update 10/30
Why isn't LER 2015-004-01 a violation? Why did the NRC intentionally walk pass this violation last Sept 2014.
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, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.I don't have any conclusive proof at all the SRV weren't replaced with clean spares last sept 2014. Maybe they all only been in the plant for seven months.
2015-004-01Obviously these guys are in trouble. Going to have to look at the safety evaluation with why they need 13 of 14 SRVs. The NRC implies it is a reactor over power level and vessel pressure thing.
test results for the ten SRVs not meeting the TS requirements are as follows:
Valve ID As Found TS Lift Setting Acceptable Band % Difference
(psig) (psig) (psig) ActualF013C 1216 1130 1096.1 -1163.9 7.61%
F013F 1240 1108 1074.8 -1141.2 11.90%
F013G 1208 1120 1086.4 - 1153.6 7.86%
F013H 1148 1108 1074.8-1141.2 3.60% (in about 7 months)
F013J 1161 1120 1086.4 -1153.6 3.66%
F013K 1161 1108 107 4.8 -1141.2 4.80%
F013 L 1165 1120 1086.4 -1153.6 4.00%
F013 M 1207 1108 1074.8 -1141.2 8.90%
F013P 1221 1120 1086.4 -1153.6 9.00%
F013R 1169 1120 1086.4 -1153.6 4.38
This is what I mean by stove piping or siloing. Nobody considered a SRV pressure lift setpoint over limit could be discovered when the plant is operational. Nobody ever figured somebody would discover evidence of a inop could occur early in a operating cycle. Then the outside contender would discover a 72% failure rate in last cycle and Hope Creek has been whining about wanting to replace the poor reliability 2 stage SRV. There is very credible proof Hope Creek in recent years spent the majority of its operational time in a condition when they shouldn't have been allowed to operate. This is a perfect SRV storm and the industry will be studying or training on these events for many years.
REACTOR COOLANT SYSTEM
3/4.4.2 SAFETY/RELIEF VALVES
SAFETY/RELIEF VALVES
LIMITING CONDITION FOR OPERATION
3.4.2.1 The safety valve function of at least 13 of the following reactor coolant system safety/relief valves shall be OPERABLE*# with the specified code safety valve function lift settings:**
4 safety-relief valves @ 1108 psig ±3%
5 safety-relief valves @ 1120 psig ±3%
5 safety-relief valves 0 1130 psig ±3%
APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.
ACTION:
a. With the safety valve function of two or more of the above listed fourteen safety/relief valves inoperable, be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN within the next 24 hours.
b. With one or more safety/relief valves stuck open, provided that suppression pool average water temperature is less than 110F, close the stuck open safety relief valve(s); if unable to close the stuck open valve(s) within 2 minutes or if suppression pool average water
temperature is 110F or greater, place the reactor mode switch in the Shutdown position.
c. With one or more of the above required safety/relief valve acoustic monitors inoperable, restore the inoperable monitors to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
*SRVs which perform as ADS function must also satisfy the OPERABILITY requirements of Specification 3.5.1, ECCS-Operating.
**The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures.
#SRVs which perform a low-low set function must also satisfy the OPERABILITY requirements of Specification 3.4.2.2, Safety/Relief Valves Low-Low Set Function.
HOPE
TABLE 1.2
OPERATIONAL CONDITIONS
MODE SWITCH
POSITION
AVERAGE REACTOR
CONDITION COOLANT TEMPERATURE
1. POWER OPERATION
2. STARTUP
3. HOT SHUTDOWN
4. COLD SHUTDOWN
5. REFUELING
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