What Is More Valuable with SRVs: Manual Remote or Auto Operation Of The Valve

These guys just were never following the rules based on profits. There are two attributes here. Is it safe? Does not following the rules lead to wider culture safety problems. The Safety Relief valves here has another unstated and regulated function. Basically a melt down at Fukushima informs us (so far) in a full scale meltdown they never challenged the integrity of the pipes and vessel. I contend the primary function of the SRVs is a tool to the operators to prevent or mitigate a meltdown independent of the bursting the vessel or pipes. A meltdown is just marginally less worst than a burst of a pipe or vessel. My version of this would make the operator functioning of the valves (opening and shutting the manually the valves to control a accident) more important than the fear of bursting a large pipe or the vessel.

But there is absolutely no doubt the genesis of this BWROG is the work I had done on the SRVs.

The bitch I got is outsiders never get credit for pushing the industry and the NRC in the safe direction and getting results. Like a thank you letter in the docket. 

Remember inaccurate or out of spec pressure testing inaccuracy is highly related to leaking SRV and damage to the manual operation of the valve.     

TSTF
1
TSTF‐576 “Revise Safety/Relief Valve  Requirements” Presubmittal Meeting September 12, 2019
Ryan Joyce, Southern Nuclear, BWROG Licensing  Committee Chairman Brian Mann, Excel Services
Technical Specifications Task Force A Joint Owners Group Activity TSTF Background •The Safety/Relief Valve (S/RV) LCO requires eachS/RV to be operable.  The associated Surveillance Requirement (SR) requires that each valve  opens within the specified tolerance around the lift setpoint. •The need for TSTF‐576 was highlighted by many LERs describing failure  to meet the S/RV SR, even though the safety function (to prevent  vessel over‐pressurization) would still have been performed. –This indicated that the S/RV LCO is not consistent with 10 CFR  50.36(c)(2), “the lowest functional capability or performance levels  of equipment required for safe operation of the facility.” –The SR is not consistent with 10 CFR 50.36(c)(3), to verify that  “facility operation will be within safety limits, and that the limiting  conditions for operation will be met.” •As a separate action, the BWROG continues to pursue improvements  to the S/RVs to address the underlying cause of the test failures.
2
Technical Specifications Task Force A Joint Owners Group Activity TSTF Background •The safety function of the S/RVs is to collectivelyensure that  the reactor steam dome pressure doesn’t exceed the value in  Safety Limit (SL) 2.1.2, “Reactor Coolant System Pressure SL.” –The SL is based on not exceeding the ASME Boiler and  Pressure Vessel Code, Section III limit of 110% of the  design pressure. •The S/RVs collectively are typically able to perform the safety  function, even if individual S/RVs may open above or below  the setpoint.
3
Technical Specifications Task Force A Joint Owners Group Activity TSTF Background •The TS contain multiple specifications that govern the S/RVs  depending on the function they are fulfilling.   –BWR/4 STS 3.4.3 and BWR/6 STS 3.4.4, both titled,  “Safety/Relief Valves,” which requires the S/RVs in safety  mode and, for BWR/6 plants, relief mode. •This TS is the subject of the traveler. –STS 3.5.1, "ECCS ‐Operating," that requires a subset of the  S/RVs to actuate in ADS mode  –STS 3.6.1.6, "Low‐Low Set (LLS) Valves," that requires a  subset of the  S/RVs to actuate in LLS mode.   •STS 3.5.1 and 3.6.1.6 are not affected by the traveler.
4
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed LCO Changes •The BWR/4 STS 3.4.3 LCO is changed from: –The safety function of [11] S/RVs shall be OPERABLE. •To: –The safety mode of the S/RVs shall be OPERABLE. •The safety mode is the capability of the S/RVs to mechanically  open to relieve excess pressure when the lift setpoint is  exceeded.
5
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed LCO Changes •The BWR/6 STS 3.4.4 LCO is changed from: –The safety function of [seven] S/RVs shall be OPERABLE. AND The relief function of [seven] additional S/RVs shall be OPERABLE. •To: The safety mode of the S/RVs shall be OPERABLE. AND The relief mode of [seven] additional S/RVs shall be OPERABLE. •In the relief mode, the S/RVs are opened by switches located in the  control room or by pressure‐sensing instrumentation.
6
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed LCO Changes •The proposed change revises the LCO to no longer specify the  number of safety mode S/RVs required to be operable, but to  instead require the safety function to be operable, which is tied to  the Safety Limit. •In the BWR/6 design, as well as two non‐BWR/6 plants (Dresden  and Quad Cities), the licensing basis permits limited credit for S/RVs  in the relief mode to protect the ASME overpressure limit.  –That LCO requirement is not changed. •The terms “safety function” and “relief function” are replaced with  “safety mode” and “relief mode” for consistency.    –Both terms are used in the Bases. –The term "safety function" could be easily confused with the  term "specified safety function" used in the definition of  operability. 7
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed SR Changes •The existing SR specifies the number of S/RVs at each setpoint and  the as‐found tolerance, the as‐left tolerance, and any allowances: SR  3.4.3.1---------------------NOTE------------------------[2] [required] S/RVs may be changed to a lower setpoint group. --------------------------------------------------Verify the safety function lift setpoints of the [required] S/RVs are as follows: Number ofSetpoint S/RVs(psig) [4][1090 ±32.7] [4][1100 ±33.0] [3][1110 ±33.3] Following testing, lift settings shall be within ±1%. •The proposed SR states: –Verify the safety mode of the S/RVs will prevent reactor steam dome pressure from exceeding Safety Limit 2.1.2.
8
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed SR Changes •The ASME Code (required to be met by 10 CFR 50.55a(f)) continues  to require as‐found testing of each S/RV to licensee‐controlled  setpoints and tolerances. •The results of the ASME testing will be used to verify the SR: –If all S/RVs lift within the as‐found tolerance, the proposed SR is  met. –If one or more S/RVs fail to lift within the as‐found tolerance, an  analysis is performed to determine if the S/RVs, collectively,  would protect the Safety Limit and accident analyses, using  NRC‐approved methods. •This type of analysis‐based SR is used in other TS, such as, “Verify  each [control room AC] subsystem has the capability to remove the  assumed heat load,” which is performed by means of a combination  of testing and calculation.9
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed SR Changes •For the BWR/6 plants (as well as Dresden and Quad Cities), the  relief mode SR is not changed. •The existing SR that verifies that each required S/RV opens when  manually actuated is deleted. –Manual actuation is not required to verify the S/RVs can  mechanically open to  relieve excess pressure when the lift  setpoint is exceeded. Inability to be manually actuated should  not render the LCO not met. –The BWR/6 relief mode is not manually actuated. –ADS and LLS TS contains a similar test as SR 3.5.1.12 and  SR 3.6.1.6.1, which are not being revised.
10
Technical Specifications Task Force A Joint Owners Group Activity TSTF Proposed Action Changes •Given that the LCO requires the safety function to be operable, the  existing Actions are replaced with a single Action that applies when  the requirements of the LCO are not met. –Requires being in Mode 3 in 12 hours and Mode 4 in 36 hours. •While the BWR/6 STS has several actions applicable to inoperable  S/RVs, the TS for the four BWR/6 plants (River Bend, Grand Gulf,  Perry, and Clinton) contains a single action for one or more required  S/RVs inoperable, that requires being in Mode 3 in 12 hours and in  Mode 4 in 36 hours.   That Action is adopted in the BWR/6 STS.
11
Technical Specifications Task Force A Joint Owners Group Activity TSTF Conclusion •TSTF‐576 revises the Safety/Relief Valve specification to  reflect the plant design and accident analysis, and to be  consistent with the requirements of 10 CFR 50.36. –S/RV requirements pertaining to ADS and LLS are  unchanged.
12
Technical Specifications Task Force A Joint Owners Group Activity TSTF TSTF‐576 Review •TSTF‐576 is a management priority for the BWR fleet and the  NRC. •The TSTF intends to request an 18‐month review of  TSTF‐576 and to request licensee adoption under the CLIIP

Mike Mulligan, Pilgrim decommissioning, NRC, Ma AG Healey: Truncated Adams Searches, erratic legal E-filing and Dead NRC OIG E-filing complaint system

What do you think, my timing of this is suspicious? 

Healey sues NRC over Pilgrim license transfer
By Colin A. Young / State House News Service

FridayPosted Sep 27, 2019 at 1:33 PM

BOSTON - Attorney General Maura Healey is suing the Nuclear Regulatory Commission over its recent approval of the transfer of the Pilgrim Nuclear Power Station license.

The attorney general lodged the suit Wednesday in the U.S. Court of Appeals for the District of Columbia Circuit over the NRC’s decision last month to approve the transfer of Pilgrim’s license from Entergy to Holtec International.

Healey, Gov. Charlie Baker’s energy and environment secretariat and members of the state’s Congressional delegation mounted an effort to block the transfer unless the NRC held a full hearing on concerns over Holtec’s ability to safely decommission the nuclear plant, the company’s financial stability and its alleged involvement in a kickback scheme. No hearing was held before the NRC approved the transfer.

“The NRC has repeatedly rubber stamped Holtec’s plans, despite serious concerns about the company’s financial capacity, technical qualifications, and competency to safely decommission and clean up the Pilgrim site,” Healey said in a statement. “We are asking the Court to exercise its authority to vacate the NRC’s misguided and unsupported actions.”

The NRC declined to comment on Healey’s lawsuit. When the agency issued its order approving the license transfer, it refuted some of Healey’s arguments.

***Dear NRC Chairwomen Svinicki, 

I have gotten word the degraded operation(truncated searches)with the NRC Adams (public portal for all NRC documents) are related to the late e-filing by Attorney General Maura Healey surrounding Pilgrim's decommissioning. The e-filing system was degraded similar to Adams or components supporting the e-filing system and the NRC knew the e-filing system was degraded for months. The NRC intentionally lied to the Massachusetts Attorney General in a official decommissioning process or legal proceeding. Worst case, Holtec license could have been rescinded and another contractor could have replaced Holtec. I have talked extensively to AG Healey about this.

I request a independent comprehensive and historical investigation on the degraded e filing system and the NRC response to the late e-filing to Ma AG Healey?

I would asked did the NRC shutdown the e filing to do maintenance while you were submitting your legal document to do maintenance (when AG Healey was using the system)? Was it negligent the NRC employees or contractors didn't verify if somebody was on the e system or using it. 

Heavens help us all if NRC had a employee waiting in standby to sabotage Healey submittance??

This all began in the PDA department with Adams's truncated and inaccurate searches. You staff treated me in a unprofessional manner. I suspected a coverup with insufficient IT infrastructure or maintenance. Maybe not enough IT people or proper training to keep the system reliable. Check out my email stream to the PDR department? 

Ultimately unreliable Adams effected everyone who used Adams for months and obstructed and disrupted public participation!

Unbelievable! I can't believe this could get worst. It just did!  Your NRC IT system is on fire with unreliability. ON Sept 14,2019 at around 8:55am I attemped to submit a simular complaint to the NRC's OIG "on line" e-complaint form. The NRC OIG wouldn't accept my complaint and reject it. The below techical gibberish words is the message I recieved. Can you explain it? Could you please pass on my complaint to the OIG. Somebody needs to explain why this happened. I am terrified when I send this to you by normal e-mail my complaint it is going to get rejected by the NRC. I am going to need from you a verification message that my complaint was recieved by the NRC OIG because you system has become so unreliable.

"Access Denied

You don't have permission to access "http://www.nrc.gov/HTBIN/nrc_mail" on this server.

Reference #18.760f6168.1568465523.c4b1174"  

I am going to need a investigation from you on the below: 

1) The truncated document searches in Adams 

2) The erratic operation of the e-filing system with Ma AG Healey leading to a late filing on decommissioning.

3) The dead NRC OIG e-filing complaint form that occurred to me this morning.

                  

I never have any confidentiality or anonymity needs what so ever. 

Mike Mulligan

Hinsdale NH 

16032094206

Ma AG Healey Over Pilgrim's Decommissioning: The E-filing System Was Degraded or Erratic for Months Prior TO The Filing

I have gotten word the degraded operation(truncated searches)with the NRC Adams (public portal for all NRC documents) are related to the late e-filing by Attorney General Maura Healey surrounding Pilgrim's decommissioning. The e filing system was degraded similar to Adams or components supporting the e-filing system and the NRC knew the e-filing system was degraded for months. The NRC intentionally lied to the Massachusetts Attorney General in a official decommissioning process or legal proceeding. Worst case, Holtec license could have been rescinded and another contractor could have replaced Holtec. I have talked extensively to AG Healey about this.

I request a independent comprehensive and historical investigation on the degraded e filing system and the NRC response to the late e-filing to Ma AG Healey?

I would asked did the NRC shutdown the e filing to do maintenance while you were submitting your legal document to do maintenance (when AG Healey was using the system)? Was it negligent the NRC employees or contractors didn't verify if somebody was on the e system or using it. 

Heavens help us all if NRC had a employee waiting in standby to sabotage Healey submittance??      

Mike Mulligan

Hinsdale NH 

16032094206

Our Goverment Shouldn't Be Subsidizing Nuclear Plant Fuel?

It seems the free and competitive market is a thing of the past. 

Exelon’s Byron 2 Completes First Insertion of Westinghouse Accident-Tolerant Fuel

Exelon’s Byron Unit 2 nuclear power plant has completed installation of EnCore Fuel, Westinghouse Electric Co.’s accident-tolerant fuel (ATF) solution, marking the start of the first test of uranium silicide fuel pellets in a commercial nuclear reactor.

The installation, completed during the plant’s scheduled 18-day spring refueling outage this April, but publicly announced on Sept. 5, marks a major milestone for Westinghouse’s development of the new fuel, which is part of the Department of Energy’s (DOE) Accident Tolerant Fuel Program, an industry-led effort to deliver the new family of robust fuels to market by 2026.

ATF is an industry concept used to describe new technologies—in the form of new cladding and/or fuel pellet designs—that further enhance the safety and performance of nuclear materials. While ATF technologies have been under development since the early 2000s, they have received a marked boost in the wake of the Fukushima accident in March 2011 as the DOE aggressively implemented plans under its congressionally mandated EATF program to develop ATFs for existing light water reactors. The program today casts a wide net of collaboration that includes several U.S. utilities, universities, and the Electric Power Research Institute, and under it, two vendors have already installed ATF concepts at two U.S. reactors.

A First for Uranium Silicide Pellets

The Byron 2 installation involved insertion of two lead test assemblies that contain chromium-coated zirconium cladding for enhanced oxidation and corrosion resistance, higher density ADOPT pellets—which is a chromia (Cr2O3) and alumina (Al2O3) doped UO2 pellet—for improved fuel economics, and uranium silicide pellets, Westinghouse said on Sept. 5.

According to Westinghouse, EnCore Fuel has the “game-changing” potential to significantly increase public safety through revolutionary new materials, while at the same time improving the economics of plant operation through longer fuel cycles and enhanced flexible power operation capability.

Westinghouse’s, which is seeking a grant totaling more than $93 million from the DOE to develop EnCore Fuel, plans to deploy the new fuel to market in two phases...

Prairie Island Steam Generator Comes from Saint Marcel and Might Be Defective

https://www.reuters.com/article/us-edf-safety/frances-asn-boss-says-at-lest-five-edf-nuclear-reactors-affected-by-anomalies-figaro-idUSKCN1VX0N7

France flags welding fault at five or more EDF nuclear reactors 

PARIS (Reuters) - At least five nuclear reactors operated by French utility EDF might have problems with weldings on their steam generators, a fault which has raised fears of closures, France’s nuclear regulator was quoted as saying.

State-controlled EDF, whose shares were down 0.9% on Thursday, had said on Tuesday it had identified issues with weldings of some existing reactors, sparking a stock price fall of nearly 7%.

France has the world’s second-largest fleet of nuclear reactors behind the United States, but a spate of technical problems, coupled with hitches at reactors under construction, has tarnished EDF’s image as a leader in nuclear technology.

EDF has exported to China, Finland, South Africa and South Korea, with Britain also set to use its equipment.

“At least five nuclear reactors are affected by this problem,” Le Figaro newspaper quoted Bernard Doroszczuk, head of the ASN regulator, as saying.

“EDF has advised that in around a week it will give an exact number of facilities affected,” Doroszczuk added.

https://www.montelnews.com/en/story/at-least-5-french-reactors-affected-by-weld-issues--report/1042135

At least 5 French reactors affected by weld issues – report 

(Montel) At least five French nuclear reactors are affected by a welding fault in steam generators, the head of France’s ASN nuclear safety authority told French daily Le Figaro late on Wednesday.

"EDF has said it will give more details on the number of components concerned in a about week… so it’s not over,” said Bernard Doroszczuk.

The comments came after operator EDF said on Tuesday that “several” French reactors were affected by substandard welding on some of their steam generators and that it was investigating the matter.

20 generators
The ASN said on Tuesday that “potentially” 20 steam generators were concerned by the faulty welds manufactured by Framatome at its Saint Marcel factory in the south of France since 2008, adding it would release more information in “the coming days”.

An official at France’s IRSN, the technical arm of the ASN, told Montel EDF and Framatome were confident that inspections on steam generators would reveal they were safe.

Steam generators are key components that convert water into steam from heat produced in a reactor core. Each of France’s 58 reactors typically holds between two and four steam generators.

The latest welding problems comes amid concern about other substandard welding at EDF’s new-generation European pressurised reactor (EPR) being built in Flamanville. 

https://www.energy-reporters.com/industry/edf-admits-to-reactor-welding-issues-in-france/

EDF admits to reactor welding issues in France 

By Energy Reporters  | 12.09.2019  | Industry

The French state-run electricity provider EDF has admitted to possible weaknesses with components, including improper welding, used in reactors in France.

Shares slumped in EDF, which said Framatome, a company partially owned by EDF that supplies atomic equipment, had reported the issues.

The French Nuclear Safety Authority said around 20 reactors built after 2008 might be affected.

The authority reported that test results appeared to have been falsified and it had alerted prosecutors to possible fraud.

An EDF spokesman said it was too early to say if any of its 58 reactors would close. He said the safety authority had been informed this week.

He added that Framatome said it had not used the same welding technique in all of the reactors.

A factory making steam generators used in nuclear reactors had purportedly failed to follow standard procedures on the welds, EDF said.

The power giant said Framatome warned of “a deviation from technical standards governing the manufacture of nuclear-reactor components”.

“Post-Fukushima, safety rules are so stringent that unplanned halts are becoming more and more frequent,” said Tancrede Fulop, a Morningstar analyst. “That is undermining the nuclear case for a low-cost, base-load production of low-carbon electricity.”

The IAEA (International Atomic Energy Agency) said last year that 71.7 per cent of France’s electricity came from nuclear sources, the world’s highest proportion.

Framatome’s factory in Saint-Marcel, central France, supplies heavy equipment for the sector, providing components for 106 reactors around the world.

EDF said the problem concerned components already installed in reactors and items being prepared for future installation.

“EDF, along with Framatome, has been conducting in-depth investigations to identify all affected components and reactors, as well as to ascertain their fitness for service,” EDF announced.

In 2016 EDF checked almost a third of its nuclear reactors after finding manufacturing problems in components made by Framatome, then called Areva, at its factory in Creusot.

That forced longer-than-anticipated maintenance outages, reducing EDF’s output.

EDF has recently had to delay the launch a new-generation nuclear reactor. The Flamanville reactor in Normandy is now not due to begin operations until 2022, a decade behind schedule.

The utility is leading the controversial £19.6 billion project to build two similar reactors at Hinkley Point in Somerset on the southwestern English coast. They are due to begin operation in 2025.

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.