NRC Answers Me About Concerns With Hope Creeks SRVs, AGAIN

Update

Mike Mulligan <steamshovel2002@gmail.com>	Sep 29 (1 day ago)
to R1ALLEGATION

Nicole,

So my comment about insulation revolves around how cavalier the NRC treats the insulation issue in this sentence. I have no information about SRV insulation issues at Hope Creek. It's not safety related, but some vague consideration is given.

"Some parts are classified as PC3 (e.g. piping and valve insulation), which means they are not safety-related, but quality consideration is given."

The big picture is, why are there so many recent issues with Target Rock SRV valves? Why can't the NRC and the licensees get a handle on these performance issue? The Industry are notorious with flip flopping between stage 2 and stage 3 valves. A plant may have issues with performance and leakage with the stage 2. They go to the stage 3. The problems are worst in the stage 3. Then they go back to the  stage 2. And on and on and on. This constitutes really experimentation.

The road blocks to fixing this so call performance issues are notorious. The example with HC is they finally publically admit the plant has set point drift performance issues. Actually it is drastically worsening in the last decade. One half ass fix after another, after the new fix, the performance issues just worsens. They begin discussions with Areva for replacements. Nothing comes out of it. Now HC decides to save their ass by going with the questionable stage 3, but a new quality issues shows up delaying the replacements. Why is the supply chain for SRVs and their component so brittle?          

Why is there one excuse after another, but it never gets fixed. I get you guys are blindly following the rules. So following the rules is solely the objective here, not getting things fixed.  

These guys are cycled extremely infrequently and no environmental stress around them. One only wonders what would happen in a accident. God help us all if you are treating the millions of components and parts like this in the plant

Excepts with Most recent LER

Supplemental Licensee Event Report (LER) Number 2016-003-01,"As-Found Values for Safety Relief Valve Lift Set Points Exceed Technical Specification Allowable Limit."

On October 22, 2016, Hope Creek Generating Station (HCGS) received results that the 'as-found' set-point tests for safety relief valve (SRV) pilot stage assemblies had exceeded the lift setting tolerance prescribed in Technical Specification (TS) 3.4.2.1. The TS requires the SRV lift settings to be within +/- 3% of the nominal set-point value. During the twentieth refueling outage (H1 R20), all fourteen SRV pilot stage assemblies were removed for testing at an offsite facility. Between October 22 and October 28, 2016, HCGS received the test results for all fourteen of the SRV pilot valve assemblies. A total of ten of the fourteen SRV pilot stage assemblies experienced set-point drift outside of the TS 3.4.2.1 specified values. All of the valves failing to meet the limits were Target Rock Model 7567F two-stage SRVs. This is a condition reportable under 10 CFR 50.73(a)(2)(i)(B) as an Operation or Condition Prohibited by Technical Specifications.

The cause of the set-point drift for the ten SRV pilot stage assemblies is attributed to corrosion bonding between the pilot disc and seating surfaces, which is consistent with industry experience. This conclusion is based on previous cause evaluations and the repetitive nature of this condition at HCGS and within the BWR industry.

Two technical evaluations were performed to assess the aggregate safety-significance of the 10 SRVs with out of tolerance initial lift set-points and determine whether the condition would have had an adverse effect on the safety function of the valves or other affected systems, structures and components (SSCs). One technical evaluation looked at 1) the Reactor Pressure Vessel (RPV) over-pressure design function of the valves; 2) the impact of higher relief setpoints on other safety systems (i.e., HPCI, RCIC, and SLC); and 3) fuels considerations. The second technical evaluation looked at stress related issues (down-comer piping, supports, spargers, and torus loads).

The evaluations concluded that the as-found condition was bounded by margins which exist in current Hope Creek design analyses; thus, the aggregate effect of this condition has no Safety Significance. In all cases, the RCS would have remained within allowable limits, and safety-related systems relied upon during high-pressure events (HPCI, RCIC and SLC) would have functioned sufficiently in accordance with the station's design bases had an accident or limiting transient occurred during Cycle 20. Fuel limits were no adversely affected by this condition.

***You see the historic trajectory going on here with these defective valves. The pressure setpoint drift was originally plus or minus 1%. The design commitment reliability was never met in these defective valves. The fix with the excessive pressure setpoint drift was to jack the inaccuracy to plus or minus 3%. As with a bunch of electro plating coatings on the pilot disc and seat that never fixed the problem. The rate of drift went up to unbelievable levels. Cooper is required to have 7 of 8 SRV operable if within plus or minus 3%. They are trying to reduce it to be 5 of 8 SRV operable or be shutdown. You got to know this is a test case. The rest of the industry wants to get this way. 

I was led to believe the PI&G inspection was a result of me.

Sept 27 R1ALLIGATION RESOURCE  To me

 Mr. Mulligan, the attached letter responds to three concerns you raised to the NRC regarding the Hope Creek SRVs. As discussed in the letter, the NRC recently conducted a PI&R inspection at Hope Creek that addressed various aspects of SRV maintenance and operation, in addition to your three concerns. The results of the PI&R sample will be

The NRC is signaling me pretty seriously they want me to see this this next PI&R documented in an upcoming inspection report.

Please confirm receipt. Sincerely, Nicole Warnek Sr. Allegation Coordinator 610-337-5222 (Region I Safety Hotline) 800-432-1156 x5222 (Hotline, Toll Free) U.S. Nuclear Regulatory Commission, Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406 I will pass your question about insulation along to Steve Pindale (who as you know conducted the most recent SRV inspection.) As for your second request, the text is below. Sincerely, Nicole Warnek Sr. Allegation Coordinator 610-337-5222 (Region I Safety Hotline) 800-432-1156 x5222 (Hotline, Toll Free) RI-2017-A-0028 Mike Mulligan                                                                                              steamshovel2002@gmail.com    SUBJECT:  Concerns You Raised to the NRC Regarding Hope Creek Dear Mr. Mulligan: The NRC Region I Office has completed its follow up in response to the concerns that you brought to our attention on May 2 and 3, 2017, regarding Hope Creek.  Your concerns were related to the safety relief valves.  Enclosure 1 to this letter restates your concerns and describes our review and conclusions regarding each concern.  Thank you for informing us of your concerns.  Allegations are an important source of information in support of the NRC’s safety mission, and we take our safety responsibility to the public seriously within the bounds of our lawful authority.  If you have any questions or if the NRC can be of further assistance in this matter, please call us toll-free via the NRC Region I Safety Hotline at 1-800-432-1156, extension 5222, between 7:30 a.m. and 4:15 p.m. EST, Monday through Friday, or contact me in writing at 2100 Renaissance Blvd, Suite 100, King of Prussia, PA, 19406. Sincerely, Nicole S. Warnek Senior Allegation Coordinator Enclosure:  As stated Concern 1: You asserted that there are commercial grade dedication problems concerning the Safety Relief Valves (SRVs) at Hope Creek. Response to Concern 1: NRC Assessment In July 2017 the NRC conducted a problem identification and resolution (PI&R) inspection sample focused on the SRVs at Hope Creek.  As part of this inspection, the inspector questioned Hope Creek staff regarding the use of non-Target Rock parts in the SRVs and associated solenoid valves and if any commercial grade dedicated parts were used.  PSEG staff indicated that they do not do commercial grade dedications (purchase class 2, or PC2) for SRV parts.  SRV parts that are safety-related are I am not sure what having commercial grade dedicated parts mean. It seem to me Target Rock basically doesn't make safety grade SRVs. A vender then upgrades the valves into safety related grade. They then sell it to HC. It the old days Target Rock would make safety grade. Accountability here is balkanized. You know, too many safety grades really translates into no safety grade. procured as PC1, which means they come qualified from an approved vendor.  Some parts are classified as PC3 (e.g. piping and valve insulation), which means they are not safety-related, but quality consideration is given.  The PC3 parts have augmented quality requirements, which are primarily vendor supplied and documentation is typically a certificate of conformance.  Finally, there are some items that are procured as non-safety related (PC4), such as gaskets, washers, and lubricants. The NRC inspectors reviewed the list of Hope Creek’s SRV PC4 parts and independently verified that these parts do not perform a safety function.  They are non-pressure retaining, non-load bearing, and do not have an active function.  Once they are properly installed, they have no credible failure mode that would impact the ability of the SRV to perform its safety function to maintain and relieve pressure.  Therefore, they are not required to undergo a commercial grade dedication process. NRC Conclusion Based on the results of our inspection, the NRC could not substantiate your concern that there are commercial grade dedication problems concerning the SRVs at Hope Creek. Concern 2: You asserted that there are Part 21 problems with the SRVs at Hope Creek. Response to Concern 2: NRC Assessment During the NRC PI&R inspection conducted in July 2017, the inspector noted that the Hope Creek staff were aware of the Part 21 issue associated with the 3-stage Target Rock SRVs.  As a result of the Part 21, PSEG had postponed the installation of a planned modification to use one or more 3-stage Target Rock SRVs at Hope Creek, pending resolution of the issues documented in the Part 21 report (i.e., Curtiss Wright Flow Control Co. – Target Rock Division; EN 50900, dated 3/17/15, and updated on 5/1/15, 6/30/15 and 2/3/17). These Part 21 Curtiss Wright reports and updates are associated with the Pilgrim 2015 SRV failures. Can you even believe how long it takes to understand and correct SRV failures. So the 2015 pilgrim SRV failure are preventing Hope Creek from installing their 3 stage SRVs.   NRC Conclusion Based on the results of our inspection, the NRC confirmed that a Part 21 report regarding 3-stage Target Rock valves (EN 50900) was evaluated for applicability at Hope Creek.  The NRC did not identify any inadequacy or impropriety associated with Hope Creek’s handling of this Part 21; therefore, your concern was not substantiated. Concern 3: You asserted that the SRVs at Hope Creek are in worse shape than the NRC knows.  Response to Concern 3: NRC Assessment The NRC maintains awareness of plant operating and equipment issues through NRC resident inspectors who report each work day to the Hope Creek station.  Additionally, specialist inspectors from the NRC’s Region I Office have conducted periodic focused inspections of PSEG’s performance to test and maintain SRVs over the years.  The last inspection report that documented NRC’s reviews and conclusions in this regard was NRC inspection report 05000354/2016001, Section 4OA2, dated May 10, 2016 (ML16131A095).  We expect that the results of our most recent inspection on this topic (the July 2017 PI&R sample) will be documented in an NRC integrated inspection report 05000354/2017003, due to be issued no later than November 14, 2017.  This report will be publicly available on the NRC website once it is issued, at https://www.nrc.gov/reactors/operating/oversight/listofrpts-body.html. NRC Conclusion Based on the results of our July 2017 onsite inspection, as well as previous inspections performed in this area, the NRC concluded that we are knowledgeable of the condition of the SRVs installed at Hope Creek, including the challenges the station has faced with maintaining the SRVs.  As such, we did not substantiate your concern that the SRVs at Hope Creek are in worse shape than the NRC knows. From: Mike Mulligan [mailto:steamshovel2002@gmail.com] Sent: Wednesday, September 27, 2017 10:06 AM To: R1ALLEGATION RESOURCE <R1ALLEGATION.RESOURCE@nrc.gov> Subject: [External_Sender] Re: Concerns You Raised to the NRC Regarding Hope Creek (RI-2017-A-0028) Nicole, I no longer communicate with the individual who gave me this information. I don't trust him. I see the NRC says the SRV insulation isn't safety related. I find this assertion ridiculous. So insulation has never been involved in the deterioration with the operability of the SRVS? I remember seeing many insulation issues with SRV LERs and inspection reports effecting component reliability. I remember my 2.206 concerning VY's actuator seals. Basically the valves weren't qualified for their environment. I believe the type I, type II component environmental mixup is in a VY inspection report.  Anyway, I thank the NRC for this report Could you send me a non photocopy copy of this document. I just want to copy and paste this document to my blog.  Mike On Wed, Sep 27, 2017 at 9:35 AM, R1ALLEGATION RESOURCE < R1ALLEGATION.RESOURCE@nrc.gov> wrote: Mr. Mulligan, the attached letter responds to three concerns you raised to the NRC regarding the Hope Creek SRVs. As discussed in the letter, the NRC recently conducted a PI&R inspection at Hope Creek that addressed various aspects of SRV maintenance and operation, in addition to your three concerns. The results of the PI&R sample will be documented in an upcoming inspection report. Please confirm receipt. Sincerely, Nicole Warnek Sr. Allegation Coordinator 610-337-5222 (Region I Safety Hotline) 800-432-1156 x5222 (Hotline, Toll Free) U.S. Nuclear Regulatory Commission, Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406 Mike Mulligan <steamshovel2002@gmail.com> 1:35 PM (1 hour ago) Nicole,  Thank you for everything you do. Just saying, I hope the PI&R inspection is congruent with SRV inspection report answering my concerns of a few years ago. I could get you the IR number if the NRC needs it.