Sunday, May 31, 2015

March 7, 2013: Mike Mulligan's Request For Special Inspection on Pilgrims SRVs Problems

Additionally, during an extent of condition review of historical SRV performance, the review identified on March 13, 2015 that SRV-3A had failed to open in response to three manual actuation demands on February 9, 2013 with reactor pressures of 114, 101, and 98 psig.


I supposed I could have danced around in a sting bikini at the font door of the NRC's main office trying to get them to take action. Maybe that could made them act.

The media is about worthless!!! 

From: Michael Mulligan [mailto:steamshovel2002@yahoo.com] 
Sent: Thursday, March 07, 2013 12:33 PMTo: newstip~globe.com; NRC Allegation
Subject: 2.206: Pilgrim Nuclear Plant SRVRequest for Emergency Shutdown  
Dear Sir, 
I called this into your hotline by telephone and left a message to a reporter an hour or so ago. This is just a follow-up. I'd like to get Gov Patrick to demand an immediate Pilgrim shutdown and demand a special investigation of these events.  
Mike 
So the below is my 2.206 request to the NRC. You'd do me a favor if the BG calls our region I public relation people...Neil Shaheen. 

March 7, 2013

Bill Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Dear Mr. Bochardt,

Request an emergency and for a exigent bases, that the Pilgrim Nuclear plant be immediately shut down. 
Don't tell me just before Nor'easter Nimo struck the Pilgrim plant with a leaking safety relief valve and down at 80%, Entergy was intending to operate that plant with a defective leaking safety relief valve till the next refuel outage? Tell me it ain't so. It certainly looks like with the current leak today they are intending to operate till next month. 
Is the game plan today to incrementally increase reactor power from 94% by 1% to see if a new SRV leak is getting worse? 
Timeline: 
1) New three stage safety relief valves installed in the plant around May 2011. 
2) First leak and shut down on Dec, 26. 2011 (SRV RV-203-3D). 
3) Second leak and shut down on Jan 20, 2013 (SRV RV-203-3B).  
4) Third leak occurred a few weeks later and the Nemo blizzard tripped the plant.. .the NRC promised these valves would be fixed. (SRV RV-203-3B). 
5) Basically they operated for 20 days at 100% power operation post shutdown, then reported on Feb 27 the plant is operating at 94% power with no explained reason until today. The reason for the down power was kept secret from the public.
(NRC added: EDO -- G20130174)  
Don't forget the repetitive nature of the recently broken scram discharge volume vent and drain valves...implies Entergy is incapable of maintaining safety components in a nuclear plant.  
The repeated nature of the failure of the safety relief valves means Entergy doesn't know the mechanism of the failure.. .it is a common mode failure. The design and manufacture of these valves
They changed out the not safe 3 stage SRV valves  for new 2 stage SRVs after Juno...the NE+RC forced their hands  
are defective and it is extremely unsafe to operate in a nuclear plant with all safety relief valves being INOP. A condition adverse to quality...  
The NRC should have made a public comment about the new leaking safety relief when they first became aware of the leak. The implication is the agency was going to allow the plant to operate with unsafe SRVs until the refueling outage next month. The NRC is involved in a serious cover-up of an extremely unsafe operation in a nuclear power.  
1) Request an immediate shutdown the Pilgrim Plant.  
2) The is the second time I requested a special NRC inspection concerning the defective SRV valves.  
3) Not allowing the plant to restart Pilgrim until they fully understand the past failure mechanisms of the four bad new three stage safety relief valves.  
4) Request the OIG investigate this cover-up to keep an unsafe nuclear plant at power. 
References:
The Popperville Town Hall (my blog) 

"Pilgrim's Safety Relief Valve Leaking Boondoggle"

Sincerely,
Michael Mulligan
PO Box 161
Hinsdale, NH 0345116033368320
steamshovel2002@vahoo.com
This is the agency's take directly in the lead up to the Juno's trip. There is a lot more evidence. These guys are picking and choosing what information they think is important to push  out for a organizational agenda.  
May 27, 2015: PILGRIM NUCLEAR POWER STATION – NRC SPECIAL INSPECTION REPORT 05000293/2015007; AND PRELIMINARY WHITE FINDING
  • The ‘A’ SRV was not planned to be used due to previously identified pilot valve leakage, but was considered by Entergy to be available for use if needed.
The problem with the above in a past LER with pilot valve leakage, they all should know this...the leak can make the relief lift inaccurate without being detectable. It could be so inaccurate if they knew about it, they would have to intermediately shut down to fix it. It illegal to be up at power with a inaccurate SRV valve.  
  • While the ‘C’ SRV satisfactorily stroked during both the setpoint test and additional low pressure (100 psig) actuation test at the testing facility, the inspection revealed notable damage to some internal valve main stage parts. Specifically, the main valve piston had indications of some scoring and the lower piston ring (two rings in total) was seized within the piston ring. The most noteworthy damage was wear (grooves) in the main operating cylinder liner where the operating piston rings rest while the valve is in its closed position.

  • During Entergy’s investigation of the January 27, 2015 partial LOOP event, Entergy staff reviewed plant parameter data associated with historical SRV actuations. During the review, Entergy staff determined that the ‘A’ SRV similarly did not open during manual actuations on February 9, 2013, during a plant cooldown following a LOOP event. This determination was based on Entergy’s review of the response of reactor pressure, level, local suppression pool temperature, and SRV tailpipe temperature.
I think Entergy was actively not looking for problems with the SRV valves in 2013. They knew the mis-operation and choose not to report it. 

  • Entergy identified that, during the February 9, 2013, event, operators attempted to utilize the ‘A’ SRV to reduce reactor pressure on three occasions (at 114 psig, 101 psig, and at 98 psig). The operators observed that the ‘A’ SRV did not yield the appropriate tailpipe acoustic monitor response, although tailpipe temperature did show an increase. Following the third opening without observing the appropriate acoustic monitor response, operators only utilized the ‘C’ and ‘D’ SRVs for plant cooldown [note that the operators considered that the ‘B’ SRV was less desirable to use due to previously-observed pilot valve leakage]. 

  • The only action that resulted from CR-PNP-2013-00825 was the replacement of components associated with the ‘A’ SRV’s acoustic monitor. Maintenance workers identified an electrical ground on the system. Analysis. Entergy’s failure to identify, evaluate, and correct the condition of the ‘A’ SRV’s failure to open upon manual actuation during a plant cooldown on February 9, 2013, was a performance deficiency. In addition, the failure to take actions to preclude repetition resulted in the ‘C’ SRV failing to open due to a similar cause following the January 27, 2015 LOOP event.
2015-002-00: On March 12, 2015, after further engineering evaluation of performance of the valves and internal conditions identified during inspection, SRV-3A and SRV-3C were determined to have been inoperable for an indeterminate period during the last operating cycle. SRV-3C was determined to be inoperable based on its on-demand performance at low reactor pressures (first

Licensee Event Report (LER).2013-002-00, "SRV-3B Safety Relief Valve Declared Inoperable Due to Leakage and Setpoint Drift" was submitted on March 31, 2013 (Reference 1), with a target schedule of September 30, 2013 to submit a Supplement to the LER, after completing
the root cause analysis. Since then the vendor (Target Rock) has issued a 10 CFR Part 21 Notification, (Reference 2)confirming defects in safety relief valve bellows.

2013 - 002 - 01 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).
Licensee Event Report 2013-002-01, SRV-3B SafetyRelief Valve Declared Inoperable Due to Leakage and Setpoint Drift
1/20/2013
  • This condition potentially applies to all four three
The design is defective creating the damaged components. There was no way to reliability to observe or predict the degradation mechanism. They were unfit for reactor operation...they were inop from new installation and onto the Juno plant trip.

The 3 stage SRVs defective and unsafe...post last outage they were all removed. 


Lets say the main spring was so severely damaged it would fail in three cycles. It would get through all the testing, then have two cycles before failing. It would pass all test, but sitting right on the precipice of failure. Is that fully operational or inoperationl? Does getting past all the pre-operational testing mean it is operational despite the actual materiel condition of the components inside the valve. 


I am certain there would be many other problems documented in secret plant documents than this.    

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 Deviation23 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
  • 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.
























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