts in the industry. It is in every plant in the nation.

I asked the NRC at VY's annual public meeting and they seemed to promise me a response:

1) Does Vermont Yankee have any code case n31 diaphragms in Vermont Yankee, specifically diagrams only qualified to 250 degrees?

2) Does any plant in the USA have code case n31 diaphragms in their plant, specifically diaphragms only qualified to 250 degrees, which should be 370 degrees... 

I have complained about components in nuclear plants being not qualified for the designed accidents in containments environments.

I specially complained about pneumatic safety relief valve o rings, seals, gaskets and diagrams. I worried they wouldn't be qualified for the containment environments...specifically for temperatures and radiation.

Code Case N31 (250?F and 220 psi with 40 year radiation exposure of 1E8 Rad):

Based on the VY SRV unqualified buna-n threaded seals, 250F isn't qualified for any containment in the USA. They should be qualified for 400 degrees F.

They could be for pneumatic actuators?

Devices that measure flow and difference of pressure (d/p)...

What the hell does "250?F" mean? What does "Code Case N31" mean and are diaphrams that meet this allowed in containments.

So why is the requirements 250 degrees and 40 year radiation exposure of 1E8 Rad?

ASME Section III Component Replacements 

N31 (1540-2)
Elastomer Diaphragm Valves, Section III, Class 2 and 3

7/18/85-Each applicant who applies the Code Case should indicate in the referencing safety analysis report that the service life of the elastomer diaphragm should not exceed the manufacturer’s recommended service life. This recommended service life should not exceed 1/3 of the minimum cycle life as established by the requirements of paragraph 3 of the Code Case. In addition, the service life of the elastomer diaphragm should not exceed 5 years, and the combined service and storage life of the elastomer diaphragm should not exceed 10 years. 

Class 1Components (III, Subsection NB)-Those components that are part of the primary core cooling system 

Components (III, Subsection NH)-Those components that are used in elevated temperature service

Class 2Components (III, Subsection NC)-Those components that are part of various important-to-safety emergency core cooling systems

Class 3Components (III, Subsection ND)-Those components that are part of the various systems needed for plant operation

When you worry about this kind of  rads for1E8, you are talking about power operations near the core and the potential of nuclear meltdown. That be 400 degree F.

Sounds like this comes from TVA, Watts Bar and not qualified nuclear parts...

Rep Org: ITT ENGINEERED VALVES, LLC Licensee: ITT ENGINEERED VALVES, LLC Region: 1 City: LANCASTER State: PA County: License #: Agreement: Y Docket: NRC Notified By: STEPHEN DONONHUE HQ OPS Officer: BILL HUFFMAN	Notification Date: 04/26/2013 Notification Time: 17:25 [ET] Event Date: 04/26/2013 Event Time: 13:54 [EDT] Last Update Date: 04/26/2013
Emergency Class: NON EMERGENCY 10 CFR Section: 21.21(d)(3)(i) - DEFECTS AND NONCOMPLIANCE	Person (Organization): JUDY JOUSTRA (R1DO) MARVIN SYKES (R2DO) DAVID HILLS (R3DO) JACK WHITTEN (R4DO) PART 21 GROUP (RX) (E-MA)

Event Text

DIAPHRAGMS MAY NOT BE QUALIFIED FOR SPECIFIC RADIATION DESIGN CONDITIONS The following report was received from ITT Engineered Valves, LLC via facsimile: "It is my duty as the Responsible Officer of ITT Engineered Valves, LLC (ITT) to inform the Nuclear Regulatory Commission of a defect with certain items of our nuclear diaphragm valve product line which may be considered Basic Components. The components are ITT's Nuclear M1 diaphragms, sizes 3 inch and 4 inch that may have been sold to certain customers for specific design conditions. The defect does not affect all 3 inch and 4 inch M1 diaphragms that have been sold. It only applies to those that were sold for a particular service condition of Code Case N31 (250?F and 220 psi with 40 year radiation exposure of 1E8 Rad). "The nature of the defect is best described by 10 CFR Section 21.3 Defect Definition #5, as 'an error, omission or other circumstance in a design certification or standard design approval that... could create a substantial safety hazard.' In this case, ITT inadvertently qualified the 3 inch and 4 inch M1 diaphragms for a design condition that includes the effect of radiation when in fact our recommendation was erroneously based on diaphragm testing that did not include irradiated diaphragm test results for those sizes. The potential safety hazard stems from the fact that if one of these diaphragms sees radiation in this particular service, there is no data to indicate that the diaphragm will perform its function in that service condition. Until such time that we can conduct additional irradiated diaphragm testing to additional sample diaphragms and test for this condition, we need to consider the parts that are in this service as potentially unsafe. "ITT is in the process of identifying all facilities for which the diaphragms were sent, either as spare parts or diaphragms incorporated into valve assemblies. We are also preparing to do further verification tests of the 3 inch and 4 inch M1 diaphragms in an attempt to ascertain the true performance rating at the noted condition. "Per 10 CFR 21 policy guidelines, this initial notification will be followed by a written notification by May 27, 2013."