05000305/LER-1986-001, :on 860211,review of Retest Requirements Re Solenoid Valve Replacement Revealed Valve Timing Test Not Performed During 1985.Caused by Erroneous Deletion from Procedures.Test Performed

:on 860211,review of Retest Requirements Re Solenoid Valve Replacement Revealed Valve Timing Test Not Performed During 1985.Caused by Erroneous Deletion from Procedures.Test Performed

ML20141P026
Person / Time
Site:	Kewaunee
Issue date:	03/13/1986
From:	Bernhoft S, Hintz D WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-86-32 LER-86-001, LER-86-1, NUDOCS 8603180446
Download: ML20141P026 (4)

LER-1986-001, on 860211,review of Retest Requirements Re Solenoid Valve Replacement Revealed Valve Timing Test Not Performed During 1985.Caused by Erroneous Deletion from Procedures.Test Performed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(1)
3051986001R00 - NRC Website

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On February 11, 1986, with the plant at full power operation, a review to deter-mine retest requirements following a solenoid valve replacement on the four 36-inch containment purge and vent valves revealed that a valve timing test had not been performed during the 1985 refueling outage. Failure to perform this test is contrary to Technical Specification Table 4.1-3, Item No. 16, which requires that a timing test be performed each refueling cycle.

These valves are used to vent containment at plant shutdown; during power opera-tions the valves' control switches are sealed shut and a two-inch mini purge line is used.

During 1979 through 1984 the timing test was included in the Pump and Valve Inservice Testing Plan. Following the 1984 refueling outage, when the two-inch line was installed, the timing test requirements were erroneously deleted from testing procedures.

Failure to perform this valve timing test is considered reportable per 10 CFR 50.73(a)(2)(1)(B) as operation prohibited by Technical Specifications.

Corrective actions have been taken to add the valve timing requirements back into a procedure.

Additional corrective actions are planned to review and docu-ment the function of valves covered by the IST Plan to prevent a recurrence of this type of event.

On March 1, 1986, a valve timing test was performed. All four valves operated within'the required time limit; hence, there was no concern that they would be able to satisfy their safety function.

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'l'X?.O naa Kewaunee Nuclear Power Plant olslalolol3l0l5 8l 6 0l0l1 0l' 0l2 0F 0 l3 On February 11, 1986, with the plant at full power operation, a review to determine retest requirements following a solenoid valve replacement on the four 36-inch containment purge and vent valves (VA) revealed that a valve timing test had not been performed during the 1985 refueling outage.

This is contrary to Technical Specification Table 4.1-3, Item No. 16, which requires that a timing test be performed each refueling cycle to demonstrate that the containment purge and vent valves will close in less than or equal to five seconds.

These valves are designated by plant operations numbers as RBV-1, R8V-2, RBV-3 and RBV-4. They are used to vent containment at plant shutdown conditions.

During power operation the control switches for these valves are administra-tively sealed in the closed position and a two-inch mini purge line is used for venting to ensure containment pressure remains below the Technical Specification limit of 2 psig. The 36-inch purge and vent valves are maintained closed during power operation due to concerns raised by the NRC in 1978 regarding the poten-tial for the large diameter purge and vent valves to fail to close under post accident conditions.

Between the years of 1978, when the NRC first raiseJ the concern, and 1984, when the Kewaunee Nuclear Plant installed the two-inch vent line, a considerable amount of negotiation took place between the two parties.

In an attempt to justify continued operation with the valves open during power operation the Technical Specification required timing test was added.

In addition, a commit-ment was made to limit containment venting to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year and to inform the NRC prior to using the system.

During the 1979 refueling outage the valves timing test requirements were added to the Inservice Pump and Valve Testing (IST) Program and put into surveillance procedure SP 167-6, " Cold Shutdown Evolution Valve Timing Test IST".

The valves were tested a total of seven times during the 1979 through 1984 annual refueling outages. On each occasion all four valves closed in less than one second on a containment vent isolation signal.

Following the modification to add the two-inch vent line, the valves were administratively closed for operation above hot shutdown and the Technical Specification requirement to perform the valve timing was to be deleted since it was no longer applicable. To reflect this change in operating practice, the IST Plan was revised following the 1984 refueling outage to show these valves as passive and the valve timing test requirements were deleted from SP 167-6.

It was an engineering personnel error that the valves were reclassified as passive.

Since the valves are in use below a hot shutdown and may be required to close to provide containment vent isolation, they should have remained classified as active. The combination of misclassification and the administrative oversight regarding the no longer applicable Technical Specification resulted in failure to comply with the existing Technical Specification timing test requirement during the 1985 refueling outage.

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m..nm To verify proper operation, a timing test was performed for these four valves on March 1, 1986 prior to putting them in service to cooldown for the 1986 annual refueling outage. At that time all four valves met their acceptance criteria by closing in less than one second on a containment vent isolation signal.

During normal plant power operation there were no safety implications since all these valves maintained closed and were satisfactorily leak tested in accordance with 10 CFR 50 Appendix J.

The only concern was when they were in use during the 1985 refueling outage under conditions requiring containment integrity for fuel movement and the RCS above 200 degrees.

The valves function would have been to automatically close to minimize a radioactive release if required.

The possibility of these valves failing to isolate during this type of an event is very remote since; 1) during the refueling outage these valves were tested daily per the plant daily checklist which verified that a high radiation signal on containment radiation monitors would init'iate a containment vent isolation,

2) the results from the prior timing test and the one performed March 1, 1986 demonstrated that there had been no degradation of the valves ability to per-form their design function, and 3) the valves received a local leak rate test every six months to prove that they were fully closed and seated.

Corrective actions have been completed to incorporate the valve timing test requirements into SP 167-6 and to perform the SP prior to putting the valves into service for the 1986 annual refueling outage. To prevent a recurrence of this type of event a review of the valves included in the IST Plan will be per-formed documenting why they are considered as active or passive.

Controls are in place to ensure Technical Specification testing requirements are satisfied. This is accomplished by a " Procedural Implementation of Technical Specifications List" which is a cross reference between the Technical Specification requirements and the procedure in which they are implemented.

This discrepancy was identified at the time of development of this list; the intended resolution of the discrepancy was to request that the valve timing test be deleted from Technical Specification.

Due to administrative oversight, this was never done. This error is considered to be an isolated occurrence.

This event is considered reportable under 10 CFR 50.73(a)(2)(1)(B) as operation prohibited by Technical Specifications for failure to perform the valve timing test required by TS Table 4.1-3.

During the time periods that the valves were in use they were tested to verify they would fulfill their safeguards functions of isolating on containment high radiation; however, the testing did not monitor for component degradation by performing a timing test.

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r NRC-86-32 WPSC(4f4)4331234 TELEX 5101012698 WPSC GRO TELECOPIER(414)433-1297 EASYUNK 62891993 WIBCONSIN_PUSUC SEm4CECOf4POftAYlO5 SOC North Adams + PO. Box 19002. Green Day, WI 54307-9002 March 13, 1986 l

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.

20555 l

Gentlemen:

l Docket 50-305 i

l Operating License DPR-43 l

Kewaunee Nuclear Power Plant l

Reportable Occurrence 86-001-00 l

l In accordance with the requirements of 10 CFR 50.73, " Licensee Event Report l

System", the attached Licensee Event Report for reportable occurrence 86-001-00 is being submitted.

Very truly yours, f &

NOw y

D. C. Hintz Manager - Nuclear Power DR/jms Attach.

cc - INP0 Records Center Suite 1500, 1100 Circle 75 Parkway Atlanta, GA 30339 Mr. Robert Nelson, NRC Resident Inspector RR #1, Box 999, Kewaunee, WI 54216 Mr. G. E. Lear, PWR Project Directorate-1 US NRC, Washington, DC 20555 Mr. J. G. Keppler, Regional Administrator Region III, US NRC, 799 Roosevelt Road Glen Ellyn, IL 60137 y"g/S Ms. N. A. Nicholson Region III, US NRC, 799 Roosevelt Road Glen Ellyn, IL 60137

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