Millstone: FSAR Safety Valves not fixed because of "scheduling, engineering, and funding challenges".

This went on for 7 years and hopefully fixed it this outage. You see how this attitude carried over to 2014 in the turbine driven Aux Feedwater pump problems and then the plant trip and LOOP. They were improperly sized, then put off fixing it till this outage

"Dominion had deferred correcting this condition over a period of six years (three refueling outages) which the inspectors noted in NCV 05000423/2012010-01, a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action.” Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 outage."

See how they hide problems from us and allow they guys not to fix safety components for many years. At the end of 2013, this is the first time we are hearing about...why wasn't made into a LER in 2007?

 

Did you catch that below, profound "scheduling, engineering, and funding challenges" over 4 years. 

The valves were initially scheduled to be restored to full qualification during refueling outage (RFO), 3RFO12, in October 2008, but the repairs were deferred to 3RFO13 due to maintenance schedule conflicts. Subsequently, repairs were not completed in 3RFO13, 3RFO14, or 3RFO15 due to scheduling, engineering, and funding challenges."

Imagine if they had a unimaginable accident like removing a transmission circuit and then getting a troublesome LOOP in a feed water piping burst and these valves did not work like specified in the FSARs? Can you imagine the fall out with agency not being able to see  defect or that they gave the plant permission to continue on with plant operation.  

2007:Dominion discovered problem.

2012: NRC first reported on it and found additional problems.

Late 2013: NRC dinged them not replacing the valves.

(I mean, who do you trust.) 

November 8, 2013

SUBJECT: MILLSTONE POWER STATION – NRC INTEGRATED INSPECTION REPORT 05000336/2013004 AND 05000423/2013004 AND NOTICE OF VIOLATION AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT NO. 07200047/2013001 

Failure to Restore Feedwater Isolation Valves to Full Compliance

Introduction. The inspectors identified a Green cited violation of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action,” for Dominion’s continued failure to take timely and effective corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion had deferred correcting this condition over a period of six years (three refueling outages) which the inspectors noted in NCV 05000423/2012010-01, a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action.” Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 outage. The violation is cited because Dominion has failed to restore compliance or

Can you believe this...why didn't the NRC demand fix it or you can't start up?  

demonstrate objective evidence of plans to restore compliance at the first opportunity in a reasonable period of time following initial identification in 2007 and documentation in 2012 NRC inspection reports.

Description. On June 27, 2007, Dominion identified that the Unit 3 feedwater isolation valve hydraulic actuators for 3FWS*CTV41A, B, C and D were not adequately sized to fully close against main feedwater pump discharge pressure to isolate feedwater flow into containment in the event of a main feedwater line rupture. Further analysis concluded that the feedwater isolation would likely occur when the feedwater pumps were subsequently stopped by either a non-safety grade trip signal or manual operator action.The feedwater isolation valves are safety-related valves that comprise train ‘B’ of the main feedwater isolation function as described in the Millstone UFSAR. Dominion determined that the hydraulic actuators for these valves were inadequately sized based on operating experience as described in Electric Power Research Institute Technical Report TR-103232. The valves were initially scheduled to be restored to full qualification during refueling outage (RFO), 3RFO12, in October 2008, but the repairs were deferred to 3RFO13 due to maintenance schedule conflicts. Subsequently, repairs were not completed in 3RFO13, 3RFO14, or 3RFO15 due to scheduling, engineering, and funding challenges. Once again, Dominion has rescheduled repairs to the upcoming refueling outage 3RFO16 in October 2014, seven years after the problem was first identified.

The main feedwater isolation valves are safety-related containment isolation valves that rapidly close in response to a phase ‘B’ feedwater isolation ESF signal. These valves are relied upon to ensure that the flow of hot feedwater is rapidly isolated for a variety of analyzed events including the rupture of a feedwater header inside containment. If feedwater flow is not isolated to the break, the additional energy transported into containment may challenge containment pressure and temperature limits, as well as the equipment qualification of various instruments and equipment inside containment.

Dominion determined (in CR-7-07160 and Operability Determination (OD) MP3-014-07) the valves would not go fully closed until after the feedwater pumps had tripped and therefore, the feedwater isolation (FWI) function was operable with a degraded margin. A subsequent review (OD000237 completed in 2009) reaffirmed this conclusion. The justification for continued operability was based on the conclusion that the feedwater line break (FLB) event remained bounded by the main steam line break (MSLB) event and that operator actions could be relied upon to manually trip the motor-driven main feedwater pump in time to reduce the differential pressure across the feedwater isolation valve allowing the valve to go fully closed before containment limits were exceeded.

On May 10, 2012, the inspectors reviewed this active OD and determined that the justification for continued operations did not meet the requirements of OP-AA-102-1001, “Development of Technical Guidance Basis to Support Operability Determinations,” Revision 6. Specifically, Dominion had concluded that the FWI function was operable because the MSLB accident bounded the FLB accident

You catch this, the overly optimistic and inaccurate engineering safety analysis that justified continued operations. Just like the analysis on not getting permission to yank out the SLOD and transmission system leading to the plant trip and LOOP.  

because the main steam break event had a greater energy release rate and no further analysis was necessary to demonstrate safety. This analysis did not fully consider the impact of continued high temperature feedwater flow from full power conditions into containment and the subsequent challenge to the electrical equipment qualification temperature limits inside containment. The inspectors documented this issue as FIN 05000423/2012003-01.

Based on the inspectors documented findings, Dominion issued CR483637 on August 1, 2012, and placed the motordriven feedwater pump in pull-to-lock to prevent it from automatically starting if a drop in feed header pressure occurred from a feed header rupture. Dominion subsequently completed an immediate operability

So why not a temporary Licence amendment request and the opportunity for a public hearing?    

determination, which concluded that the feedwater isolation function was degraded but operable based upon the conclusion that the main feedwater pumps would likely trip within a short period of time. The non-safety grade main feedwater pump trip signal that would likely stop the pumps and operator actions would also manually stop the main feedwater pump while implementing emergency operating procedure E-0, “Reactor Trip or Safety Injection.” 

The inspectors noted the deferral of repairs to 3FWS*CTV41A, B, C, and D from 3RFO15 to 3RFO16 and questioned the continued validity of the operability determination which relied upon an untested, non-safety grade main feedwater pump trip signal for another operating cycle. Dominion developed a procedure, SP 3621.5, “Overlap Testing of Main Feedwater Pump Trips,” Revision 000, which operators used to test the feedwater pump trip signal. This successfully completed test allows Dominion to continue to consider the feedwater isolation function degraded but operable until full compliance is restored in 3RFO16. 

Analysis. The inspectors determined that the failure to take timely and effective corrective action in accordance with 10 CFR 50, Appendix B, Criterion XVI, following identification of a degraded condition of the Unit 3 main feedwater isolation valves was a performance deficiency that was reasonably within Dominion’s ability to foresee and correct.

The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of IMC 0612, Appendix E, “Examples of Minor Issues.” Specifically, Dominion did not correct a condition adverse to quality in a timely manner and resulted in a situation that impacted the operability of the feedwater isolation valves. Additionally, the finding is more than minor because it is associated with the Design Control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone’s objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

In accordance with IMC 0609, Appendix A, “The Significance Determination Process for Findings At-Power,” the inspectors performed a Phase 1 SDP screening and determined the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. In the event of a ruptured feedwater line, the train ‘A’ main feedwater regulating valves and bypass valves would remain capable of closing to isolate feedwater flow.

The inspectors determined this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because Dominion did not maintain long term plant safety by minimizing long-standing equipment issues and ensuring maintenance and engineering backlogs which are low enough to support safety. Specifically, Dominion deferred the feedwater isolation valve replacement project from 3RFO15 to 3RFO16 because the design change could not be issued to support online work on the project required prior to the outage. Additionally, there were a number of outstanding technical issues for the design change that were not resolved in time despite the condition existing since 2007 (H.2.a).

Enforcement. 10 CFR 50 Appendix B, Criterion XVI, “Corrective Action,” requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, from 2007 until repairs are completed in October 2014, Dominion failed to take timely correction action to correct the degraded condition of the Unit 3 main feedwater isolation valves. Dominion entered this issue into their CAP as CR507299. The NRC identified a performance deficiency with these valves on August 31, 2012, which is documented as a Green NCV of 10 CFR 50 Appendix B, Criterion XVI, “Corrective Action,” (NCV 05000423/2012010-01). The inspectors determined that Dominion had failed to restore compliance at the first opportunity within a reasonable time following the issuance of the finding and NCV. Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 refueling outage. Therefore, this violation is being cited, consistent with NRC Enforcement Policy, Section 2.3.2. A Notice of Violation is enclosed (Enclosure 1).