Valve Test Failures Result in a
Condition Prohibited by Technical Specifications and a Loss of Safety Function
PLANT
STATUS
Cooper Nuclear Station (CNS) was
in Mode 1, Power Operation, at 100 percent power, when the event was
discovered; i.e., January 26, 2015.
BACKGROUND
The pressure relief system
includes three American Society of Mechanical Engineers code safety valves (SV)
[EllS: SB] and eight safety relief valves (SRV) [EllS: RV], all of which are
located on the main steam lines [EIlS: SB] within the drywell [EllS: NH],
between the reactor vessel [EllS: RPV] and the first main steam isolation valve
[EllS: ISV]. The SVs provide
protection against over pressurization of the nuclear system and discharge
directly into the interior space of the drywell. The SRVs discharge to the suppression
pool and provide three main functions: overpressure relief operation to limit
the pressure rise and prevent safety valve opening, overpressure safety operation
to prevent nuclear system over pressurization, and depressurization operation
(opened automatically or manually) as part of the emergency core cooling system
[EllS: B J, BM, BO].
Technical Specification (TS)
Limiting Condition for Operation 3.4.3 requires the safety function of seven SRVs
and three SVs to be operable. The nominal set pressure and tolerances for these
valves are established in CNS TS Surveillance Requirements (SR) 3.4.3.1.
The SRVs installed at CNS are
Target Rock Model 7567F, two-stage, pilot-actuated valves with pilot assemblies
comprised of Stellite 21 pilot discs and Stellite 6B pilot body seats. The
pilot assemblies had been in continuous service since installation in Refueling
Outage (RE) 27.
Corrosion bonding occurs when
the protective oxide layers of the seat and disc break down and allow a crevice
corrosion process to develop between the seat and disc. The seat is machined
and then lapped with the disc to create a tight fit with one another. During
the material removal process (machining) on both the seat and disc, the
protective oxide layer that provides corrosion protection is removed. Because
the SRV pilot valves are then assembled, the oxide layer is not given sufficient
time to reestablish itself naturally, and no external process, such as
pickling, is done to ensure that the oxide layer is reestablished to its full
extent without any breaks or discontinuities. When the SRV pilot valves are
assembled, the seat and disc are jammed together and air cannot reach the
surfaces, therefore the full benefits of the oxide layer of the anti-corrosion
material is diminished.
EVENT
DESCRIPTION
On January 26 and February 11,
2015, three complete SRVs and five SRV pilot assemblies, removed during
RE28 in the Fall of 2014, were as-found tested at National Technical Systems
Laboratories, formerly Wyle Laboratories.
The pressure setpoint for SRV
pilot assembly serial number 385 is 1090 psig. The TS SR 3.4.3.1 as-found limit
of acceptance is 1090 +/- 3%. The first actual lift pressure of this SRV
pilot assembly was recorded as 1124 psig, 3.119% above the pressure setpoint.
For informational purposes, the technicians performed a second and third lift.
The results were 1087 psig and 1087 psig, both within 3% of the pressure
setpoint.
The pressure setpoint for SRV
pilot assembly serial number 386 is 1100 psig. The TS SR 3.4.3.1 as-found limit
of acceptance is 1100 +/- 3%. The first actual lift pressure of SRV number
386 was 1192 psig, 8.36% above the pressure setpoint. A second and third lift
was performed and the results were 1108 psig and 1112 psig, both within 3% of
the pressure setpoint.
The pressure setpoint for SRV
pilot assembly serial number 1242 is 1090 psig. The TS SR 3.4.3.1 as found limit
of acceptance is 1090 +/- 3%. The first actual lift pressure of this SRV
pilot assembly was recorded as 1267.7 psig, 16.24% above the pressure setpoint.
The results of a second and third lift were 1091 psig and 1090 psig, both
meeting the pressure setpoint.
After this failure, testing was
halted in order to verify testing accuracy. Testing was found to be the same as
used in years past, and testing resumed on February 10 and February 11 for the
remaining five SRVs.
The TS SR 3.4.3.1 as-found limit
of acceptance for SRV pilot assembly serial number 1243 is 1100 psig +/- 3%.
The first actual lift pressure of this SRV pilot assembly was recorded as 1139
psig, 3.545% above the pressure point. For informational purposes, a
second and third lift was performed. The results were 1112psig and 1105 psig,
both meeting the pressure setpoint.
SRV pilot assembly serial number
1241 was tested. The TS SR 3.4.3.1 as-found limit of acceptance is 1090 psig +/-
3%. The first actual lift pressure of this SRV pilot assembly was recorded
as 1138 psig, 4.404% above the pressure point. A second and third lift was
performed. The results were 1106 and 1092 psig, both meeting the pressure
setpoint.
BASIS
FOR REPORT
CNS is reporting this event as
an operation or condition prohibited by plant TS per 10 CFR
50.73(a)(2)(i)(B), and also as a
condition that could have prevented the fulfillment of the safety function of structures
or systems as defined under 10 CFR 50.73(a)(2)(v).
An existing engineering analysis
demonstrated that the reactor vessel would not be challenged during an overpressure
event. In addition, a new analysis determined that the existing Minimum
Critical Power Ratio (MCPR) operating limit would have protected the MCPR
safety limit in the event of an anticipated operational occurrence. As such,
this event will not be counted as a Safety System Functional Failure for the
Nuclear Regulatory Commission performance indicator since no loss of safety
function occurred.
SAFETY
SIGNIFICANCE
Although the TS related to the
set point lift pressures of the SRV pilot valve assemblies were exceeded, an analysis
of this event indicates that the design basis pressures to ensure safety of the
reactor vessel and its pressure related appurtenances would not be challenged.
Public safety was not at risk. Safety to plant personnel and plant equipment
were not at risk.
CAUSE
The direct cause of five of
eight SRV pilot valves failing their lift tests is corrosion bonding.
CORRECTIVE ACTIONS
The following corrective actions
have been entered into CNS' corrective action program:
1. CNS shall inspect the SRVs
during disassembly to ensure there are no indications of binding, vibration, or
other mechanical problems that might cause effects similar to that of corrosion
bonding.
2. Laboratory work, under the
direction of CNS, shall be undertaken to confirm or deny corrosion bonding of
the disc and seats as needed. A comparison with previous laboratory findings
about SRV pilot valves will be performed to determine, if possible, the role
time in-service played in the failures.
3. Based on the results of the
inspection and laboratory work, specific findings and corrective action recommendations
in the form of a revised root cause investigation report will be completed.
4. If no evidence to refute
corrosion bonding is identified, ensure after machining and lapping processes
have been completed, that the oxide, passive layer on the seat and disc are
fully restored by pickling or an equivalent process.
5. Presuming that no technical
reason is discovered to prevent the following, submit to the Nuclear Regulatory
Commission a Technical Specification change that requests setpoint changes as
noted in EE 10-053; NEDC-33 543P, Revision 0, Class Ill, DRF 0000-0103-4647,
dated February 2010; GE-H NEDC-3362OP, Revision 0, May 2011; and GE-H, report
002N5242-R0, entitled, Cooper Cycle 28 SRV Set Point Study.
PREVIOUS
EVENTS
Licensee Event Report (LER)
2011-005-00 - On June 22, 2011, one of eight Target Rock SRV pilot valve
assemblies failed to lift within TS lift setpoint requirements. Wyle Laboratories
performed this testing. The pressure setpoint of the failed pilot assembly was
1090 +/- 32.7 psig; it lifted at 1199 psig. Two subsequent informational
lifts were performed for the SRV pilot assembly and were within the TS pressure
setpoint tolerances. The mechanistic cause was the same as reported in previous
LERs, pilot disc-to-seat corrosion bonding.
LER 2010-001-00 - On January
12, 2010, two of eight Target Rock SRV pilot valve assemblies failed to lift within
TS lift setpoint requirements. Wyle Laboratories performed this testing. The
pressure setpoint for the first pilot assembly is 1100 +1- 33.0 psig;
the SRV pilot assembly lifted at 1166 psig. The pressure setpoint for the
second pilot assembly is 1090 +1- 32.7 psig; it lifted at 1139 psig. Two
subsequent informational lifts were performed for both SRV pilot assemblies and
were within the TS pressure setpoint tolerances. The mechanistic cause was the
same as reported in previous LERs, pilot disc-to-seat corrosion bounding.
LER 2008-002-00 - On July 7
through July 9, 2008, the results of Target Rock SRV test data performed at Wyle
Laboratories identified that one of eight SRV pilot assemblies failed as-found
pressure setpoint testing. The SRV pilot assembly lifted at 1165 psig, outside
its TS setpoint tolerance of 1100 +/- 33.0 psig. The mechanistic cause
was pilot disc-to-seat corrosion bounding between the Stellite 21 pilot disc
and Stellite 6B pilot body seat to cause the SRV pilot assembly to lift outside
its TS setpoint tolerance.
LER 2007-002-00 - On February 28
through March 2, 2007, the results of Target Rock SRV tests performed at Wyle Laboratories
identified that one of eight SRV pilot valve assemblies failed to lift within
its TS lift setpoint of 1090 +/- 32.7 psig. The failure was a result of
sufficient corrosion bonding between the SRV pilot valve assembly Stellite 21
disc and the pilot valve Stellite 6B body seat to cause the SRV pilot valve to
lift outside its TS setpoint tolerance.