Would it make a difference?
The rumor going on has it Pilgrim’s 2 stage SRVs have been borrowed from this Hope Creek’s SRV disaster? All three of the test 3 stage SRVs failed lift testing and 71% of their 2 stage failed also. Check out the date I wrote my blog entry. Would it make a difference to Pilgrim's continued operation if they had Hope Creek 2 stage SRV in the plant?
Nearly Identical To Pilgrim’s SRVs: 71% Target Rock Two Stage SRV Tech Spec Failure Rate
I like the concept of DG load testing. They test these guys monthly or so at full design load. They don’t test these guys at say 5% full plant design load. We got big quality troubles with both the 2 stage and 3 stage Target Rock safety relief salves. These failures are sending us a big signal something has to done about these problem.
As most BWR plants during the worst case design accident…very infrequent…these Safety Relief Valves could/will have to be cycled up to 400 times. I don’t think the current testing regime covers this worst duty at all. How do we know how these delicate valves will behave after 100 cycle in a short period time and environment? We are talking science and engineering here?
I’d be test cycling a hunk of these valves some 400 times...one valve 400 times per outage. This is how the engineers screw the operations people when the plant is in the clutches of a terrible designed accident…they don’t have our backs. Nope, seeing how important these guys are when 99% of the safety systems have been wiped off the table and unavailable, I be regularly test cycling these guys 800 times just to make sure something is working when everything else is gone.
By the way, I got a great question for everyone. They say test stand lift or pressure testing damaged the internal just before going into the Pilgrim plant. Why hasn’t the damaged proliferated to the other BWR plants who also used this test stand or similar? Why haven’t I seen problems similar to Pilgrim’s throughout the industry whose use similar test stand set-ups, testing regimes or procedures?
Sincerely,
Mike Mulligan
Hinsdale, NH
http://steamshovel2002.blogspot.com/
This is the NRC response to me. Mr Sheenan is a public relation NRC official. He has little contact with technical information and the plant itself...especially hands on experience with things going on in the plant.
The NRC conducted an annual Problem Identification and Resolution Inspection sample at Pilgrim related to installation of these 2-stage safety relief valves (SRVs). As documented in the inspection report:
• Entergy removed all four 3-stage SRVs and replaced them with refurbished 2-stage SRVs.
• The 2-stage SRVs are of a design that is in use at other industry boiling water reactors.
• The inspectors reviewed design documentation associated with this change. The inspectors determined that the modification and design of these 2-stage SRVs are consistent with Pilgrim’s design and licensing bases.
• The inspectors observed surveillance testing of the 2-stage SRVs during startup from the last refueling outage, and observed proper operation when actuated manually from the main control room.
• The inspectors concluded that the 2-stage SRV design did not invalidate any existing commitments or requirements.My response?
Based on our inspection, we determined that use of the 2-stage SRVs was acceptable.
Neil Sheehan
The NRC put it up on the blog...I am actually impressed with their transparency.If I knew what plant those SRVs came from, then I could do an Adams look-up on the operational history of that model and the particular valves to see how safe they are? This unnecessary secrecy implies a cover-up in itself.
Did they come from Vermont Yankee?
Why didn’t Energy just refurbish their old two stage 2010 valves to save money?
Are the SRVs in the plant now identical to the pre 2010 ones? Cause if not, they needed a 10 CFR 50:59 and LAR. As you know, these valves could operate perfectly in another plant, but be inappropriate in Pilgrim. Our domestic fleet of nuclear plants are basically a design one off...each are mostly a unique design?
Blog: The inspectors observed surveillance testing of the 2-stage SRVs during startup from the last refueling outage, and observed proper operation when actuated manually from the main control room. Basically the 3 stage SRVs were unfit to be in an operating reactor plant.
They did exactly the same test at the beginning of the last operating period with the 3 stage SRVs and nobody ever discovered that the three SRVs were nonfunctional and required an immediate emergency shutdown. Was there NRC observers there on that test?
There is increasingly widening gulf between what is documented in an “inspection report” and what really is going on in the plant. This is the story of the SRVs, Pilgrim and the NRC since 2010.
So we are going to make believe Entergy never wrote this 2010 evaluation and the document isn’t in the docket?
Entergy to NRC: Pilgrim Nuclear Power Plant To Cease Operations
Part 1 continuing
By the way, I am impressed with the NRC for allowing me to discuss problems like this on your blog.
Am I the only one reading documents submitted by Entergy to the NRC anymore? Does the NRC keep up with reading pertinent documents like Pilgrims 2010 SRV License Amendment Request? They are shifting from the 2 stage to the defective and dangerous 3 stage SRV. We now have these 2 stage reliefs back in Pilgrim??
Basically Entergy says the valves currently in the plant are dangerous, leak and unsafe in the below 2010 LAR document. These valves drift outside the tech spec set point often requiring a immediate shutdown wink, wink. But these dangerous degradations are undetectable at power. This is why we went to the 3 stage SRV. You might have inop two or more valves each requiring a immediate safety shutdowns, but the plant can’t detect the dangerous deterioration. Don’t be confused, I am not talking about the 3 stage SRV removed from the plant last spring…these are the guys in the plant right now.
“Proposed License Amendment to Technical Specifications: Revised Technical Specification for Setpoint and Setpoint Tolerance Increases for Safety Relief Valves (SRV) and Spring Safety Valves (SSV), and Related Changes”March 15, 2010
The SRVs require replacement because the current two-stage Target Rock SRVs have been unreliable performers with respect to leaking while in-service and the subject of setpoint drift. SRV pilot valve leakage has led to multiple plant shutdowns and the setpoint drift problem resulted in exceeding current TS limits and numerous Licensee Event Reports (LERs). It has been determined that pilot valve leakage is due to low simmer margin and high as-found lift setpoints are due to corrosion bonding at the pilot valve disc/seat. To address current SRV performance problems, Entergy has performed extensive investigations and feasibility studies. The preferred option for correcting these problems is to replace all SRVs and SSVs during the next refueling outage. RFO-1 8 is currently planned to start on or about April 17, 2011.
Mike MulliganHinsdale, NH
http://steamshovel2002.blogspot.com/
Part 2
Entergy's LER: Notice how Entegy is allow to pick and choose what information they release to the public? They aren’t required to explain the vulnerabilities and defective 2 stage design outlined in their 2010 LAR going into the plant after the 2015 spring outage.
“All SRV body/bases were removed from the system during the current refueling outage. In place of the four SRV's removed from the plant during the current refueling outage, PNPS has installed 2-stage SRV's”
This is a brazen cover-up on top of the first cover-up. It is mind boggling.
Inspection Report 2015-002, is this a full and accurate statement considering how defective and unsafe Entergy identified the 2 stage in the 2010 LAR? Should the residents discussed the limitation of the 2 stage in 2015-002-02?
“The inspectors concluded that the 2-stage SRV design did not invalidate any existing commitments or requirements.”
They are used valves from another plant and Entergy has indication this model valve is defective and dangerous in their 201O LAR. They certainly aren’t new. They basically grab them from a nuclear plant junk yard. They aren't being manufactured today.
Entergy Senior Communication Specialist Lauren Burm: “Burm said four new safety relief valves were installed during a recent refueling and refitting of the reactor.”Seriously Bill, is this statement true?
Bill Mohl, president of Entergy Wholesale Commodities: “Mohl said that the plant has previously addressed the safety relief valve issue and the plant is operating safely”.
Again the skimpy information gives Entergy the advantage to keep operating with a poorly designed component and dangerous. You notice both sides of the story; this is why Pilgrim needs the valve and this is the vulnerabilities of the design of the valve? You decide if it is safe or not. The NRC never treats us as adults.
NRC Public Affairs specialist: “The plant has since replaced all four valves...”
Part 3
As a compensatory action for the defective and dangerous SRV 2 stage SRVs outlined in the 2010 LAR:
I request Pilgrim to shutdown for any indication of a leaking SRVs or any out of normal temperature reading of a tailpiece. I request Pilgrim to shutdown quarterly in order to detect the outside setpoint 3% plus or minus required tech spec vulnerabilities and unreliabilities.
The OIG was really was involved with this…I request a outside the OIG and NRC investigation of this whole mess.
It all leads to this…I am asking the NRC now. Is the 2 stage SRVs now installed in Pilgrim safe? Does these valves meet all codes and rules…do they meet the highest ethical and nuclear professional obligations. Could you direct me to a current comprehensive engineering document discussing all the historic safety limitation of the currently installed 2 stage SRV valves and the compensatory action?
Sincerely,
Mike Mulligan
Hinsdale, NH
http://steamshovel2002.blogspot.com/
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