ML051450501

Condition Report CR-04-02514

ML051450501
Person / Time
Site:	Millstone
Issue date:	09/27/2004
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2005-0208 CR-04-02514
Download: ML051450501 (6)

Text

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_1 Millstone Condition Report CR-04-02514 TRENDING CR FOR MAIN STEAM SAFETY VALVE*

OPENING AF TER REACTOR TRIP AT MILLSTONE UNIT 2.

Document Notes INITIATOR:

MICHAEL MI.' EXT. 0215 INITIATOR REQUESTS POLLOWUP =: NO SIgnIficance: 2 Process: TRACKING CORRECTIVE ACTIONS Status: OPEN Dlscoverd: Wednesday. March 17.2004 CRED Req.: NO Initiatod: Wednesday. March 17. 2004 Reportable-No Screened: Wednesday, March 17,2004 Unit: 02 Processed by CA. Thursday, March 18, 2004 CR Owner MGONUCFUEL MANAGER NUCLEAR FUEL Document Notes

.-' CONDITION DESCRIPTION

ISSUE DESCRIPTION:

IT IS EXPECTED THAT THE STEAM DUMP SYSTEM WILL HAVE SUTFFICIENT CAPACITY MID RESPONSE TIME SUCH THAT FOR A ROUTINE REACTOR TRIP, THE MAIN STEAM SAFETY VALVES WOULD NOT OPEN.

CONTRARY TO THIS EXPECTATION, THE LAST THREE REACTOR TRIPS AT FULL POER FOR MILLSTONE UNIT 2 HAVE RESULTED IN MOMENTARY OPENING OF AT LEAST ONE MAIN STEAM SAFETY VALVE.

WHILE A NUMBER OF EVALUATIONS AND DESIGN CHANCES HAVE BEEN MADE TO REDUCE THE LIKELIHOOD OF SAFETY -VALVE-OPENINGr-THE-RECENT-TRIPS-HAVE-.DEMONSTRATED THAT FOR SOME SET OF CONDITIONS, SAFETY VALVE OPENING WILL STILL OCCUR.

AT THE REQUEST OF VAINAGEMETr.

THIS TRENDING CR IS 3EING WRITT-EN TO XNITIATF AN INTEGRATED EVALUATION OF THIS ISSUE TO DETERMINE IF ANY ADDITIONAL CORRECTIVE ACTIONS ARE APPROPRIATE.

THE INTECIRATED EVALUATION SHOULD INCLUDE A REVIEW OF DESIGN BASIS AND LICENSING BASIS REQUIREMENTS, OPERATING EXPERIENCE FROM OTHER CE NSSS PLANtS AND THE HP2 PAST HISTORY.

THE EVALUATION WILL DETERMINE IF THE OPENING OF THE MAIN STE.M SAFETY VALVES SHOULD BE EXPECTED IN THE PREVIOUS EVENTS AND DETERM2NE IF ANY ADDITIONAL CHANGES SHOULD BE INVESTIGATED.

IMMEDIATE ACTION(S)

TAKEN:

FOR EACH TRIP, THE OPERATORS TOOK THE APPROPRIATE ACTIONS TO ENSURE THE SAFETY OF THE PLANT. AN EVENT EVALUATION TEAM HAS BEEN FORMED TO EVALUATE THE PLANT RESPONSE AND DETEMYINE IF ANY CORRECTIVE ACTIONS ARE NEEDED.

NO OTHER IMIED$ATE ACTIONS ARE NEEDED.

RECOIMENDED ACTION(S):

NUCLEAR FUELS ENGINEERING SHOULD TATE THE LEAD FOR THE EVALUATION, WITH ASSISTANCE FROM SITE ENIGINEERING AND DESIGN ENGINEERING.

SCREENING -

DOES THE REPORTED ISSUE IMPACT:

PERSONNEL SAFETY :> NO PLANT SAFETY => NO SEE

• IMXCEDIATE ACTIONS TAXEN AND *SCREENER COXM(ENTS..

AVAILABILITY OF EQUIPMENT FOR PLANT OPERATIONS _> NO OPERXBILITY => No REPORTADILITY => NO REACTIVITY MANAGEMENT => NO ENVIRO1NENTAL CONTROLS.

ETC => NO PLANT OR EQUIPMENT RELIABILITY => YES SCREENER CO)MCENTS:

CONCUR WITH PRE SCREMTING -

CR FOR TRENDING ONLY CRED REQUIRED => NO COMPEJSATORY ACTIONS => NO ROOT CXUSE/EVENT REVIEW TEAM REQUIRED?

NO OPERATING EXPERIENCE => YES SIGNIFICANCE DETERIMINATION REQUIRED?

NO REWORK => NO CONDITION REVInEJ TEAK COMMENTS:

SDP.

?HRT?

INITIATING PROCESS ALERT GROUP:

YGrYUCFUEL Trend Issue 001 Category Attr DescriptIon WHATHAP CFMT CONFIGURATION MANAGEMENT DEGRADATION SELFIDENT YES CR WAS SELF IDENTIFIED BY THE PROCESS ITEAM SAFDEVPRECUR RVLF RELIEFVALVELIFT INPOPOC CM.3 DESIGN CHANGE PROCESS INITIALCODE ICNF CONFIGURATION CONTROL (PAPERWORK. DRAWING & DESIGN CONTROL)

HOWDISCOVR SELF SELF IDENTIFIED CATEGORY ENGR ENGINEERING ISSUES Trend Issue 002 Category Attr DescrIptIon RIESPDEPT EOCAUDES ENUC NUCLEAR ENGINEERING EQBX OTHER I I I-EQCAUCAT COMPTYPE CAUSECODES EQA RLFV 1304 ENGINEERING/DESIGN VALVE RELIEF ORIGINAL PROBLEM NOT RESOLVED BY DESIGN CHANGE DESIGN CONFIGURATION & ANALYSIS CAUSALFACTOR CF13 Notos THE ISSUE OF MSSV OPENING FOLLOWING ROUTINE REACTOR TRIPS WAS APPARENTLY CLOSED BASED UPON THE RISKS AND RESOURCES WEEDeD FOR TESTING.

THE SAFETY SIGNIFICANCE WAS BASED UPON THE IMPACT ON SGTR RATHER THAN THE POTENTIAL IMPACT ON MSSV RELIABILITY AND COVSEQUENTLY AM RELIABILITY.

Document References Ref Fac. Type Sub DocumontNo.

Sheet RevIsion Typo MP RPT ACR CR.Od-02543 CR ISSUED FOR TRENDING THE LIFTING OF SIG SAFETY V ALVES 2-MS-252 AND 2-MS.242 FOLLOWING U2 REACTOR T RIP ON 311 504 MP RPT ACR CR.04.02760 MANUAL REACTOR TRIPPING CAUSES SG SAFETY VALVES TO LUFT`

J CR System References Fac Unit Sys Loc Sys DoscrIption IMP NA NA NA NO SYSTEM REFERENCE

'Action Roquest: 04001714 Typo:

CAO (CONDITION ADVERSE TO QUALITY (SIGNIF LVL'S 1 & 2)).

Status:

APPROVED Status Date:

Thursday. March 18, 2004 8173 Due Dato:

Sunday. August 07, 2005 1)

Sublect:

CR-O040251 4 TRENDING CR FOR MAIN STEAM SAFETY VALVE OPENING Owed To:

MGRNUCFUEL (MANAGER NUCLEAR FUEL)

Description THIS

./R COORPNATES TSHE ACTIVITIES ASSOCXXTED WITH T5U SUnjECT CR.

t S..

SEP-28-2004 16:05 MILLSTONE 860 44-S t>.15 I. U 4

September27,2004 15 Millstone Condition Report CR-04-02514 Page Assignment:

04001714-01 Type:

Due Date:

Status:

Rasp. Group Organization Status Date:

Subject:

Schedule Ref:

Mode:

Affectod Unit:

Affectod System CATI (CR INVESTIGATION ASSIGNMENT)

Wednesday, April 07,2004 COMPLETE MGRNUCFUEL (MANAGER NUCLEAR FUEL) 85H Tuesday. April 06, 2004 CR-04-02514 LEAD: TRENDING CR FOR MAIN STEAM SAFETY VALVE OP NA NA (ASSIGN'MT IS NOT RELATED TO A PLANT MODE CHNG BWR PWRF) 02 NA (NO SYSTEM REFERENCE)

Assignmont Closure Notes INVESTIGATION COMPLETED 03/24/2004 INVESTGATOR M. XAS DEPARTME11T IGRNUCFUEL PROBLEM STATEMENT THE STEAM DUMP SYSTEM AND NORMAL OPERATING CONDITIONS HAVE NOT BEEN OPTIMIZED TO PREVENT OPEISNG MSSVS Ott ROUTINE REACTOR TRIPS AT MP2.

EVENT TREND OBSERVED OF OPENING MSSVS FOLLOWING KP2 REACTOR TRIPS ON 3/7/03. 3/6/04 MN 3/15/04.

INVESTIGATION THE MSSVS OlN MP2 HAVE OPENED FOLLOWING THE LAST THREE REACTOR TRIPS AT MP2.

DURING THE REACTOR TRIP ON 3/7/03, THE QUICX OPEN FEATURE OF THE STEAM DUMP SYSTEMS FAILED TO INITIATE.

WITH THIS TYPE OF FAILURE.

IT IS EXPECTED THAT THE MSSVS WOULD OPEN.

FOR REACTOR TRIPS ON 3/6/04 AND 3/15/04. THE QUICK OPEN FEATURE APPARENTLY OPERATED AS REQUIRED.

POWEVER, SAPETY VALVES WERE ACTUATED 0 THESE TRIPS AS WELL.

XS A RESULT OF THIS TREND.

MANAGEMENT HAS REQUESTED THE T£rFr-TqnTmj r v-mrsvws&t moyc SRNDm ik@n I

Assignment Attributes Resp.Individual: BE084CK MICHAELKAI Assignment Text CR-04-02514, SIGNIFICANCE LEVEL: 2 INITIATED BY:

MICHAEL KAI, PHONE:

0215 INITIATOR FEEDBACK REQUESTED:

NO i

i i I

_^-*ib-S S^-V;I-Wv__!H--

_s USE OF THE ELECTRONIC CR INVESTIGATION DATABASE IS REQUIRED TO COMPLETE THIS ASSIGNMENT.

-PROVIDE APPARENT CAUSE DETERMINATION AND PROVIDE A CORRECTIVE ACTION PLAN.

-INVESTIGATOR MUST BE TRAINED PER REQUIREMENTS OF D2IAP 1604.

-CRT REVIEW DETERMINED THIS EVENT/ISSUE MAY NEED TO BE COMX(UNICATED VIA OE.

SEE RELATED OE ASSIGNMENT.

CONDITION REVIEW TEAM COMMENTS:

SDP.

?MRT?

ISSUE DETAIL:

IT IS EXPECTED THAT THE STEAM DUMP SYSTEM WILL HAVE SUFFICIENT CAPACITY AND RESPONSE TIME SUCH THAT FOR A ROUTINE REACTOR TRIP.

THE MAIN STEAM SAFETY VALVES WOULD NOT OPEN.

CONTRARY TO THIS EXPECTATION.

THE LAST THREE REACTOR TRIPS AT FULL POWER FOR MILLSTONE UNIT 2 HAVE RESULTED IN MOMENTARY OPE25ING OF AT LEAST ONE MAIN STEAM SAFETY VALVE.

WHILE A NUMBER OF EVALUATIONS AND DESIGN CHANGES HAVE BEEN MADE TO REDUCE THE LIKELIHOOD OF SAFETY VALVE OPENING, THE RECENT TRIPS HAVE DEMONSTRATED THAT FOR SOME SET OP CONDITIONS, SAFETY VALVE OPENING WILL STILL OCCUR.

AT THE REQUEST OF MANAGEMENT.

THIS TRENDING CR IS BEING WRITTEN TO INITIATE AN INTEGRATED EVALUATION OF THIS ISSUE TO DETERMINE IF ANY ADDITIONAL CORRECTIVE ACTIONS ARE APPROPRIATE.

THE INTEGRATED EVALUATION SHOULD INCLUDE A REVIEW OF DESIGN BASIS AND LICENSING BASIS REOUIREMENTS, OPERATING E.IPERIENCE FROM. OTHER CE NSSS PLANTS AND THE MP2 PAST HISTORY.

THE EVALUATiON WILL DETEPWINE IF THE OPENING OF THE MAIN STEAM SAFETY VALVES SHOULD BE EXPECTED IN THE PREVIOUS EVENTS AND DETERMINE IF ANY ADDOTIONAL CHANCES SHOULD BE INVESTIGATED.

Assiqnment System References Fac Unit Sys Loc Sys Description MP NA NA NA NO SYSTEM REFERENCE Asltpnrent Clorura Notol CONDITION REPORT SUM1ARY, 04/06/2004 6:30:57 AM DETERMINE IF ADDITIONAL CORRECTIVE ACTIONS ARE WARRANTED.

IN KP2 FSAR SECTION 7.4.5.1.1. IT IS STATES:

.. THE STEAM DUMP TO CONDENSER; ST7EAM DUMP TO ATMOSPHERE, ANM BYPASS SYSTEMS COMBINED PROVIDE A MEANS OF DISSIPATING EXCESS NUCLEAR STEAM SUPPLY SYSTEM (NSSS)

STORED ENERGY AND SENSIBLE HEAT FOLLOWING A SIMJLTANEOUS REACTOR AND TURBINE TRIP FROM FULL-LOAD WITHOUT LIFTING THE SECONDARY SAFETY VALVES. "

THIS REQUIREMENT XS All ORIGINAL DESIGN REQUIREMEINT.

THIS REQUIREMENT WILL ASSURE THAT THE KSSV RELIABILITY WILL BE MAINTAINED AS DESIGNED.

AS DESCRIBED IN A 1976 REPORT, PROBLEMS WITH THE STEJM DUMP SYSTEM WERE ENCOUNTERED DURING THE INITIAL NOT FUNCTIONAL TESTING.

DURING PRE-CORE HOT FUNCTIONAL TESTING UNACCEPTABLE VALVE OSCILLATIONS WERE OBSERVED WHEN THE VALVES WERE USED FOR STrAM FLOw CONTROL.

DURING POST CORE HOT FUNCTIONAL TESTING, IT WAS NOTED THAT THE VALVES WOULD NOT OPEtl MORE THAN 60% UNDER LOAD.

HYDRAULIC DAMPENERS WERE INSTALLED TO SLOW DOWN THE OSCILLATIONS, BUT THE VALVES STILL ONLY OPENED TO eo%.

A MODIFICATION TO THE PLUGS WAS MADE TO TRY TO SOLVE THE CAPACITY PROBLEK BUT WAS UNSUCCESSFUL.

INSTALLXTION OF THE 2fYDRAULIC DAMPENERS APPARENTLY ALSO RESULTED IN EXTENDING THE QUICK OPENING TIME BEYOND 3 SECONDS CAUSING THE SAFETIES TO LISm DURING REACTOR TRIPS.

THIS WAS CONFPIMED BY TESTING.

PROJECTION ASSIGNMENT 76-618 WAS INITIATED TO CORRECT THE EXTENDED DELAY TIME.

COPES-VULCAN MODIFIED THE VALVES SO THAT THE QUICK OPENING WAS RESTORED TO LESS THANI 3 SECONDS.

THESE MODIFICATIONS INCLUDED INCREASING THE SIZE OF THE SOLENOID VALVE AND SUPPLY LINE TO THE AIR OPERATORS AND THE USE OP LESS STIFF SPRINGS.

COPES-VULCAN ALSO ADDED MORE RESTRICTIVE VALVE TRIMS TO OBTAIN BETTER FLOW CONTROL CAPABILITY TO THE CONDENSER.

THE CAPACITY ISSUE WAS ADDRESSED BY ADDING THE QUICK OPEN FEATURE TO THE ATMOSPHERIC DUIP VALVES (PA 79-2560).

I I

CR 4UMBER SIGNIFICANCE LEVEL

CR-04-02514

2

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Pages 3 Soptombor27.2004 15 Millstone Condition Report CR-04-02514

.1 Assignment Closure Notes THE WORX DONE IN 1976 APPEARS TO HAvE RESOLvEb THE QUICK OPENING RESPONSE TIME, BUT NOT THE CAPACITY ISSUE.

HOWEVER.

APPARENTLY THIS WAS SUFFICIENT TO SOLVE THE PROBLEM OF SAFETY VALVES OPENING FOLLOWING REACTOR TRIP.

WHEN MP2 IMPLEKENTED STRETCH POWER, THE ISSUE OF OPENING MSSVS POST TRIP RECURRED.

IN JUNE 1982, CE SUBMITTED A PROPOSAL TO PERFORM A STUDY TO DETERMINE THE OPTIMUX CONTROL SYSTEM CHANGES THAT WOULD ELIMINATE THE ACTUATION OF THE MSSVS FOLLOWZNG ROUTINE REACTOR TRIPS.

CE HAD PERFORMED A SIMILAR STUDY FOR THE IXPLEMENTATION OF STRETCH POWER AT ST. LUCIE 1.

A LOWER OPERATING SC PRESSURE WAS SELECTED THAT ELIMINATED THE POTENTIAL FOR MSSV ACTUATION FOLLOWING ROUTINE REACTOR TRIPS.

AS A RESULT Or THE PROPOSAL, PROJECT ASSIGNMENT 83-039 WAS INITIATED.

THE CE PROPOSAL CONSISTED OF THREE AssIgnmant Closure Notes NOT RESULT IN A MAJOR REDUCTIO1 IN THE DEGREE OF PROTECTION PROVIDED TO THE PUBLIC HEALTH AND SAFETY.

I `1i I n r t - s - - rtrc f l r - -. r - n. -

e -.,

ns r s I

COMPUTER CODE MODEL TO IDENTIFY ANY DEFICIENCIES OR CHANGESNEEDED IN THE _CONTROL SYSTEMS.

IF CHANGES IN THE SETPOINTS OF THE C0NTROL SYSTEMS WERE NOT-SUFFICIENT. A SECOND STUDY WOULD BE PERFORMED.TO DETERMINE THE OPTIMUM OPERATING CONDITIONS THAT WOULD PREVENT THE SAFETY VALVES FROM ACTUATING FOLLOWING REACTOR TRIP.

THIS STUDY IS THE ONE THAT RESULTED IN THE SELECTION OF THE LOt4ER OPERATING SG PRESSURE FOR ST. LUCIE.

THE THIRD PHASE WOULD INVESTIGATE MODIFICATIONS TO THE CONTROL SYSTEM TO ALLOW OPERATION AT A HIGHER STEAM GENERATOR PRESSURE.

INSTEAD OF CONTRACTING WITH CE. IT WAS DECIDED TO DO PHASE 1 IN-HOUSE.

THE SAFETY ANALYSIS SECTION USED RETRAN TO MODEL THE CURRENT SITUATION AND EVALUATE POTENTIAL CHANGES.

THE RETRAN ANALYSIS STARTING POINT ASSUMED THAT TWO SAFETY VALVES WERE LIFTING FOLLOWING THE REACTOR TRIP.

WITH THIS ASSUMPTION, VARIOUS OPTIONS rOR CONTROL SYSTEM CHANGES WERE EVALUATED.

BASED ON THE STUDY, IT WAS CONCLUDED THAT A SUBSTANTIAL CHANGE IN SECONDARY SIDE RELIEF RATE WAS NEEDED.

INCREASING THE ATMOSFHERIC DUMP VALVE CAPACITY WAS NOT A PRACTICAL SOLUTION.

AN ALTERNATIVE SOLUTION PROPOSED WAS TO DELAY TURBINE TRIP BY 3 OR 4 SECONDS.

APPARENTLY.

THE OPTION OF REDUCING SC PRESSURE WAS NOT EVALUATED.

IN 1984, IT WAS DECIDED TH)AT CONFIRMATIbN OF THE SAFETY VALVE LIFT ASSUMPTION IN THE RETRAN STUDY WAS NEEDED BEFORE PROCEEDING WITH ANY DESIGN CHANGES.

IT WAS DECIDED THAT A ONE YEAR PERIOD OF DATA COLLECTION WOULD BE ESTABLISHED.

IF AT THE E12JD OF THAT ONE YEAR PERIOD, THE DATA COLLECTED WAS NOT ADEQUATE TO CONFIRM THE MODELING, THE PROJECT WOULD BE CLOSED.

THE TESTING PLAN WAS MEVIESED AND APPROVED BY PORC.

THE PROJECT WAS CLOSED IN 1997 BASED UPON THE FOLLOING:

THE RISK AND COSTS ASSOCIATED WITH TESTING DID NOT JUSTIFY ADDITIONAL TESTING AND THE LIFTING OF SAFETY VALVES FOLLOWING A SGTR HAD BEE=

EVALUATED TO AS A RESULT.

IT APPEARS THAT THE RISK ASSOCIATED WITH ONE OR TWO SAFETY VALVES OPENING UPON REACTOR TRIP WAS ACCEPTED A!ID THE POTENTIAL DEGRADATION IN THE DUMP CAPACITY WAS ACCEPTED AS-IS.

SINCE THAT TIME. THERE HAVE BEEN RECURRING ISSUES RAISED ABOUT THE PERFOXL\\NCE OF THE STEAY DUMP VALVES AND THE DESIGN BASIS.

THE ISSUE OF THE DISCREPANCY OF THE DUMP CAPACITY WAS RAISED AS AN ISSUE DURING RECOVERY AND DOCUMENTED IN D2DP DISCREPANCY MP2-MS-09.

THE PROPOSED RESOLUTION WAS TO REVISE THE FSAR TO REFLECT A LOWER DESIGN CAPACITY.

THERE HAVE BEEN A NU4BER OF CRS ASSOCIATED WITH THE TtRBINE-DUMP-SYSTEM- -THE-OUICM-DPflLFIAT1RLJN 2002. KM(OD H2-99057 A SECOND SOLENOID VALVE IN PARALLEL WITH THE EXISTING SOLENOID VALVE WAS ADDED TO PROVIDE SUFrICIEINT AIR SUPPLY-TO'OPEN THE VALVES-IN LESS THAN THREE SECONDS. CR-03-11377 AND CR 03-114e2 DOCWMENT SURVEILLANCE FAILURES FOR THE QUICK OPEN RESPONSE TIME.

AS A RESULT OF SOER 02-4 RECOmMrENDATION 3 ISSUE 157. A REA WAS INITIATED FOR EVALUATION OF THE REPLACEMENT OF THE STEAM DUMP VALVES.

CR-03-11P04 WAS INITIATED TO RE-OPEN THE ISSUE OF THE POTENTIALLY DEGRADED CAPACITY OF THE STEAM DUMP SYSTEM.

FOLLOWING THE 3/7/03 TRIP. A REVIEW OF THE REACTOR TRIPS DATING BACK TO 2999 WAS PERFORMED.

OF THE FOUR TRIPS FROM 100% POWER, THE VSSVS WERE CONFIRMED TO H.AVE OPENED FOR TWO OF THETRIPS (5/25/99 AND 1/27/00).

FOR THE 2/11/00 TRIP DUE TO DROPPED CONTROL RODS, THE MSSVS DID NOT OPEN. NOTE THAT IN A DROPPED ROD, THE REACTOR POWER WILL DECREASE SINCE )IP2 RUNS WITH THE CONTROL RODS IN MANUAL CONTROL.

FOR THE 4/19/02 TRIP, THERE IS NO SEQUENCE Or EVENTS DATA AVAILABLE FROM THE PROCESS COMPUTER.

THUS, IT WAS NOT POSSIBLE TO DETERMINE WHETHER THE SAFETY VALVES OPENED FOR THIS TP.IP.

FOR ALL OF THE TRIPS THAT OCCURRED WHEN POWER WAS LESS THAN 100%,

NONE OF THE HSSVS OPENED.

THIS INCLUDES TRIPS AT 971 ANID 98% POWER.

ON MARCH 20, 2004 CALVERT CLIFFS 1 HAD A REACTOR TRIP THAT WAS DUE TO VERY SIMILAR FEEDwATER PROBLEMS AS THE 3/7/04 AND 3/14/04 TRIPS AT MP2.

MIKE GAHAN OF CALVERT CLIFFS CONFIRMED THAT THE XSSVS DID NOT OPEN DURING THIS REACTOR TRIP.

HE CONFIRMED THAT FOR CALVERT

CLIFFS, THE MSSVS DO NOT ROUTINELY OPEN FOLLOWING REACTOR TRIPS.

HE STATED THAT THE NORMAL OPERATING CONDITIONS FOR CALVERT CLIFFS IS 2700 MWT.

T-COLD 549 DEGREES F AND SC PRESSURE OF eso PSIG.

THE SG PRESSURE IS APPROXIMATELY 25 TO 30 PSI LOWER THAN THE NORMAL OPERATING PRESSURE FOR HP2.

THIS TENDS TO SUPPORT THE ORIGINAL CE PROPOSAL FOR REDUCING SG PRESSURL.

A QUALITATIVE ASSESSMENT OF OPENIING SAFETY VALVES 4

111 I

SEP-28-2004 16:05 MILLSTONE

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Pago 4 September27,2004 1s Millstone Condition Report CR-04-02514 4

Asshanmant Closure Notes FOLLOWING ROUTINE REACTOR TRIPS WAS REQUESTED FROM THE' PRA SECTION. STEAM LINE BREA.S ARE A CONTRIBUTOR TO CORE MELT FREQUENCY BECAUSE OF THE IMPACT ON THE RELIABILITY/AVAILABILITY OF THE TURBINE DRIVEN XF1 PUMP.

IF THE KSSVS ARE CHALLENGED DURING ROUTINE REACTOR TRIPS. THERE IS SOME PROBABILITY THAT THEY WOULD FAIL OPEN OR LEAK SIGNIFICANTLY.

CURRENTLY THIS IS UOT ASSUMED IN THE PRA MODEL.

IF THIS SITUATION WERE YODELED.

IT IS JUDGED THAT THERE WILL BE AN INCREASE IN CDP.

EASED UPON THIS INVESTIGATION, IT IS CONCLUDED THAT IT IS LIKELY THAT THE STEAM DUYP SYSTEM XS OPERATING AT A LOWER CAPACITY THAN ORIGINALLY DESIGNED.

IN ADDITION, THE OPTXWJM SOLUTIO?

MAY BE TO REDUCE SG PRESSURE AS WAS APPARENTLY IMPLEMENTED AT ST. LUCIE WHE2 THEY IMPLEMENTED STRETCH POWER.

A CONTROL SYSTEM STUDY SIMILAR TO WHAT WAS ORIGINALLY PROPOSED BY CE SHOULD BE PERFORMED TO DETERMINE THE OPTIMUM COMBINATION OF CONTROL SYSTEM AND/OR OPEPATING CONDITION CHANGES THAT WOULD ELIMINATE THE OPENING OP THE MSSVS FOR ROUTINE IAssinment Closure Nots AR-5 CONTACT COPES VULCAN FOR EXTENT OF CONDITION LIST OF AVAILABLE INFORMATION:

1.

MEMO FROM M. HESS TO E.

FARRELL "TURBINE BYPASS VALVES". DATED AUGUST 17. 1976

2. CE PROPOSAL NO. 1N20602-1 *A. PROPOSAL TO NORTHEAST UTILITIES SERVICE COMPANY FOR PREVENTION OF SECONDXRY SAFETY VALVE ACTUATION FOR MILLSTONE UNIT 2,. DATED JUlE 14. 1982

3.

INTEROFFICE MEVO FROM a.

CATAUDELLA TO R.

PLACE,-

" PREVENTION OF SECONDARY SAFETY VALVE ACTUATION',

DATED 11/17/82

4.

KEMO FROM A.

MELE TO J. BLAISDELL "MILLSTONE UNIT NO.

2 PREVENTION OF SECONDARY SAFETY RELIEF VALVE ACTUATION (PA 83-039)". GMiB-83-505, DATED OCTOBER 6.

1983 1RE AtORTR-P8.

I INDIVIDUALS CONSULTED IN INVESTIGATION2I J. PARILLO.-R.-

BORCHERT, D.

BAJUMPAA.

R.

STERNER.

A.

CHYRA.

K.DESLANDES.

L. WAGNECZ.

J. CRAFFEY. H. GAHAN (CALVERT CLIFFS).

PREVIOUS CRSIARS CR-03-11377 DURING PERYORMANCE OF IC 2425E 2-MS-209 FAILED THE QUICK OPEN STROXE TIME AR-l MAINTENANCE RULE FAILURE CR-03-11482 DURING PERrORMANCE OF IC 2426E 2-MS-209 FAILED THE QUICK OPEN STROXE TIME AR-1 MAINTENANCE RULE FAILURE AR-2 CRED CR-03-0O002 REA RECOMMENDING REPLACEMENT OF THE RP2 CONDENSER STEAM DUMP VALVES AR-2 REA VALUE MODEL CR-03-11e04 CONDENSER DUMP AND TURBINE BYPASS ACTUAL CAPACITY DOES NOT Y.ET ORIGINAL SPECIFICATION.

FSAR OR AR-2 REVIEW REA AR-3 PSAR PZVIE1 S. MEMO FROM T. HONIAN TO A.

MELE, "MILLSTONE UNIT 2 -

PREVENTION OF SECONDARY SAFETY VALVE ACTUATION FOLLOWING NOR.ML REACTOR TRIP'.- NE-83-SAB-282,- DATED OCTOBER 25. 1983

6.

MEMO FROM A. MELE TO R.

PLACE;

' *MILLSTONE UNtIT-NO.

2 PREVENTION OF SECONDARY SAFETY VALVE ACTUATION (PA 83-039)-",

GMB-E4-39, DATED JANUARY 19, 1984

7.

XEMO FROM T. V. SIM4ONDS TO DISTRIBUTION., ' ' t3N STEAM SAFETY/RELIEP (MSSR) VALVE TESTING (PROJECT ASSIGNMENT NO.83-039)".

GVB-66-421 DATED JUNE 24.

1986 S. MEMO FROM T. V. SIMMONDS. TO DISTRIBUTION

' ACTUATION OF STEAM GENERATOR SAFETY/RELIEF VALVES (PROJECT ASSIGNMET 110.83-039)*,

CMB-86-409, DATED JUNE 1S, 1986

9.

MEMO FROM T. V. SIMMONDS TO C. KOYOSXY, "MILLSTO'NE UNIT NO.

2 MAIN STEAM SAFETY/RELIEF VALVE ACTUATIONr PROJECT ASSIGNMENT NO.83-039 CLOSE OUT",

QS-87-S04.

DATED AUGUST 18, 1987

10.

MILLSTONE UNIT 2 NUCLEAR POWER PLANT DESIGN EASIS DOCUMENTATION PACKAGE MAIN STEWM. SYSTE,. REVISION 0.

DATED FEBRUARY 1, 1994, PAGES 3.2-86 THROUGH 3.2-91

11.

MY.OD M2-99057 "MODIFICATION OF YAIN CONDENSER STEAM DUYP VALVES, 2-MS-206, 207, 208 AND 209

CR INVESTIGATOR: K.

KAI (COMPLETED M:A-1604 CAUSE EVALUATION PROGRAM CBT 10/29/03)

CR CHECKLIST:

NOTE, SOMr Or THE CHECKLIST ITEMS ARE NOT APPLICABLE TO THIS TRENDING TYPE CR.

THESE INCLUDE:

?7?, 711?.

?E02?. ?EQ3?. ?EQ4?. ?EQ67. ?EQ7?, ?HP1?. ?HP2?

EXTENT OF COMDITION 4

0 THIS ISSUE APPEARS TO BE SPECIFIC TO THE XP2 AND CE NSSS DESICN.

NEITHERA MP3, NORTH ANNA AND SUPAY HAVE EXPERIENCED PROBLEMS WITH CHALLENGES TO MSSVS FOLLOWING AR-4 EVALUATE SIMULATOR MODEL

SEP-28-2004 16: 06 M ILLSTONE 8603 443 5893 P. Ub September27,2004 15 Millstone Condition Report CR-04-02514 Pago Ac4Iqnment Closure Notes XOUTINE REACTOR TRIPS.

IN ADDITION. THE PROBLEM WAS APPARENSLY SOLVED FOR ST. LUCIE AND CALVERT CLIFFS.

IT APPEARS THE MP2 IS AN OVTLItR.

INITIATOR FEEDBACK INITIATOR HAS PERFORXED THE INVESTIGATION.

CAUSE Al -

ORIGINAL PROBLEM NOT RESOLVED BY DESIGN CHANGE THE ISSUE OF mSSV OPENING FOLLOWING ROUTINE REACTOR TRIPS WAS APPARENTLY CLOSED BASED UPON TYE RISKS AND RESOURCES NEEDED FOR TESTING.

THE SAFETY SIGNIFICANCE WAS EASED UPON THE IMPACT ON SGTR RATHER THAN THE POTENTIAL IMPACT ON MSSV PELIABILITY AND CONSEQUENTLY AFW RELIABILITY.

CORRECTIVE ACTIONS FOR CAUSE 1

1.

GENERATED ACTION TO:

PERFORM A CONTROL SYSTEM STUDY THAT WILL DETERMINE THE OPTIMUM COMBINATION OF STEAM DUKP SYSTEM CHANGES AND CHANGES IN NORMAL OPERATING CONDITIONS THAT WILL ELIMINATE THE POTENTIAL FOR OPENING VSSVS FOLLOWING REACTOR TRIP.

THE STUDY SHOULD INCLUDE A SURVEY OF PLANTS SImILAR f Fac UnIt Svc Loc Sys Doscription MP NA NA NA NO SYSTEM REFERENCE Assignment Closure Notes CR investigation was presented ?RT on 3/14/04.

M5T approved the investigation ard corrective actior.s with coernents.

The corrective action A/9s have been revised to reflect MRT con'ents. Thus, this asEignment ic complete.

M. Kai Ext. 021S S

J2 I

9.1

.6 Assignment: 04001714-03 Typo:

Due Date:

Status:

Resp. Group Organization Status Date:

Subject:

SchAdulA Rt~f CAOE (OPERATING EXPERIENCE REVIEW ASSIGNMENT)

Friday, April 16, 2004 COMPLETE MGRNUCFUEL (MANAGER NUCLEAR FUEL) 85H Monday, April 12, 2004 CR-04-02514 OEASSIGNMENT:TRENDING CR FOR MAIN STEAM SAFETY I

I TO TFE DESIGN0F XF27TIIGxASa HEE25 APPROVED BY CLINT GLADDING.

ACTION OWNER:

MCRDESENG-.-_DUE DATE: 06/07/2004

_PRIORITY:

PXED SCHEDULE

REFERENCE:

NA MODE: NA UNIT: 02 :

-AND-SYSTEM:-NA-t-NA;-ASSiGNMENT--YPE :-CACA

2.

GENERATED ACTION TO:

INITIATE RE TO IMPLE.MENT RECOMMENDED CONTROL SYSTEM UND/OR OPERATING CONDITION CHANGES. THIS ASSIGNMENT HAS BEEN APPROVED BY CLINT GLADDING.

ACTION OVNER:

MGRDESENG : DUE DATE: 08/07/2004 ;

PRIORITY: PMED

SCHEDULE

REFERENCE:

NA ; MODE: NA ; UNIT: 02 AND SYSTEM: NA I NA; ASSIGNMENT TYPE:

CACA

-co--

A Mode:

NA (ASSIGN'MT IS NOT RELATED TO A PLANT MODE CHNG EWR PWR) 02 t1

.Affected Unit.

-Affected System-NA-( NO SYSTEM REFERENCE.)

Assiqnment Attributes IRosp. Individual: SE84CK MICHAEL KAI Assignment: 04001714-02 Type:

Duo Dato:

Statues:

Resp. Group Organization Status Date:

Subject:

Schedule Rot:

Mode:

Aflected Unit:

Affected Syslem CATT (CATEGORY T -TRACKING COMMITMENT (NOT C. M. P. S OR X))

Wodnesday. April 28.2004 COMPLETE MGRNUCFUEL (MANAGER NUCLEAR FUEL)

ESH Wednesday, AprIl 14, 2004 CR-04-02514 SITE MRT PRESENTATION:TRENDING CA FOR MAIN STEAM NA NA (ASSIGN'MT IS NOT RELATED TO A PLANT MODE CHNG BWR PWR) 02 NA (NO SYSTEM REFERENCE)

Assignment Text CR-04-02514, SIGNIFICANCE LEVEL: 2 INITIATED BY:

MICHAEL KAI PHONIE:

0215 CRT REVIEW DETEPMINED THIS EVENT/ISSUE MAY NEED TO BE COMMUNICATED VIA OR. ASSESS FOR THE NEED TO SHARE THIS EVENT WITH THE INDUSTRY PER INPO GUIDANCE POUND ON THE NUCLEAR NE"O*RX SUBXITTAL DOCUMENT ILOCATED IN MILLSTONE EXPLORER/DOCUMENT EXPLORER/FORMS/M102/SHARE OE. IF THE EVENT SHOULD BE SHARED, PREPARE NUCLEXR IETWORK DOCUMENT AND PROVIDE TO OE GROUP.

IF EVENT IS NOT TO BE SHARED, PROVIDE 5USTIFICATION FOR NOT SHARING IN CLOSURE NOTES. ASSIGNMENTS NEED TO BE COMPLETED WITHIN A THIRTY DAY TIME FRAME TO SUPPORT INPO PERFORMANCE GOALS.

OE QUESTIONS SHOULD BE REFERRED TO B.

BASTIGLIA X6063.

CONDITION REVIEW TEAM COMMENTS:

SDP.

?KRT?

ISSUE DETAIL:

IT IS EXPECTED THAT THE STEAM DUMP SYSTEM WILL HAVE SUFFICIENT CAPACITY AND RESPONSE TIME SUCH THAT FOR A ROUTINE REACTOR TRIP. THE MAIN STEAK SAFETY VALVES WOULD NOT OPEN.

CONTRARY TO THIS EYPECTATION.

THE LAST THREE REACTOR TRIPS Am FULL POWER FOR MILLSTONE UNIT 2 HAVE RESULTED IN MO METARY OPEXIJNG OF AT LEAST ONE MAIN STEAM SAFETY VALVE.

WHILE A NUMBER OF EVALUATIONS AND DESIGN CHANGES HAVE BEEN MADE TO REDUCE THE LIKELIHOOD OF SAFETY VALVE OPENING, THE RECENT TRIPS HAVE DEMONSTRATED THAT FOR SOME SET OF CONDITIONS.

SAFETY VALVE OPENING WILL STILL OCCUR. AT THE rEQUEST OF MANAGEMEN.T, THIS TRENDING CR IS BEING WRITTEN TO INITIATE AN INTEGRATED EVALUATION OF THIS ISSUE TO DETERMINE Ir ANY ADDITIONAL CORRECTIVE ACTIONS ARE APPROPRIATE. THE INTEGRATED EVALUATION SHOULD INCLUDE A REVIEW OF DESIGN BASIS AND LICENSING BASIS REQUIREHEITS, OPERATING EXPERIENCE FROM OTHER CE NSSS PLANTS AND THE MP2 PAST HISTORY.

THE EVALUATION WILL DETERXINE IF THE OPENING OF THE MAIN STEAM SAFETY VALVES SHOULD BE EXPECTED IN THE PREVIOUS EVENTS AND Assignment Attributes Resp. IndIvIdual: SE084CK; MICHAEL KAI

-I Assignment Text CR-04-02514, SIGNIFICANCE LEVEL: 2 INITIATED BY:

MICHAEL MA!. PHONE: 021S

-PRESENT RESULTS OF I5VESTIGATION AND CORRECTIVE ACTION PLAN TO SITE KRT. --

-CONTACT HEDORA DALLY, X2454. TO SCHEDULE.

CONDITION REVIEW TEAM COM4ENTS:

SDP. ?7OT?

Assignment Svstem References

SEF-28-2004 16:06

,s'_;,

0 Sepsamber27,2004 15 MILLSTONE 860 443 5893 ti.U Millstone Condition Report CR-04u02514 Page 6 DETERMINE IF ANY ADDITIOVAL CHANGES SHOULD BE ItNESTZGATED.

Assignment System References Fac Unit Syo Leoc Sys Description MP NA NA NA NO SYSTEM REFERENCE AssIgnment Closure Notes it has been determined that this issue should be be shared vith the industry.

The INPO Nuclear Network Template has been filled out and sent to Mary Lou Calderone of the OE group. Thus. this assignment is complete. M.. Kai Ext. 0215 Assignment: 04001714-04 Assignment:

04001714-05 Type:

Due Date:

Status:

Rosp. Group OrganIzatlon Status Date:

Subject:

Schedule Roef:

Modo:

Affectod Unit:

Affected System CACA (CR CORRECTIVE ACTION ASSIGNMENT)

Thursday. January 20,2005 ACCEPTED MGRDESENG (MANAGER DESIGN ENGINEERING) 826 Tuesday, April 06, 2004 CR-04-02S14: CORRECTIVE ACTION 2 FOR CAUSE I

NA NA (ASSIGN'MT IS NOT RELATED TO A PLANT MODE CHNG BWR PWF) e 02 NA (NO SYSTEM REFERENCE)

Typo:

CACA (CR CORRECTIVE ACT1ON ASSIGNMENT)

Due Date:

Frlday, December31. 2004 Status:

ACCEPTED Rasp. Group MGRNUCFUEL (MANAGER NUCLEAR FUEL)

Organization 85H -

Status Date:

Friday, August 13, 2004 Sublect CR-04-02514: CORRECTIVE ACTION 1 FOR CAUSE Schedule Rel:

NA Mae: _

NA-- (ASSIGNMT IS NOTRIELATED TO A PLANT-.

-MODE CHNG ESWR PWR)

Affected Unit:

02 Affacod Systam NA (NO SYSTEM REFERENCE )

Assignment Attributes Resp. individual: CY92SAD. MICHAEL F. MARINO Assignment Text INITIATE REA TO IMPLEMENT REC0XMENDED CONTROL SYSTE1 a1ND/OR OPERATING CONDITION CHANGES. THIS ASSIGNMENT HAS BEEN APPROVED BY CLINT GLADDING.

PRIORITY CODE IS FOR SHIS ASSXGNMENT 5s P~irS.

4/14/04 Based upon input from MRT, this assignment has been extended to 9/X7/04.

M. Yai Exc.

0215

'Thi-i.assignment-wa--incorrectly.5q'enced.

it must come after aceignment 04, which is due 12/31/04.

Please extend to 1/20/05; M Marino 0108 9/11/0 4 Note: oxtension approved by Al Elm-for Skip Jordan.

9/17/04, Due date has boon extended to 1/20/05 per above adpproval.D.Connors Assiqnment Attributes Rasp.individual: MPOODAS: JOHN S. SPAARGAREN Assignment Text PERFORM A CONTROL SYSTEM STUDY THAT WILL DETERMINE THE OPTIMUM COMBINATION OF STEAM DVMP SYSTEM CHANGES AND CHANGES I1 NORMAL OPERATING CONDITIONS THAT WILL ELIMINATE THE POTENTIAL FOR OPENING VSSVS FOLLOWING REACTOR TRIP. THE STUDY SHOULD INCLUDE A SURVEY OF PLANTS SIMILAR TO THE DESIGN OF MP2. THIS ASSIGNMEDT HAS BEEN APPROVED BY CLINT GLADDING.

PRIORITY CODE IS FOR THIS ASSIGNMENT IS PXED.

4/14/04 Based upon input from HRT. the following changes are made to this assignment:

1.

Inmut from operations and Training, at necessary.

to reflect MP2 specific experience should be included in the study.

2.

if. as a result of the study, no additional corrective action is necessary, an FSAR change shall be initiated to reflect the change in performance of the stcam dunw system.

3.

The completion of this task it extended to 8/16/04.

M. Vai Ext. 0215 e/13/04 The decision hat been made to perform the control study in-house by Safety Analysis. Therefore the assignment is transferred to MGRNUCFUEL -85H.

Also. the study will not be completed until the end of the year.

Therefore the due date is being extended to 12/31/04.

As thiz is a PMED assignmenc Skip Jordan has been informed of this change and has concurred. W. L. Van Haltern x0211 Assignment Svstem References Fac Unit Sys Lac Sys Description MP 02 NA NA NO SYSTEM REFERENCE Assignment System References Fac Unit Sys Loc Sys Description MP 02 NA NA NO SYSTEM REFERENCE TOTAL P.07