Wednesday, September 11, 2019

More Manufacturing Problems with Steam Generators and Reactor Vessels

Update Sept 13

Burnell, Scott

Thu, Sep 12, 11:55 AM (19 hours ago)


to me, OPA


Hello Mike;

The NRC continues await more information on the issue, so it would be premature for the agency to draw any conclusions. To this point no vendor has filed a Part 21 report regarding Framatome’s statement. Thank you.

Scott Burnell

Public Affairs Officer

Nuclear Regulatory Commission



Mike Mulligan <steamshovel2002@gmail.com>

Thu, Sep 12, 7:18 PM (12 hours ago)
 


to Scott


That is a blatant copout. You could make a request on a regulator to regulator bases to get information about this.
***EDF/ Framatome Saint Marcel factory SG Problem

Mike Mulligan <steamshovel2002@gmail.com>

11:25 AM (1 hour ago)

to OPA

OPA Resource <OPA.Resource@nrc.gov>

To:steamshovel2002@yahoo.com

Sep 11 at 10:18 AM

Mr. Douglas, 
Could we get a public notification and a explanation surrounding the Saint Marcel manufacturing problems with SGs and other large components? I am thinking on your web page and Facebook. Could I speak to a expert concerning this? Could this be going on at other SG manufacturing facilities throughout the world for US plants? I know Prairie Island's SG's came from Saint Marcel and it fits the time frame. Could we get a list of US plants and components that came out of Saint Marcel factory? I hope the NRC has notified the appropriate plants they may defective SGs and other components in their plants? With the Areva  hydrogen flaking with vessels and now this, it questions the quality of components coming from Framatome.

I screwed up. I gave you the wrong e-mail address. Well actually your NRC'c virus protection won't accept some yahoo emails because of credibility issues...spam. Instead of using steamshovel2002@yahoo.com would you use steamshovel2002@gmail.com from now on.

I just want to thank you for being a US government employee during these tumultuous times in our nation's history. Keep holding your head up high? 

Mike Mulligan 
Hinsdale, NH
16032094206      

***Made at the Saint Marcel factory in France? 
The ASN was not immediately available for comment, but Frederic Menage, head of nuclear safety at ASN’s technical arm IRSN, told Reuters the weldings problems affected mainly EDF reactors whose steam generators had been replaced since 2008, notably its older 900 megawatt reactors.
I don't know what "notably its older 900 megawatt" means. I read it as saying their older reactors at around 900 megawatts. There is no doubt Framatone would do everything they could to not get their American SGs involved unless it was pried out of them. They are differently not saying there is no American SGs involved. That is why we must get the NRC involved. All I want them to say is no American SGs are involved...

Update: Vogtle 3 and 4 SGs didn't get produced by Framatone. 

  
(Vogtle 3 and 4: AP1000)
...EDF warns of problems with nuclear reactor components

The energy giant didn’t, however, say if any of the reactors will have to be halted 

By Priyanka Shrestha
More Articles

Wednesday 11 September 2019


Image: Olrat/Shutterstock

French energy giant EDF has warned several of its nuclear reactors may have problems with weldings and other components.

In a statement published on its website, EDF said nuclear reactor company Framatome – formerly called AREVA – informed it of a “deviation from technical standards” in the manufacturing of certain components on reactors that are currently in operation.

EDF holds a majority stake in Framatome, which owns a factory that supplies heavy equipment for the French nuclear industry and has provided components for 106 reactors worldwide.

The energy giant didn’t, however, say if any of the reactors will have to be halted.

The statement adds: “Relating to standards associated with the manufacturing process, the deviation concerns an excursion from temperature ranges in certain areas during manufacturing operations, more specifically involving detensioning heat treatment on some steam generator welds.


“It concerns in-service components as well as new components which have not yet have been installed on any sites.”

Reports suggest the news has sparked the biggest daily fall in the company’s shares in nearly two years.

More than 71% of the electricity production in France comes form nuclear power plants, according to statistics from the International Atomic Energy Agency (IAEA) last year.

EDF is currently leading a project to build reactors at the Hinkley Point C nuclear power station in Somerset in the UK.

Browns Ferry: Operators Denied Access To Safety Systems

Well, this is what you would see in a EMP bomb?
Power Reactor Event Number: 54266
Facility: BROWNS FERRY
Region: 2     State: AL
Unit: [1] [2] [3]
RX Type: [1] GE-4,[2] GE-4,[3] GE-4
NRC Notified By: RYAN GRIMME
HQ OPS Officer: THOMAS KENDZIA
Notification Date: 09/11/2019
Notification Time: 03:10 [ET]
Event Date: 09/10/2019
Event Time: 19:34 [CDT]
Last Update Date: 09/11/2019
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(ii)(B) - UNANALYZED CONDITION
Person (Organization):
FRANK EHRHARDT (R2DO)

Unit SCRAM Code RX Crit Initial PWR Initial RX Mode Current PWR Current RX Mode
1 N Y 100 Power Operation 100 Power Operation
2 N Y 100 Power Operation 100 Power Operation
3 N Y 100 Power Operation 100 Power Operation

Event Text

UNANALYZED CONDITION DUE TO LIGHTNING STRIKE

"A lightning strike occurred at approximately 1502 CDT on 09/10/2019, and a resulting power surge damaged some of the security door card reader system equipment. However, this did not affect access to plant areas for personnel who were already within protected area. At 1830 on 09/10/2019, it was discovered that some of the oncoming night shift personnel could not access particular areas that required the use of security card readers. Extent of condition check at 1934 on 09/10/2019 determined that access to 1A and 3A Electric Board Rooms, which contain remote shutdown panels and Fire Safe Shutdown equipment. was prohibited for the night shift personnel. This condition is reportable under 10 CFR 50.72(b)(3)(ii)(B) - Any event or condition that results in the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. Access was restored to all plant areas at 2106 on 9/10/2019. No plant events occurred during the time frame that the 1A & 3A Electric Board Rooms inaccessible that would have required access to these areas.

"The NRC Resident Inspector has been notified."

Saturday, September 07, 2019

I Got An Idea, Don't Buy Any Russian Uranium For US Plants

The vast majority of uranium powering our reactors comes from Russia. How about just not buying Russian uranium.  

This is setting up USA to subsidize uranium cost to the utilities.   
White House Considering Direct Purchases of U.S. Mined Uranium

By Brinkwire on September 7, 2019 demestic 

(Bloomberg) — The White House is considering a plan that would have the government directly purchase uranium from U.S. producers as it contemplates ways to revive the flagging domestic mining industry.

A group set up by President Donald Trump to study the issue is considering a request by the nuclear industry to use the Defense Production Act, a 68-year-old Cold War-era statute once invoked by President Harry Truman to help the steel industry. The plan calls for requiring the government to buy American uranium to replenish their stockpiles and for other purposes, Paul Goranson, chief operating officer for Energy Fuels Inc., said in an interview.

Energy Fuels and Ur-Energy Inc. unsuccessfully petitioned the White House to put quotas on foreign imports of uranium. The concept of direct government purchases of U.S. uranium was among ideas discussed during a roundtable with administration staff and the nuclear industry at the Old Executive Office Building earlier this week, Goranson said.

“They seem receptive to direct purchasing of material,” Goranson said. “The president intends to take bold action on this. It’s got his attention now.”

The White House didn’t immediately respond to a request for comment.

Share Rise

Shares in U.S. uranium producers rose on the report. Energy Fuels jumped as much as 11% while Ur-Energy climbed as much as 10%. Cameco Corp. increased about 2%.

Trump in July rejected the Commerce Department’s recommendation that he impose quotas on uranium imports using a trade law tied to national security concerns that he invoked to impose tariffs on steel, solar panels and hundreds of billions of dollars of Chinese goods. Instead, Trump said a fuller analysis was needed and he directed his administration to identify other options. He created a nuclear fuel working group comprised of six cabinet secretaries and several other top White House officials.

The Uranium Producers of America, which represents miners including Cameco, is requesting “federal actions facilitating domestic uranium production” of at least 7.5 million pounds per year by 2025 and 10 million pounds per year by 2030, according to a letter the Santa Fe, New Mexico, trade group sent to the working group last month. That includes millions of pounds via contracts with the Department of Defense, requirements that government-owned utilities buy domestic uranium, and the creation of a new “Federal Uranium Security Stockpile.”

“We may not be able to continue any operations without immediate relief from the impact of state-backed entities, which have distorted global prices and made it more difficult for free market mines in the U.S. to compete,” the group wrote in the letter, which included a request to direct payments to domestic uranium companies.

In a separate letter, the Nuclear Energy Institute, which represents nuclear reactor operators, also recommended the working group use the Defense Production Act to “accelerate the procurement” of domestic uranium as well as “incentivize” the annual purchase of domestic uranium through a tax credit for nuclear utilities.

In addition, the trade group urged expanding an Energy Department loan program to include domestic uranium projects and to ”modernize the Nuclear Regulatory Commission’s regulatory regime to be more safety focused, risk-informed, timely, consistent, cost-contained, and transparent.”

(Updates with more details starting in seventh paragraph.)

Friday, September 06, 2019

How Does the Brunswick Plant Get To Be So Lucky

Electric Power
05 Sep 2019 | 19:41 UTC
Washington
 
Duke shuts Brunswick nuclear plant in North Carolina ahead of Hurricane Dorian

Author William Freebairn
Editor Keiron Greenhalgh
Commodity Electric Power

Washington — For the second time in a year, Duke Energy is shutting its two-unit Brunswick nuclear plant near Wilmington, North Carolina, in advance of the arrival of a hurricane.

Grand Gulf Had a Excellent August Capacity Factor

Pittleful before that.

Friday, August 23, 2019

China

I think the response to Trump and the USA is China is going  are to make a bloody mess out of the  Hong Kong protesters. That will make them look tougher to the USA, Hong Kong and the Chinese people. We are humiliating China.

I think this is going to make the HK protestors even more crazy, more confident... That is why China needs to go crazy on them...

Tuesday, August 20, 2019

Hinsdale, NH: Bad Selectpeople, Bad Department, Bad Police Officers and High Turnover Of Officers

This comes from selectpeoples office. Effectively young people, the right young people, don't want to join the police departments nationwide because of their bad reputation in the media. And the economy is booming.   
Redacted 'Laurie' list offers no answers for local additions  

By PAUL CUNO-BOOTH Sentinel Staff

Twelve police departments from the region are now listed on the exculpatory evidence schedule, which tracks current and former New Hampshire law enforcement officers found to have lied, used excessive force or otherwise behaved in a way that could harm their credibility as witnesses.
This is what I think is the reason of the Laurie list. You get on this list as a police officer, every case of officer probably would get overturned. The state doesn't want justice with these cases and it is cheaper that way.  
Officers stay on the list even after they leave an agency or stop working in law enforcement altogether. Because the state has not released an unredacted list, it is not clear who the officers are or whether they still work in the field.

Five local police chiefs said the officers listed from their departments are no longer employed there. In some cases, they said, the officers have been gone for years. 
You know, the Keene Sentinel puts the disgraceful Hinsdale police department first in the article. There is absolutely no information our town has fixed this problem. I think the police department problem should be our highest priority. It is vital for our economic development. It effects our housing values. What company would want to move to Hinsdale that has a terribly dysfunctional police department.     
“The three that are being reported on by this agency no longer work here,” Hinsdale Police Chief Todd Faulkner said. “I know that some of those names [being on the list] are a result of action that the department took.”...
The impedance of this meeting came from me. I asked about the problems with police in a prior selectmen meeting and it was recorded.   
Pay cited for Hinsdale Police Department vacancies Posted Wednesday, June 5, 2019 7:51 pm 
By Bob Audette, Brattleboro Reformer

HINSDALE, N.H. — The town of Hinsdale has 10 slots designated for its police department, counting the chief of police. But at this moment, it only has four officers and its chief.

"Our department is currently in crisis mode," said Corp. Adam Belville, reading from a statement during the Monday evening meeting of the Hinsdale Board of Selectmen. "Often times there is only one officer working at a time who is responsible for responding to calls and handling investigations."

After reading from his statement, Belville went on to describe the situation as "a boiling point."

"I wouldn't be here if I didn't have the best interests of the town and department in mind," said Belville, who noted many small-town departments get rookie cops who stay on board for a year or two for experience before hopping to a bigger city with better pay.

All four officers on the town's payroll went to Monday night's meeting, but Chief Todd Faulkner stayed away.

"They didn't tell the board anything that I haven't told the board before," said Faulkner, and most of that is about how much pay he can offer new recruits to the department.

"Every year I have expressed to the town that pay is an issue," said Faulkner. "I am sympathetic about how the budget works and how much the people of Hinsdale are paying in taxes, but the hiring pool that's out there is not sustainable and my officers will do what's right for them and their families, regardless of how dedicated they might be to Hinsdale."

Starting pay in Hinsdale is about $19 an hour, or $39,520 a year, for applicants with no certification. With prior experience, the starting pay is a little less than $22 an hour, or about $45,760 a year.

"Do you feel one of the biggest factors in the retention of officers has to do with pay?" asked Selectmen Mike Carrier during the Monday night meeting. Carrier himself is a police officer with the Winchester Police Department and a former member of both the Hinsdale and Brattleboro police departments.

Belville said there are a lot of factors weighing against Hinsdale and other small-town police departments, but pay is one of the major factors.

"Larger departments ... are definitely dangling the pay in front of them," he said. In addition, he noted, officers can work at a larger department and have a smaller caseload because there are more officers on staff.

Sgt. Joshua Murray put it more bluntly.

"Would you go to the town that pays less to do more or go to the town that pays you more to do less?" asked Murray.

Up until about two years ago, said Faulkner, the town guaranteed all of its employees a 3 percent pay raise each year, dependent on a performance review, in addition to cost-of-living increases, amounting to about 5 percent a year.

The town went to performance-based pay raises for two years, he said, but this year has placed a freeze on all pay raises.

The Hinsdale police budget for fiscal year 2019, which ends June 30, is $1,390,493.

Both Belville and Faulkner acknowledged that all the departments in the region are fighting over the best applicants, but only the ones, like Keene, that offer a better starting pay, are winning.

The Keene Police Department is currently hiring, with a starting pay between $43,992 and $55,681, depending no experience.

Pay in nearby Winchester is similar to what is offered in Hinsdale, said Chief Mike Tollett, who has eight full-time slots, counting himself, all of which are filled. However, noted Tollett, one of his officers is leaving on Saturday. Pay starts at about $19 an hour for non-certified officers and $21 to $22 per hour depending on experience.

"Winchester is horrible with pay," said Tollett. And that's not just in his department. "No town employees got annual raises or cost of living increases."

In the past, said Tollett, the way to get a pay raise in the Winchester Police Department was to get promoted.

Something Unusual Is Going On At Browns Ferry

Update

Aug 22, 2019

Lighting Alost Took out Browns Ferry 


Update

https://whnt.com/2019/08/09/tva-completes-457-million-extended-power-uprate-modifications/

Considering how old and obsolete these plants are, it's a three unit facility, a $500 million upgrade is just peanuts. They didn't go big enough to tell you the truth.  

***This just happened overnight. These guys just spend a lot of money upgrading the capacity of the plants and components. A few years back they were continually down powering in the summer because the river water going into the plants was too hot. They spent a lot of money to counteract the hot summer time southern water going into the plants. They are lost a tremendous amount of electricity going into the plant. My best guess its the hot water has come back or overwhelmed the new cooling towers.  

unit# 1   50%

         2    50%

         3     90%



Friday, August 16, 2019

?

NUCLEAR REGULATORY COMMISSION
FULL WRITTEN EXPLANATION
 
The Nuclear Regulatory Commission voted to close the following meeting: 

Tuesday, September 10, 2019
 
10:00 a.m. Briefing on NRC International Activities (Closed Ex. 1 & 9) 
The Commission voted 4 to O on August 1, 2019, to close this discussion which is reasonably expected to involve classified information and which premature disclosure would be likely to significantly frustrate implementation of a proposed Commission action. 
Attendance 
Commissioners and members of their staffs Executive Director for Operations and members of her staff Director, Office of International Programs Representatives of Commission staff offices \
Contact Person for More Information 
Denise McGovern, Office of the Secretary (301-415-0681)
Denise McGovern o~--J.Vvl,~ Office of the Secretary 08/#

Thursday, August 15, 2019

Widespread Platumin Coating Flaking On Seating serfaces in BWR Safety Releif Valves.

Update Aug 19

Experiments: stellite, stellite B and now platium. 

Update Aug17

I spent about 2 hours talking to the Brunswick inspector and the public affairs people yesterday. I called the chairman's office and they got a Washington public affairs officer to talk to me. My aim with the chairman's office was gain me more influence than I deserve. If NRC officials know this emendated from chairman's office they will pay more attention to me. Basically went over the territory with BWR SRV testing failures. It is surprising the inspectors only look at this from their plant perspective...don't understand the big picture. My total objective with calling the chairman's was I want to take to their expert on Safety Relief Valves. He would have broad experience with all the troubles with the SRV. The PA guy said he would do the best that he could do. 

I got wind their is a secret white paper on SRV problems. This isn't disclosed to outsiders. I guess it is a NRC internal position paper, more about the internal agency deliberations. I asked the NRC to release the paper to me. I wonder how many secret white papers, over a host of other issues, there are within the NRC.

***The failure of the platinum to stick to the seating surfaces is a unreviewed safety problem. The problem is only looked at on a single plant bases. It is going on all over the place. Platinum is flaking off at untold BWR facilities including Browns's Ferry and Brunswick. Platinum is just the latest coating scam. This is leading to some eye popping magnitude pressure testing failures never seen before. Worst, the flaking is leading to steam cutting of the seats. This direly threatens the operability of the valves. Steam cutting the pilot valves does lead to a high probability of the valves to fling open at power and inability to shut the valve. It is also implicated in the valve not being about to open on demand and in remote. Pilgrim Plant had similar problems with SRVs. The plant grade by the NRC was severe downgraded and is directly implicated with their permanent closure. 
1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER
YEAR
Browns Ferry Nuclear Plant, Unit 2 05000260
SEQUENTIAL NUMBER
REV NO.
2019 - 002
NARRATIVE
 
I. Plant Operating Conditions Before the Event
At the time of discovery, Browns Ferry Nuclear Plant (BFN) Unit 2 was in Mode 1 at approximately 91 percent power.
II. Description of Event
 
A. Event Summary 
On May 29, 2019, NWS Technologies notified the Tennessee Valley Authority (TVA) with the as-found testing results of the thirteen Main Steam Relief Valves (MSRVs) [EIIS:RV], which were removed during the Spring 2019 Unit 2 Refueling Outage 20 (U2R20). Three MSRVs (BFN-2-PCV-001-0004, BFN-2-PCV-001-0018, and BFN-2-PCV-001-0019) had as-found lift settings which were outside of the +/- 3 percent band of their setpoints required for operability. 
Technical Specification (TS) 3.4.3, Safety/Relief Valves (S/RVs), requires twelve of the thirteen S/RVs to be operable for S/RV system operability. The three MSRVs were found to have been inoperable for an indeterminate period of time during the entire operating cycle between March 29, 2017, and March 2, 2019, and longer than permitted by TS 3.4.3. 
Previously, on April 27, 2018, MSRV BFN-2-PCV-001-0041 had been declared inoperable due to excessive leakage. It was removed and replaced during a midcycle outage in May 2018. Subsequent testing by NWS Technologies identified the as-found lift setting was outside the required +/- 3 percent band. At the time, BFN-2-PCV-001-0041 was the only known inoperable MSRV and the requirement of TS 3.4.3 (twelve of the thirteen S/RVs operable) was considered to be met.
Throughout this event, the two-stage MSRV pilot valves remained capable of maintaining the reactor pressure below 1375 pounds per square inch gauge (psig), which is the American Society of Mechanical Engineers (ASME) code limit of 110 percent of the vessel design pressure. The valves remained capable of performing their required safety function.
 
The TVA is submitting this report in accordance with Title 10 of the Code of Federal Regulations 50.73(a)(2)(i)(B), as any operation or condition which was prohibited by the plant's TS.
B. Status of structures, components, or systems that were inoperable at the start of the event and that contributed to the event
There were no structures, systems, or components (SSCs) whose inoperability contributed to this event.

NARRATIVE
 
C. Dates and approximate times of occurrences
Dates March 29, 2017
April 27, 2018
May 7, 2018
May 10, 2019
March 2, 2019
May 29, 2019
 
Occurrence Unit 2 entered Mode 2 at beginning of cycle 20 (U2C20) 
BFN-2-PCV-001 -0041 declared inoperable due to excessive leakage  
Unit 2 entered Mode 4 for the replacement of BFN-2-PCV-001 -0041 
Unit 2 entered Mode 2 following the replacement of BFN-2-PCV-001 -0041 
Unit 2 entered Mode 4 for U2R20 
NWS Technologies notified the TVA with as-found testing results of the thirteen Unit 2 MSRV pilot valves removed during U2R20 

D. Manufacturer and model number of each component that failed during the event
The failed components were all Target Rock Corporation two-stage pressure control valves, model number 7567F.
 
E. Other systems or secondary functions affected
No other systems or secondary functions were affected by this event.
 
F. Method of discovery of each component or system failure or procedural error 
Failure of MSRVs BFN-2-PCV-001-0004, BFN-2-PCV-001 -0018, and BFN-2-PCV-001-0019 was discovered at NWS Technologies during their as-found testing of the thirteen MSRV two-stage pilot valves which were removed during U2R20. Failure of MSRV BFN-2-PCV-001-0041 was discovered based upon leakage estimates during plant operation and subsequent testing by NWS Technologies. 
G. The failure mode, mechanism, and effect of each failed component  
MSRVs BFN-2-PCV-001 -0004, BFN-2-PCV-001-0018, and BFN-2-PCV-001-0019 failed due to corrosion bonding to the valve seats as a result of the platinum anti-corrosion coatings flaking off. Two additional test lifts on each valve were within the acceptance criteria of +/- 3 percent of the required setpoint, indicating corrosion bonding caused each pilot valve to initially lift high.

NARRATIVE
 
2019 - 002
Failure of MSRV BFN-2-PCV-001-0041 was caused by a delamination of a portion of the platinum anti-corrosion coating which lead to the leak.
 
These guys crossed their quality and QA regulations. This platinum coating should have been proofed in a test stand with the same environment and duration as the SRVs in the reactor with a generous margin of safety.  The guys are doing unapproved experiments in a reactor.  
H. Operator actioans  
There were no operator actions associated with this event.
I. Automatically and manually initiated safety system responses
 
There were no automatic or manual safety system responses associated with this event. 
Ill. Cause of the event 
A. Cause of each component or system failure or personnel error  
MSRVs BFN-2-PCV-001-0004, BFN-2-PCV-001 -0018, and BFN-2-PCV-001 -0019 failed above their setpoint band due to valve disc corrosion bonding to the valve seat as a result of the platinum anti-corrosion coating flaking off. In the case of MSRV BFN-2-PCV-001-0041, the loss of the platinum anti-corrosion coating led to leakage which affected its lift setpoint. 
B. Cause(s) and circumstances for each human performance related root cause 
No human performance related root causes were identified. 
IV. Analysis of the event 
BFN Unit 2 TS Limiting Condition for Operation (LCO) 3.4.3 requires twelve Operable S/RVs during Modes 1, 2, and 3. If one or more required S/RVs become inoperable, Required Action A. 1 requires entering Mode 3 within 12 hours and Required Action A.2 requires entering Mode 4 within 36 hours. S/RV Operability requires that S/RVs be within a +/- 3 percent band of their setpoint values in accordance with Surveillance Requirement (SR) 3.4.3.1. BFN Unit 2 has thirteen MSRVs to satisfy this requirement with margin.
When tested, the following four S/RVs were outside the allowable+/- 3 percent band.
 
S/RV Number Set~oint Test Result Difference BFN-2-PCV-001-0004 1155 1215 +5.2% BFN-2-PCV-001-0018 1145 1197 +4.5% BFN-2-PCV-001-0019 1135 1214 +7.0% BFN-2-PCV-001-0041 1155 1230 +6.5%
00

NARRATIVE
 
Prior to startup from U2R20, all thirteen MSRV pilot valves were replaced with refurbished valves which were certified to lift within +/- 1 percent of their setpoint. Operating Experience has shown that Target Rock two-stage MSRV setpoint drift is not a uniform, linear process. The corrosion bonding increases at a random rate. Without an accurate and reliable model for predicting or estimating the setpoint drift development, the point in time where the setpoint exceeded the +/- 3 percent limit cannot be reliably determined. Since this drift occurred during the operating cycle when the MSRVs were installed, MSRVs BFN-2-PCV-001-0004, BFN-2-PCV-001 -0018, and BFN-2-PCV-001-0019 are conservatively considered to be inoperable for an indeterminate period of time between March 29, 2017, and March 2, 2019. MSRV BFN-2-PCV-001 -0041 was considered to be inoperable from April 27, 2018 until entering Mode 4 on May 7, 2018, for replacement. More than one MSRV was considered to be inoperable during the entire operating cycle and longer than permitted by TS 3.4.3. 
TS LCO 3.0.4 states that when an LCO is not met, entry into a Mode or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Because Unit 2 made Mode changes from a mid-cycle on May 10, 2018, while TS 3.4.3 was not met, Unit 2 was in violation of TS 3.0.4. 
V. Assessment of Safety Consequences 
System availability was not impacted by this event. The failure of the MSRV pilot valves to meet their TS 3.4.3 specified mechanical setpoints does not impact their remote-manual operation or activation through the MSRV Automatic Actuation Logic, since these operating modes and functions rely upon electrically signaled control air solenoids to open the MSRV pilot valves. 
The bounding maximum over-pressurization analyses are performed each fuel cycle to show that the requirements of the ASME code regarding overpressure protection are met. The analyses are performed specifically to show that the dome pressure TS limit of 1325 psig is not exceeded and that the vessel pressure does not exceed the limit of 1375 psig. In addition, the Anticipated Transient Without Scram (A TWS) pressurization analyses are also performed to demonstrate that the 1500 psig peak vessel pressure limit is not exceeded. 
For the ASME analysis, the existing analysis setpoint groupings conservatively bound the eleven lowest as-found MSRV opening setpoints; however, the highest as-found valve opening setpoint falls outside the bounds of the existing analysis valve groupings. Therefore, the limiting ASME overpressurization event, identified as the ASME with main steam isolation valve closure at 102 percent rated power/ 105 percent rated flow at coastdown, was re-analyzed based on the as-found lift settings. The re-analysis determined a maximum dome pressure of 1272 psig and maximum vessel pressure of 1305 psig, which are within the ASME limits.
For the A TWS analysis, the existing analysis valve setpoint groupings conservatively bound the eight lowest as-found MSRV opening setpoints; however, the four highest valve setpoints fall outside the existing analysis valve groupings. Therefore, the limiting A TWS overpressurization event, identified as the A TWS pressure regulator failed open at 100 percent rated power I 81 percent rated flow at beginning of cycle, was re-analyzed based on the as-found lift settings. The re-analysis determined a maximum vessel pressure of 1414 psig, which is within the ATWS limit.
TS Bases 3.4.3 states that the overpressure protection system must accommodate the most severe pressurization transient. The MSRVs remained capable of maintaining the reactor pressure below 1375 psig, which is the ASME code limit (110 percent of the vessel design pressure). The valves remained capable of performing their required safety function. Therefore, as defined in NEI 99-02, failure of the MSRV pilot valves was not a safety system functional failure.
 
Based on the above, the TVA has concluded that sufficient systems were available to provide the required safety functions needed to protect the health and safety of the public...