Friday, March 27, 2015

NRC Commissioner Ostendorff: False Senate Statement And Indicating He Is A Captured Regulator (loss of neutrality)

It is like asking GM how many accidents have your cars been in the last year. They say "none". You find out a car accident according (the inside rules to report to outsiders) to GM means something from the engine coming back hitting or killing somebody in the car. Now you have to figure out what was GM's motivation with making this grossly inaccurate statement. You are puzzled by the response, as you know all of the accidents aren't the fault of GM. 
Mar 30, 2015

 I pretty happy with this response...this speaks of many NRC people are considering it. This isn't your typical repeater acknowledgement response. They are considering my blog with increased activity.  

 You notice nothing from Ostendorff office?  
March 29: 
Senator Alexander is the most prominent nuclear industry politician in the nation.
Just gets you to wonder, TVA owns Tennessee. Alexander is a Tennessee US senator. Sequoyah Nuclear Plant and Watts Barr are nuclear plants in Tennessee. Watt Barr II was abandoned decades ago and in the last few years they resurrected this plant from the dead. TVA is in the final process of getting a license and starting up this old dog plant old plant for the first time. They did the same thing Browns Ferry, when stated up they later discovered many deficiencies and they really have never recovered from this fiasco. The red finding was all about the inadequate job prestart-up. 
I think in the Senate hearing Senator Alexander was signaling TVA and TVA nuclear is big Tennessee business (Employment and associated business contributions) to the Senator, I am going hard on this issue to the NRC. Ostendorff was saying, don’t worry I will play ball with you and the NRC will follow me, you have nothing to worry about.
Ultimately I think Ostendorff and Senator Alexander were signaling to new construction Vogtle and the rest, that the NRC is automatically and hard in your corner. The game is rigged.
This all has sentiments of pre Fukushima and the nuclear village in the USA.
Does being pro nuclear and survival always mean squashing nuclear plant employees...    
March 28:


Pandora's Promise (39:15) 
Gwyneth Cravens ”There has not been a single death from the operation of a commercial nuclear power plant in the USA…not a single death. Not one deaths in the history of nuclear power in the USA” 
Senate Hearing (1:58:15) 
Senator Alexander: "How many deaths have we ever had as a result of the operation of a Navy Reactor" 
Commissioner Ostendorff: "None" 
Senator Alexander: "How many deaths have we ever had as a result of the operation of a commercial Reactor." 
Commissioner Ostendorff: "None" 
Chairman@nrc.gov

Commissioner Ostendorff: False Senate Statement and indicating He Is a Captured Regulator (loss of neutrality)

Dear Chairman Burns,

I wish to make a fraud, waste abuse complaint concerning commissioner Ostendorff during a Senate subcommittee hearing over knowingly making a false statement. This questions if he could ever be trusted to tell truth in congress or in any future public statement. Commissioner Ostendorff behavior questions if he could be a neutral and independent US government regulator in the future.

Please include this complaint in the Adams docket. I have zero faith in the independence of the Office of Inspector General. Because the OIG basically works for you and this issues revolves high officials of the NRC, I think this investigation needs to go outside the NRC to ascertain the real integrity of the Nuclear Regulatory Commission.

I can hear the winds whispering around Diablo Canyon nuclear plant in the background?
  
The gist of what is going on here, corrupt utility pressure though a US senator and a unethical commissioner is attempting improperly to influence the internal deliberation of the NRC…to corruptly weaken oversight of all nuclear power plants.

NRC OIG: Responsible for investigative activities relating to NRC administered or financed programs and operations. Conducts and reports on investigations involving fraud, waste, and abuse to ascertain and verify the facts with regard to NRC employee and contractor misconduct and the integrity of NRC programs and operations.

So Ostendorff phraseology is taken right out of the fanatical pronuclear playbook. He is supposed to be neutral regulator for nuclear power…he should express the full facts on the deaths in the nuclear industry or any issue. He is not allowed to shade the fact for campaign contribution or for big buck later in the private sector. He should never be untruthful in a senate hearing and in all of his dealings being a NRC commissioner. How can anyone trust a word out of his mouth now?

I am just saying from a smart guy in the control room of a nuclear power plant …this is extraordinary safety intimidation by a NRC commissioner and the agency itself…these folks are educated enough to know the fatalities in the nuclear industry doesn't add up to these words spoken in a Senate hearing. How often has he spoken these words not recorded and what does he coach the nuclear industry behind the scenes. Seeing how this is repeatedly acceptable (not contested ethical lapse) behavior for the Nuclear Regulatory Commission and within high halls of our political system, how can any employee feel safe to raise a safety problem with a commissioner who shows such a lack of integrity? How can any nuclear employee raise a troublesome safety problem with the agency and congress blatantly indicating such a lack of integrity?
   
If a commissioner can use openly in a Senate hearing inaccurate nuclear industry extremist and ideological phraseology without fear, extremist pro nuclear propaganda, then all of the NRC employees and industry people should fear him. He has the power to create a nuclear ideological lie at will…a wall of intimidation through using inaccurate information to the public…that means he can destroy anyone who crosses him through wrecking a career with a lie from an extraordinary powerful position. If commissioners are openly making ideological culture lies…that is giving permission to the all executives in the nuclear industry to use their position to suppress safety problems through their powerful position with lying and giving accurate information to the NRC, congress public. Really, has the pro nuclear propaganda extremist taken over the Nuclear Regulatory Commission and congress, which will lie through their teeth for survival? And this guy was a high Navy nuclear submarine officer…this behavior and untruthfulness have diminished the Navy and the United States Government.

I request that NRC Commissioner Ostendorff immediately resign his office or the president fire him.
  
Linkedin: “In 2013, the stator at Arkansas Nuclear One dropped while being removed. Pictures are in a file posted at:

 http://allthingsnuclear.org/arkansas-nuclear-one-pictures-of-an-accident/”

David Lochbaum Director, Nuclear Safety Project at Union of Concerned Scientists

One crushed and 9 injured over not following company procedures. Basically three NRC yellow findings indicating nuclear safety systems were seriously impaired.

The below Conversion began about March 23, 2015
(protected contributor): Interesting when considering that the drop and landing of this large weight in itself caused a trip of the working nuclear reactor at full load! Yet some feel that this was simply an industial accident.
It's like saying the poisoning of the control room staff by an impromptu arrival of a birthday cake is just a catering issue !
Also as a link to nuclear safety culture the question is that exactly what jobs/projects/lifts etc are or should be included in the "nuclear safety culture" and when designing a nuclear power station should not all the design of everything and anything placed or used at a nuclear site be subject to the same nuclear safety culture to include the potential issues with maintenance, repair and replacement?
Even a broken down large vehicle passing through an emergency gate might contribute to an ineffective planned response to a nuclear accident resulting in an off-site nuclear incident that was preventable! 
(Mike Mulligan): One of the NRC commissioners at a senate hearing said no employees ever died at a USA nuclear plant?
(protected contributor): Mike,
Do you have a link to that statement? 
(Mike Mulligan): http://www.appropriations.senate.gov/webcast/energy-water-development-subcommittee-fy16-nuclear-regulatory-commission-budget-hearing Energy & Water Development Subcommittee: FY16 Nuclear Regulatory Commission Budget Hearing
It came from Ostendorff’s mouth in the Q and A.
The worst group of NRC commissioners I’ve ever seen.
With all the musical chairs going on in recent years, they set this up for the extended period of four NRC commissioners for the next two years. What chances you think they will get to nominate another commissioner in the political environment?
Oh please, please, please: don’t make me listen to this again. 
(Mike Mulligan): “How many deaths have we ever had from commercial nuclear power plant operation?” Ostendorff: “None”
Basically asked the same about navel nuclear reactor operation. Seeing how the back aft seawater system was solely controlled by Rickover… I would call the loss of the Threshers as emerging from navel nuclear plant operation.
At the 1 hour 58:15 minute point on the video
Basically asked the same about navel nuclear reactor operation. Seeing how the back aft seawater system was solely controlled by Rickover… I would call the loss of the Threshers as emerging from navel nuclear plant operation.
At the 1 hour 58:15 minute point on the video
(protected contributor): The affirmation that there have been no deaths from (U.S) naval nuclear operations may just be excessively cute, hairsplitting, and semantically deceptive.
Some fatal events arising from U.S. naval nuclear operations include:
Thresher
Scorpion
Greenville sinking of Ehime Maru
etc.
The affirmation that there have been no deaths from (U.S) commercial nuclear operations is demonstrably false.
Some fatal events arising from U.S. commercial nuclear operations include:
Surry pipe rupture
Calvert Cliffs asphyxiation
Palisades electrocution
Crystal River drowning
etc.
(protected contributor): If anyone who sees this has high level contacts at the NRC, would they be so kind as to provide a word to the wise?
Give them the link at
http://www.appropriations.senate.gov/webcast/energy-water-development-subcommittee-fy16-nuclear-regulatory-commission-budget-hearing Energy & Water Development Subcommittee: FY16 Nuclear Regulatory Commission Budget Hearing
(Mike Mulligan): It came from Ostendorff’s mouth in the Q and A.
At the 1:58:15 minute point on the video… 
(Mike Mulligan): ‘False Ostendorff Senate Confirmation Testimony in 2010’
http://steamshovel2002.blogspot.com/2012/08/false-ostendorff-senate-confirmation.html Do you think this NRC cutsie talk stops at senate hearing door?
In Ostendorff’s senate nomination hearing, he said there has never been a radiation release above 20,000 picocuries per liter of water in the USA. That was flat out inaccurate as Vermont Yankee had 100,000 and 1,000,000 pico curies per liter leaked into the ground. I e-mailed his office and he corrected the transcript record.
I think he said that intentionally signaling to the industry I’ll always be available to play footsie when necessary.

(Mike Mulligan): Nuclear insiders use the “no deaths ever’ in the nuclear industry all the time. They know it is literally is a false statement, it is more special signal or code word to indicate I am a member that belongs to a select group of nuclear insiders.
Maybe it is a statement of contempt to the politicians and media…they are so stupid about anything nuclear, I can feed them any old crap?
There is no question Ostendorff knows there is a double meaning with this code phrase.
Maybe it is a statement of contempt to the politicians and media…they are so stupid about anything nuclear, I can feed them any old crap?
There is no question Ostendorff knows there is a double meaning with this code phrase. 
(Mike Mulligan): Then there was SL-1?(protected contributor): SL-1 was military, not commercial.
https://en.wikipedia.org/wiki/SL-1 
(Mike Mulligan): Senator Alexander was doing the two step with Ostendorff in this Q & A exchange. I thought the SL-1 fits into the military category like the Navy nuclear powered ships. 
(protected contributor): Mike,
Thanks for the link to the hearing.
I took the time to view it all.
It gives a picture that is hard to get otherwise.
Are there any hearings that get to the real issues?
Thanks for the link to the hearing.
I took the time to view it all.
It gives a picture that is hard to get otherwise.
Are there any hearings that get to the real issues? 
(protected contributor) The hearing is at
http://www.appropriations.senate.gov/webcast/energy-water-development-subcommittee-fy16-nuclear-regulatory-commission-budget-hearing Mike gave the link above.
I would call it senatorial theater. 
(Mike Mulligan): What is really going on here is the committee blackmailing or intimidating the NRC with budget cuts if the Republicans don’t get their wish list…less regulations and oversight.
I just don’t think Senator Feinstein does a good job in the broader issues with the NRC. She comes from a big state and she just has too many other things to worry about.
The democrats just don’t have much focus with nuclear interest and they don’t get money or votes from the nuclear industry interest. The democrats are always missing from action as in these meetings. Only Feinstein showed up…the asterisk is who showed up for the meeting.
But you get an indicator of the problems with our political system when most of the subcommittee doesn’t show up.
Powerful Richard Durbin of Illinois has the largest concentration nuclear plants in the USA and he is always missing from action and this very particular.
The members must come to an agreement before the meeting on who is going to show up…

*Chairman Lamar Alexander
*Ranking Member Dianne Feinstein
Republican
Thad Cochran Mississippi
Mitch McConnell Kentucky
Richard C. Shelby Alabama
Susan Collins Maine
*Lisa Murkowski Alaska
Lindsey Graham South Carolina
John Hoeven North Dakota
James Lankford Oklahoma

Democrat
Patty Murray Washington
Jon Tester Montana
Richard J. Durbin Illinois
Tom Udall New Mexico
Jeanne Shaheen New Hampshire
Jeff Merkley Oregon
Chris Coons Delaware 
(Mike Mulligan): For the record this is copied over from another Linkedin discussion...
This is a quote from the Pandora’s Promise movie. It occurs at the 39:15 minute point. See how close this is to Ostendorff’s senate testimony. It is propaganda and clearly not true. Who even cares what the film maker says, it free speech, but it is propaganda and not accurate:
  • Gwyneth Cravens ”There has not been a single death from the operation of a commercial nuclear power plant in the USA…not a single death. Not one death in the history of nuclear power in the USA” 
(Mike Mulligan): We were discussing the recent Senate NRC budget hearing …I complained about an inaccurate commissioner Ostendorff statement. This is an interesting thread at the end talking about this and a link to the senate hearing the at time point in the video of the offending commissioner’s statement.
An almost identical statement is in Pandora’s Promise. I live about 3 miles from the community in the background and I was at the protest that day. The statement in the movie is at the 39:15 minute point.
Here is the Ostendorff’s statement that irked me in the senate hearing at the 1 hour 39:15. It is almost identical to Pandora’s Promise.
  • Senator Alexander : “How many deaths have we ever had from commercial nuclear power plant operations?” Ostendoroff: “None” (with a smirky face)”



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Wednesday, March 25, 2015

2.206: Request Emergency Vessel Inspection Within Six Months On Most USA Nuclear Plants?


(final version)  

March 25, 2014

Mr. Mark A. Satorius
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001


Dear Mr. Satorius:

SUBJECT: 10 CFR 2.206 Petition requesting emergency ultrasonic inspection test or best available flaw detection technology for USA reactor plants similar to the thousands of cracks discovered in Belgium nuclear power plants.  

“The discovery of the cracks in the reactors “could be a problem for the entire global nuclear industry,” says Jan Bens, general director of the Belgian Federal Agency for Nuclear Control (FANC), speaking on.”

This is a 2.206 on all US nuclear plants. Please place on all plant dockets especially Vermont Yankee and Kewaunee Power Station.

I don’t even think a LOCA in a vessel is even a consideration in plant licensing and this could be our Fukushima style accident in the USA.

Doel 3 and Tihange 2

Cracks discovered in the walls of Belgian nuclear reactors are causing unease among experts. The reason: a previously unknown phenomenon – material fatigue. There are fears that many more reactors could be affected.

Several thousand cracks have been discovered by corrosion experts in the pressure vessels of two reactors at the Belgian nuclear power stations Doel 3 and Tihange 2. Caused by a previously unknown phenomenon, material fatigue, it is feared the finding could have implications outside of Belgium.

The discovery of the cracks in the reactors “could be a problem for the entire global nuclear industry,” says Jan Bens, general director of the Belgian Federal Agency for Nuclear Control (FANC), speaking on.

Examination of nuclear reactors demanded

Of most concern are the cracks that have been found in the walls of pressure vessels, the part of reactors where the highly radioactive chain reaction takes place. During such a process, the vessel is under extreme stress and instability caused by the cracks could cause a potentially catastrophic release of radioactive contamination.

It is already known that pressure vessels can become fatigued as a result of stress caused by pressure, temperature and radioactive materials. But the Belgian Nuclear Research Center in Mol has only just found out “that the material is mechanically weakened through radiation much more than previously thought,” says Heinz Smital, nuclear physicist and expert at Greenpeace.

Nuclear material corrosion expert Walter Bogaerts, of Belgium’s University of Leuven says that corrosion factors have until now been “underestimated”, globally. He adds: “I would be really surprised if it had not also occurred elsewhere.”

Reactors could be shut down

Digby MacDonald, an expert in corrosion at the University of California, Berkley, analyzed the cracks together with Bogaerts and has advised nuclear reactor operators and government regulators that they should use ultrasound equipment to carefully examine reactors for cracks. “All reactor operators should be require under the leadership of regulatory authorities,” says MacDonald. He adds that the results of such detailed investigations “could be insignificant, or so strong that all the reactors must be shut down.”

According to nuclear experts, hydrogen from the reactor can penetrate the reactor wall and there in the steel increase the interior pressure causing small bubble and cracks from just a few millimeters in size “up to seven centimeters”, says Smital.

Using special ultrasound equipment, experts discovered 13,047 cracks in total in the Belgian reactor Doel 3 and 3,149 in Tihange 2. The reactors have been shut down, as a result. Whether they will once again be connected to the network is, as of yet, unclear.

Danger for the nuclear industry

The appearance of the cracks as a result of material fatigue has caused a tide of reaction. Safety checks are being demanded all over world and “could lead to a wave of reactor closures”, says Smital.

Greenpeace successfully sued the Belgian nuclear authority FANC in January following the publication of the detailed investigative documents. “It's a very delicate matter and could indeed have a huge impact on the whole nuclear industry,” says Smital. Greenpeace is demanding that all reactors worldwide are closely examined.

The German Environment Ministry has also reacted and is seeking to have immediate contact with the Belgian authorities to see whether the findings could be applicable to German reactors.

But according to Greenpeace, the Belgian findings confirm the growing threat posed by old nuclear power plants. The world’s reactors now have an average age of 29 years. “That is no longer state-of-the-art, which can be dangerous, even when you upgrade,” says Smital. “What are now needed are scenarios for a shut down of plants. Every country needs a get-out plan.””

1) I request exigent and immediate full scale ultrasonic inspections similar or with better technology (as was done on the Belgian Doel 3 and Tihange 2 nuclear plant discovering 13,047 recent cracks) on the following US nuclear power plant:

BWR: Vermont Yankee (June 1974)

PWR: Kewaunee Power Station (Nov 1972) (preferred to be first)

Both these plants are permanently shut down so it won’t disrupt plant operations. An emergency ultrasonic inspection could occur very quickly based on the plants permanently shut down status and the Kewaunee plant is similar to the Belgium PWRs and its age. The nuclear fuel is out of the core and the surroundings would have lower doses. You could quickly strip off the vessel insulation and you wouldn't need to replace it for lower doses. You wouldn’t have to replace the core interior components either?

2) I request large bore holes samples be cut out of both vessel at the worst place similar to the “Davis Besse hole in the reactor head” event. Then transport the vessel specimens to a respected metallurgic laboratory for comprehensive off site testing.

3) Request an immediate NRC report and public meeting on the vulnerabilities with US reactor cracking and these mysterious weakened vessels. 

4) If distressing and unsafe results are discovered at Vermont Yankee or Kewaunee, I request that within six months all USA plants be ultrasonically tested or better technology.

5) How has the average concentration of hydrogen in the coolant changed over the recent decades? Would an increasing concentration of hydrogen in the coolant lead to more hydrogen ions getting injected into the vessel iron?

6) Does noble chemistry increase or decrease this kind of corrosion? 

7) Are there other chemicals added to the coolant that could make this kind corrosion worst? 

8) What are they talking about here:
  
"However, as Belgian continues to debate the fate of the reactors, prolonged studies on the steel used in the construction of the reactors revealed unprecedented embrittlement – unusual swelling – that can compromise the integrity of the plant and possibly cause ruptures, spewing dangerous radioactive material equivalent to an atomic bomb."

9) I understand all US nuclear plants have coupons and I consider them irrelevant to this problem.

10) Request the NRC coordinate with the Belgian Federal Agency for Nuclear Control (FANC).

11) Request detailed inspection on the condition of the reactor cladding and a explanation of any defects. 




Sincerely,


Mike Mulligan
Hinsdale NH
1-603-336-8320

steamshovel2002@yahoo.com


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Wednesday, March 18, 2015

Storm Juno LOOP and SRV Malfunction...the Special Inspection.

Works in progress...I've be adding to this in the next week. Heading towards a 2.206.

 Update: March 20, 2015 
Yesterday i called the Hatch nuclear plant senior resident asking him about all their recent failures of the model 0867F SRVs. Could just leave a recording. You know you are in Siberia when the regional public relations person calls you back instead of the resident inspector.
He didn't have much information about the Hatch SRV events…but he did say something particular. There is no doubt he called region I officials and the higher level officials were coordinating the response. What the message the NRC wanted me to relay to the public:
The failed SRV at Pilgrim had 57 cycles on it while a similar Hatch SRV  has 3 to 4 cycles on it. Hatch operates their SRV's fundamentally different than Pilgrim.
I tried to probe this guy (he was a nice guy) asking him how Hatch operates their SRVs different than Pilgrim. I told him I was a license operator at Vermont Yankee. He responded back to me, Pilgrim uses their SRVs to control pressure while up at power while Hatch does not. You never know when these guys are playing dumb or are really dumb? Usually all NRC employees, no matter what the stripe, are particularly intelligent. I asked him twice what he meant by that, the response never changed. 
If I had to translate what he said, I think he was trying to say during start-ups and particularly shutdowns and hard shutdowns, Pilgrim reverts as a normal operation path, especially when the main stream lines are closed, into using their SRVs as the means of cooling the core and pressure control in the vessel. 
Is he saying all their shutdowns and hard shutdowns are causing damage to Pilgrims SRVs? Why are the SRV designs so delicate? 
Typically in the worst accident possible (DBA), they cycle the SRV valves between 300 and 500 times in one accident…
I asked region I senior public affair official to respond to this in a phone message (Mrs. Srenci)

Did the NRC release this for the public meeting tonight?

 PNO

Part 21 Event Number: 50900
Only the 0867F is under investigation.
The root cause of the potential test induced defect has not yet been confirmed as of the date of this report.
One of the four installed MS-SRVs may not have fully opened.
As-found steam testing of the affected MS-SRV did not duplicate this failure; the valve opened on demand.  
We are working with all three (4) sites to identify appropriate precautions.
Rep Org: CURTISS WRIGHT FLOW CONTROL CO.
Licensee: CURTISS WRIGHT FLOW CONTROL CO.
Region: 1
City: EAST FARMINGDALE State: NY
County:
License #:
Agreement: Y
Docket:
NRC Notified By: JOHN DeBONIS
HQ OPS Officer: STEVE SANDIN Notification Date: 03/17/2015
Notification Time: 09:59 [ET]
Event Date: 03/17/2015
Event Time: [EDT]
Last Update Date: 03/17/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
21.21(a)(2) - INTERIM EVAL OF DEVIATION
Person (Organization):
GLENN DENTEL (R1DO)
BINOY DESAI (R2DO)
PART 21/50.55 REACT (EMAI)
Event Text
INTERIM PART 21 REPORT - POTENTIAL TEST INDUCED DEFECT IN A 0867F MAIN STEAM SAFETY RELIEF VALVES

The following report was received from Curtiss - Wright via email:

"This letter provides interim notification of a potential test induced defect in a 0867F Series Main Steam Safety Relief Valves (MS-SRVs) manufactured and supplied by Target Rock (TR). The information required for this notification is provided below:

"(i) Name and address of the individual or individuals informing the Commission.

William Brunet
Director of Quality Assurance
James White
General Manager
Target Rock, Business Unit of Curtiss-Wright Flow Control Corporation
1966E Broadhollow Road
East Farmingdale, NY 11735

"(ii) Identification of the basic component supplied for such facility or such activity within the United States which may fail to comply or contains a potential defect.

Target Rock 0867F Series of Main Steam-Safety Relief Valves Manufactured by Target Rock. This is a 3-stage piloted valve consisting of a main valve (the 'Main') with an actuator mounted to it (the 'Topworks'). The 0867F is the latest generation of the 67F line of MS-SRVs, including the original 3-Stage and 2-Stage designs, and this product line has over 40 years of plant operational experience. Only the 0867F is under investigation. This is due to the differences between the 0867F design and the other designs.

"(iii) Identification of the firm supplying the basic component which fails to comply or contains a defect.

Target Rock, Business Unit of Curtiss-Wright Flow Control Corporation
1966E Broadhollow Road
East Farmingdale, NY 11735

"(iv) Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.

As we understand it, the Pilgrim Station recently manually opened the Target Rock Main Steam Safety Relief Valves (MS-SRVs) as part of cooling down the reactor following a loss of offsite power. One of the four installed MS-SRVs may not have fully opened. As-found steam testing of the affected MS-SRV did not duplicate this failure; the valve opened on demand. However, the valve did not re-close as expected. Internal inspections found damaged parts in the main stage subassembly that could potentially affect the ability of the MS-SRV to operate as designed.

We are investigating potential root causes for this damage. However, we are still unable to determine if a specific defect exists. GE SIL-196, Supplement 17 determined Main Spring relaxation was caused by 'extreme dynamics encountered during limited flow testing . Valve dynamics under full flow conditions (i.e. discharge not gagged) are much less severe than those under limited flow conditions.' These extreme dynamics, under limited flow test conditions, are the focus of our investigation. Specific areas of investigation include;

a) Testing of materials to verify they are consistent with our material specifications,
b) evaluation of differences between the 0867F and earlier designs, and
c) evaluation of the differences between different limited flow test loop configurations and test procedures

"(v) The date on which the information of such defect or failure to comply was obtained.

The Pilgrim event occurred on January 27, 2015. As-found testing occurred on February 2, 2015.

"(vi) In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regulations in this part.

While we have yet to determine if a specific defect exists, the following plants were supplied 0867F MS-SRVs:

- Pilgrim (Model 09J-001) Quantity Shipped = 8
- Fitzpatrick (Model 09H-001) Quantity Shipped = 4, Quantity on order= 8
- Hatch 1 and 2 (Model 09G-001) Quantity Shipped= 24, Quantity on order= 12

The following plants will be supplied 0867F MS-SRVs:

- Hope Creek (Models 14J-001, 14J-002) Quantity on order = 7

"(vii) The corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action.

The root cause of the potential test induced defect has not yet been confirmed as of the date of this report. Therefore, no specific corrective actions have been initiated. Target Rock Problem Report 080 will document the corrective actions when they are determined and complete the 10 CFR Part 21 evaluation of the potential test induced defect. This determination will be based on further mechanical and material evaluations. TR anticipates completing these evaluations within 45 days; however, in the event the evaluations are not completed, TR will forward another interim report within 45 days.

"(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

We are working with all three (4) sites to identify appropriate precautions.

"(ix) In the case of an early site permit, the entities to whom an early site permit was transferred.
Not applicable.

"Should you have any questions regarding this matter, please contact Michael Cinque, Director of Program Management at (631 ) 293-3800."

SRV-3B Safety Relief Valve Declared Inoperable Dueto Leakage and Setpoint Drift
Licensee Event Report 2013-002-01

Event date 01 20 2013

LER: 2013 002 01

Report Date 1 31 2014

On Sunday January 20, 2013, at 2050 hours with the reactor at 100% core thermal power (RMSS in RUN), PNPS declared SRV-3B inoperable and entered Technical Specification (TS) 3.6.D.2 requiring an orderly reactor shutdown such that reactor coolant pressure is less than 104 psig within 24 hours. On Monday January 21, 2013, at 1300 hours (16 hrs and 10 minutes) reactor coolant pressure was lowered to less than 104 psig. SRV-3B had been declared inoperable consistent with PNPS procedures that state an SRV is inoperable if the first stage pilot thermocouple temperature is 350 F below its baseline temperature. This LER Supplement provides the determination of cause for the leakage. The cause of the SRV leakage was that the natural frequency of the pilot assembly was close to a resonant frequency of the valve assembly when installed on the PNPS main steam line, that had failed to be considered in the design of the SRV. A contributing cause was wear and looseness of parts in the main stage of RV-203-3B.

The reactor was depressurized and a new pilot valve assembly was installed on SRV-3B. On January 22, 2013, at 1015 hours reactor restart was commenced. On January 24, 2013 at 0312 hours 100% core thermal power was achieved.

This LER also reports the as-found setpoint of one SRV pilot valve tested was less than the minimum pressure required by TS 3.6.D.1.

This event had no impact on the health and/or safety of the public.

BACKGROUND:

As background, the pressure relief system includes four (4) SRVs and two (2) spring safety valves (SSVs). During Refueling Outage (RFO-1 8), in April/May, 2011, the four SRVs were replaced with Target Rock Model 0867F 3-stage SRVs. The SRVs discharge through their individual discharge piping, terminating below the minimum suppression pool (torus) water level. The four SRVs are installed on the main steam piping in containment between the reactor pressure vessel and the flow restrictors.

The 3-stage SRV contains a pilot (also called the first stage), a second stage, a main stage, and an air operator.

To monitor these valves for leakage, Pilgrim installed thermocouples at the pilot (first stage), at the second stage, on the tailpipe near the valve (4.5' to 6' away), on the tailpipe far from the valve (-20' away) and at the pilot bellows. Procedure 2.2.23, "Automatic Depressurization System", provides guidance for interpreting the thermocouple data and determining valve operability based in part on testing performed by Target Rock.

Subsequent to installation in RFO-1 8 and prior to this event, Pilgrim experienced minor second stage pilot valve leakage from SRV RV-203-3C on May 18, 2011 and November 25, 2011. Also, on December 26, 2011, SRV RV- 203-3D first stage pilot valve experienced leakage while operating at full power. The SRV was declared inoperable and the plant was shutdown on December 26, 2011 in accordance with TS 3.6.D.2 and RV-203-3C was replaced entirely, and the RV-203-3D pilot assembly was replaced (LER 2011-007-00).

EVENT DESCRIPTION:

On Sunday January 20, 2013, at 2050 hours with the reactor at 100% core thermal power (RMSS in RUN), PNPS declared SRV-3B inoperable and entered Technical Specification (TS) 3.6.D.2 requiring the initiation of an orderly reactor shutdown such that reactor coolant pressure is less than 104 psig within 24 hours. On Monday January 21, 2013, at 1300 hours (16 hrs and 10 minutes) reactor coolant pressure was less than 104 psig. SRV-3B had been declared inoperable consistent with PNPS procedures that state an SRV is inoperable if the pilot stage thermocouple temperature is 350 F below its baseline temperature.

While at full power, indication of a steam leak across the first stage pilot of RV-203-3B was identified. The leakage was evaluated and in accordance with criteria specified in procedure 2.2.23, specifically, if the pilot stage thermocouple temperature is 35 degrees F below its baseline temperature (with a smaller decrease at the second stage thermocouple) and cannot be explained by a corresponding downpower, the SRV is inoperable. The safety relief valve was subsequently declared inoperable and the Limiting Condition for Operation (LCO) for Technical Specification (TS) 3.6.D.2 was entered. Per TS 3.6.D.2 the plant was shutdown and reactor coolant pressure was below 104 psig within 24 hours.

CAUSE:
The SRVs were purchased new, installed, and tested for the first time in April/May 2011 during RFO-1 8.

 Following an extensive investigation, it was determined that the cause of the SRV leakage was that the natural frequency of the pilot assembly was close to a resonant frequency of the valve assembly when installed on the PNPS main steam line. This was not considered in the Entergy specification or the Target Rock design of the

EXTENT OF CONDITION:

This condition potentially applies to all four three stage SRVs that were installed in RFO 18. During Cycle 19 operation, Pilgrim has observed leakage from RV-203-3B, 3C, and 3D. 
·         On May 18, 2011 and November 25, 2011, SRV RV 203-3C second stage pilot valve minor leakage was observed. This condition did not cause inoperability of the valve. SRV RV-203-3C was replaced during the December 26, 2011 shutdown.

·         On December 26, 2011, SRV, RV-203-3D first stage pilot valve experienced leakage that exceeded the operability criteria while operating at full power. The plant was shut down as required by TS 3.6.D.2, RV 203-3C and 3D were repaired and the plant returned to full power operation. The cause of the pilot leakage was later determined to be a combination of the natural frequency issue and weakening of the pilot bellows spring. This bellows spring had a through wall failure during testing at an offsite test facility in March 2013. This failure was the subject of a Target Rock 10 CFR, Part 21 (Reference 1).

·         On January 20, 2013, Pilgrim experienced the event described in this Licensee Event Report, first stage pilot valve leakage of SRV, RV-203-3B. The plant was shutdown as required by TS 3.6.D.2. The pilot valve was replaced with a refurbished pilot and the plant was returned to full power operation.

·         On February 3, 2013, RV-203-3B first stage pilot valve leakage was identified while at full power. Reactor power was lowered to 80% and at 1000 psig pressure, the pilot was reseated. An Operability Determination with a compensatory measure was implemented to maintain the reactor power at 80% and reactor pressure at 1000 psig. An Operations Decision Making Issue (ODMI) was implemented to monitor and take corrective actions. During the forced outage on February 8, 2013, caused by a loss of offsite power due to a major winter storm, RV-203-3B first stage pilot valve was replaced with a new pilot valve and the plant was returned to power operation. The cause of the pilot leakage was determined to be a combination of the natural frequency issue and weakening of the pilot bellows spring. This bellows spring had a through wall failure during testing at an offsite test facility in March 2013. This failure was the subject of a Target Rock 10 CFR, Part 21 (Reference 1).

The removed RV-203-3B pilot valve was sent to Wyle Laboratory for testing.
As-found test results for the SRV, RV 203-3B pilot valve were:
Pilot S/N SRV Position As-Found Deviation

23 RV-203-3B 1112 psig (-)3.8%

Technical Specification 3.6.D.1 requires the as-found setpoint to be within 1155±34.6 psig (1120.4 psig to 1189.6 psig). The as-found setpoint was less than the minimum pressure specification required by TS 3.6.D.1. This test result was entered into the corrective action program as a separate event, and is included in this LER since the condition was discovered within 60 days from the initial discovery of pilot leakage. Accordingly, this as-found value being out of Technical Specification setpoint is reported in this LER pursuant to 10 CFR 50.73(a)(2)(i)(B).

·         The third pilot on RV-203-3B began leaking on February 26, 2013. Leakage was controlled by reducing power and pressure per the ODMI. This pilot was replaced during the Spring 2013 RFO. The cause of the pilot leakage was that the pilot assembly had a natural frequency that was close to a resonant frequency of the valve assembly when installed on the PNPS main steam line.

CORRECTIVE ACTIONS:

The following corrective actions were taken to address this event related to leaking RV-203-3B:

·         The SRV-3B pilot was replaced with a refurbished and tested pilot.

·         PNPS Procedure was revised to reduce reactor power and pressure to stop leakage per an ODMI as described in "Extent of Condition."

The following corrective actions are being taken to address the results of review of Extent Conditions:

·         To minimize the possibility of further pilot leaks, all currently installed pilots (and replacements if necessary until the long term corrective action can be taken) have been set at the high end of their allowed set pressure band.

·         The recommendations of the Target Rock 10 CFR, Part 21 are being followed.

·         The only PNPS pilot with a bellows spring from the same material and heat treatment certifications as the failed bellows was removed from the plant. Detailed metallurgical analysis did not identify any intergranular cracks such as those identified in the failed bellows.

·         PNPS has ordered new pilot assemblies with enhancements designed by Target Rock to raise the natural frequency of the pilot and make it more resistant to steam system vibration (References 2 and 3).

These pilots include the bellows replacement recommended by the 10 CFR, Part 21. PNPS plans to install these pilots during the spring of 2015 RFO.

SAFETY CONSEQUENCES:

The leaking SRV pilot valves and the plant shutdown to repair the SRV in accordance with Technical Specification 3.6.D.2 posed no threat to the public health and safety.

All leakage from the valve was collected in plant systems, the suppression pool (torus), and processed in accordance with normal station practices.

Pilgrim has installed temperature monitoring to provide sufficient indication of SRV leakage to ensure that timely actions can be taken to ensure that the plant is maintained in a safe condition. Procedure 2.2.23 provides the instructions and guidance for interpreting and responding to SRV temperature indications. Based on these instructions, the plant was shutdown. The SRV would have been able to respond if needed to meet its core cooling
or reactor pressure vessel over protection functions. As a result, the plant safety was maintained. The risk of operating with a leaking SRV is characterized by an increased chance of having an inadvertently opened SRV with increased chance of that valve failing to reclose.
Assuming the plant operated for 24 hours with this condition, this results in a change in core damage frequency of less than 1.OE-7. The impact of setpoint drift (0.8% below the 3% tolerance) is considered to be bounded by delta change in core damage frequency of less than 1.OE-7.

PREVIOUS EVENTS:

Prior to Cycle 19, there were no leakage or setpoint drifts occurrences with three stage safety relief valves since the new design was installed in April/May, 2011, during Refueling Outage 18 for all four safety relief valves.

During Cycle 19, Pilgrim observed minor leakage from the second stage pilot valve of RV-203-3C. Also, first stage pilot valve leakage was observed from RV-203-3D which was confirmed, plant was shutdown as required by TS 3.6.D.2, and first stage pilot valve was replaced. This event is described in LER 2011-007-00. During the outage for RV-203-3D, the entire RV 203-30 was replaced with a new valve assembly.

The industry has experienced numerous instances where SRV leakage has occurred at other plants with other Target Rock Model three stage safety relief valves.

OE33766 - Three Stage Safety Relief Valve Pilot Leakage just below Normal Operating Pressure - Plant Hatch. The plant Hatch installed the same model 3-stage SRVs in Unit 2 in April 2011. Hatch experienced numerous pilot leaks during 2011. On some occasions, leakage was reduced by power and/or pressure reductions. Hatch Unit 2 had some success through power and/or pressure reductions and operating for several months after reseating the first stage pilot valve through power and/or pressure reductions.

OE26394 & OE26892 - Planned Shutdown due to a three stage Safety Relief Valve Leak - Peach Bottom Unit 3

OE32805 - Safety Relief Valve Temperature Phenomenon – Fitzpatrick

OE34730 - Target Rock 3 Stage Main Steam SRV Bore to Seat Misalignment - Limerick 2

OE19219 - Plant Shutdown Due to Increasing Tailpipe Temperature - Duane Arnold

REFERENCES:

1. Target Rock Letter NID#13307, "10 CFR Part 21 Report, Notification of a Defect, Bellows Failure," June 17, 2013.

2. Target Rock Technical Evaluation of Replacement Items TERI 075, "Technical Evaluation of Pilot Assembly 304095-1 Replacing Pilot Assembly 303977-1 for 0867F-001," Target Rock, Revision A, January 14, 2013.

3. Target Rock Letter SRP1 3003, "Enhancements to Primary Pilot Design," Target Rock, January 21, 2013.

4. Condition Report CR-PNP-2013-0378, Safety Relief Valve RV-203-3B, Pilot Leakage.























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