ML19210B797

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Recommendations to NRC for Ser,Kewaunee Nuclear Power Plant:Inservice Testing Program.
ML19210B797
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 09/30/1979
From: Coppola A, Randy Hall, Lettieri V
BROOKHAVEN NATIONAL LABORATORY
To: Cheng C
Office of Nuclear Reactor Regulation
References
CON-FIN-A-3117 BNL-NUREG-26781, NUDOCS 7911120393
Download: ML19210B797 (46)
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Inservice Testing Program Subject of this Document: Recommendations to the NRC for the Safety Evaluation Report of Kewaunee Nuclear Power Plant Type of Document: Informal Reoort Author (s): A. Coppola, V. Lettieri, and R.E. Hall Date of Document: September 1979 Responsible llRC Individual UI'.Cy Cheng ,

and f1RC Office or Division: Division of Ooerating Reactors _

U.S. Nuclear Regulatory Cammission Washington, D.C. 20555 This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

Brookhaven PP tional Laboratory Upton, ?JY 11973 Associated Daiversities, Inc.

for the U.S. Departfaent of Energy Prepared for U.S. !!uclear Regulatory Commission trashington, D. C. 20555 Under Interagency Agreement EY-76-C-02-0016 HRC FIH l'o. A-3117 INTERIM REPORT X1C lesearch amlibchnica! IW W N. Assistance Rcport " 22280 39 3

iMITED DISTRIBUTION -

L.NURE& 26781 ORMAL REPORT RECOMMENDATIONS TO THE NRC FOR THE SAFETY EVALUATION REPORT OF KEWAUNEE NUCLEAR POWER PLANT INSERVICE TESTING PROGRAM A. COPPOLA, V. LETTIERI, AND R.E. HALL

% y w Ju o S. .\ m DATE PUBLISHED - SEPTEMBER 1979 DEPARTMENT OF NUCLEAR ENERGY BROOKHAVEN NATIONAL LABORATORY UPTON, NEW YORK 11973

?' , F1 Prepared for the U.S. Nuclear Regulatory Commission

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~l Office of Nuclear Reactor Regulation Contract No. EY-76-C-02W16

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@@0$'Ok0bObb 1317 304 NOTICE This rep >rt was prepared as an account of work sp>nsored by the United States Gosernment. Neither the United States nor the United States Nu< tear Regulatory .

Conimission, nor any of their employen, not any of their wntrattors, sulrontra(ton.,

or their employees, makes ans w arranty , exprew or in1 plied, or assumes any legal hability or rnp>nsibility for the accuracy, t ompletenns or usefulness of any informa-tion, apparatus, product or prosess dis losed. or represents that its use would not inhinee privately ow ned rights.

BNL-NUREG-26781 INFORMAL REPORT LIMITED DISTRIBUTION Recanmendations to the NRC for the

. Safety Evaluation Report of Kewaunee Nuclear Power Plant Inservice Testing Program A. Coppola, 'V. Lettieri, and R.E. Hall Engineering and Advanced Reactor 3afety Division Department of Nuclear Energy Brookhaven National Laboratory Upton, New York 11973 September 1979 Prepared for U.S. Nuclear Regulatory Canmission Washington, D.C. 20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3117 I b $ .. *

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\3\1 NOTICE: his document contains preliminary informa'. ion and was prepared primarily ?or interim use. Since it may be subject to revision or correction and does not represent a final report, it should .

not be cited as reference without the excressed consent of the author (s).

TABLE OF C0!1 TENTS E x e c u t i v e S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.0 Pump s , I n se rv ic e Te s ti ng P rog ram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.0 Va l ve s , I n se rv i c e Te s t i ng P r og r am . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.0 Col d Shutd own Te s ti ng of Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . P 5 4.0 Prog rr_.: B r e ak d ow n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Conc 1usion............................................................... 39 1317 .307 4

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Brookhaven National Laboratory Recommendations to the NRC for the Safety Evaluation Report of Kewaunee Nuclear Power Plant Wisconsin Public Service Corporation Inservice Testing Program (Docket No. 50-305)

  • (Submittal dated July 14, 1977 and February 9,1979)

Executive Summary Under contract to the Nuclear Regulatory Commission (NRC), the Reactor Engineering Analysis Group of Brookhaven National Laboratory (BNL) has con-ducted a review of the Inservice Testing portion (IST, pumps and valves) of the Kewaunee Nuclear Power Plant, Docket No. 50-305, Inservice Inspection and Test program (ISI/IST). This evaluation is based on the submittals of pro-posed ammendments to the technical specifications dated July 14, 1977 revised February 9,1979, and a meeting held with representatives of the licensee, the NRC staff and BNL on July 10 and 11,1978. The ISI portion of the submittal was reviewed by the NRC staff and is not commented on herein.

Based on that meeting, the proposed technical specification change was resubmitted on February 9,1979 and this document has been fonnally reviewed for this report. Most of the open items discussed at the meeting were cor-rected by the resubmittal . The recommendations made in this report are based on evaluations which considered: Practicality within limitations of equipment design and geometry, requirements of Section XI of the 1974 Edition thru Sum-mer of 1975 of ^.he ASME Boiler and Pressure Vessel Code, 10 CFR 50.55a(g), NRC Staff Guidance Letters (November 1976 and January 1978), and topics of numer-ous NRC Staff /BNL briefings.

The review covers two major areas and is summarized as follows:

1. Inservice Testing of Pumas - Seven relief requests were reviewed and all are recommended to te granted. The complexities of older plants not designed to the 197a ASME code are apparent. In most cases, flow measurement and bearing temperature are not available measurements.

The proposed tests in lieu of the ASME requirements are acceptable.

2. Inservice Testing of Valves - This area involves the greatest number of relief requests and 1s divided into three main categories. The first category (2.1) is a group of general commentaries developed for all plants by the NRC staff. The second category (2.2 - 2.12 inclu-sive) contains 27 relief requests particular to Kewaunee. Twenty four of these are recommended for approval . The last category (Section 3.0) is a review of valves which cannot be tested quarterly but will be exercised at cold shatdown. All of these are recommended for approval. Section 4.0 is a program summary of the recommenda-tions for valve testing.

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In summary, it has been found that the program, as reviewed and modified by this analysis is in compliance to the extent possible with the requirements set forth in Section XI of the 1974 Edition and Addenda through the Summer 1975 of the AStE Boiler and Pressure Vessel Code as required by 10 CFR 50.55a(g).

BNL has evaluated requests and recommended relief from specific require-ments which were determined to t,c impractical for this facility, for the pump and valve portion of the ISI/IST program only. The ISI portion of this review '

was done by the NRC staff.

This report includes the relief request spccific evaluations that are recmmended to be included in the NRC's Safety Evaluation Report or, the sub-ject of IS /IST for the Kewaunee Nuclear Power Plant. These recommendations are a result of the above described review and do not constitute a cmplete-ness evaluation of the program.

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1.0 PUMPS, INSERVICE TESTING PROGRAM 1.1 HPSI Pumps 1.1.1 Relief Request: The vibration amplitude and the bearing tempera-ture of pumps APSI-1A and APSI-1B will be measured at refueling outages in lieu of Section XI requirements.

Code Requirement: An insenice test shall be run on each pump, nominally each month during normal plant operation. Each inservice test shall include measurement and obsenation of all quantities in

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Table IWP-3100-1 except bearing temperatures which shall be measured during at least one insenice test each year.

Licensee Basis for Relief Request: (a) The monthly perfomance test of these pumps is run under recirculation "miniflow" condi-tions. With high head,1ow flow operating conditions, these pumps vibrate considerably more than under normal flow conditions.

Vibration measurements will be taken when the pumps are run under a reference flow condition during each refueling outage. (b) The bearing oil cooling system for these pumps is cooled by the Service Water System. The system is not temperature stabilized, therefore, meaningful results from the recording of this te11perature cannot be expected.

Evaluation: The measuring of bearing temperatures at refueling outages meets the intent of the Code (yearly measurements). The NRC staff agrees that vibration measurements during miniflow tests are not very meaningful and it is therefore recommended that this relief request be granted.

1.2 Residual Heat Removal Pumps 1.2.1 Relief Request: The vibr6 tion amplitude, bearing temperature and the lubricant level of APRHI-1 A and APRHI-1B will be measured at refueling outages in lieu of Section XI requirements.

Code Requirement: See Code Requirement, Item 1.1.1.

Licensee Basis for Relief Request: (a) The monthly performance test of them pumps is run under recirculation "miniflow" condi-tions. With high head, low flow operating conditions, this pump vibrates considerably more than under nomal flow conditions.

Vibration measurements will be taken when these pumps are run under a reference flow condition during each refueling outage. ( b) Be-

- aring temperatures are recorded at refueling since that situation provides reference conditions in which the bearing temperatures have had adequate time to stabilize. (c) Monthly recording of

., Lubricant Level or Pressure requires entry into the RHR pump pit which is normally inaccesible at power. No remote indication ex i s ts.

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Evaluation: The licensee states that pumps APRHI-1A and APRHI-1B are tested under "miniflow" conditions. With high head, low flow conditions, these pumps vibrate considerably more than under nonnal flow conditions. Based on the fact that the vibration test under "miniflow" conditions is not representative of the pump's con-dition, therefore, it is recommended to grant relief to measure vibration amplitude at refueling outages in lieu of the Code re-quirement. ,

These pumps are tested monthly under "miniflow" conditions. Under these conditions, the pumps are njn for as short a time as possible to prevent pump damage, and consequently the bearing temperature is constantly rising. Based on the above, it is recanmended that re-lief be granted to measure bearing temperatures at refueling out-ages when these pumps are tested at full ficw and are nJn long enough for test parameters to stabilize. In the event that the time period between refueling outages exceeds one year, this item is a relief request, otherwise, the indicated frequency meets the intent of tne Code. As the licensee has stated, recording of lubricant level requires entry into the RHR pump pit which is nonnally inaccessible at power. Based on the impracticality of monthly recording of lubricant level due to plant design, relief is recommended to record this level at refueling outages.

1.3 Auxiliary Feedwater System Pumps 1.3.1 Relief Request: Flow rate will not be measured for pumps 1A and 1B. In addition, vibration amplitude and bearing temperature of these pumps will be measured at refueling outages in lieu of Sec-tion XI requirements.

Code Requirement: See Code Requirement, Item 1.1.1.

Licensee Basis for Relief Request: Under the operating mode in which these pumps will be t isted the system will have fixed re-sistance. As allowed by footnote 1 of Table IWP-3100-1, this para-meter will not be recorded. The monthly perfonnance test of these pumps is run under recirculation "miniflow" conditions. With high head, low ilow operating conditions, these pumps vibrate consider-ably more than under normal flow conditions. Vibration measure-ments will be taken when these pumps are run under a reference flow condition during each refueling outage. Bearing temperatures are recorded at refueling since that situation provides reference conditions in which the bearing temperatures have had adequate time to stabilize.

Evaluation: Since pumps 1A and 1B will be tested with fixed re-sistance, as per footnote 1 of Table IWP-3100-1, flow rate will not be measured. This is not a relief request.

The licensee states that pumns 1A and IB are tested under " mini-flow" conditions. With high head, low flow conditions, these pumps vibrate considerably more than under nonnal flow conditions. Based 4

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on the fact that the vibration test under "miniflow" conditions is not representative of the pump's condition, therefore it is recom-mended to grant relief to measure vibration amplitude at refueling outages in lieu of Code requirement.

These pumps are tested monthly under "miniflow" conditions. Under these conditions, the pumps are run for as short a time as possible 1.u prevent pump damage, and consequently the bearing temperature is constantly rising. Based on the above, it is Nconmended that re-lief be granted to measure bearing temperature at refueling outages when thcse pumps are tested at full flow and are run long enough for test parameters to stabilize. In the event that the time peri-od between refueling outages c_ceeds one year, this item is a re-lief request, otherwise, the indicated frequency meets the intent of the Code.

1.3.2 Relief Request: Flow rate for turbine driven pump 1C will not be measured. In addition, vibration amplitude and bearing temperature will be measured at refueling outages in lieu of Section XI re-quirements.

Code Requirements: See Code Requirements, Item 1.1.1.

Licensee Fasis for Relief Request: Under the operating mode in which this pump will be tested, the systs will have fixed resis-tance. As allowed by footnote 1 of Table IWP-3100-1, this para-meter will not be recorded. The monthly perfonnance test of this pump is run under recirculation "miniflow" conditions. With high head, low flow operating conditions, this pump vibrates consider-ably more than under normal flow conditions. Vibration measure-ments will be taken when the pump is run under a reference flow condition during each refueling outage. Bearing temperature is recorded at refueling since that situation provides reference conditions in which the bearing temperature has had adequate time to stabilize.

Evaluation: Since pump 1C will be tested with fixed resistance, as per footnote 1 of the Table IWP-3100-1, flow rate will not be measured. This is not a relief request.

The licensee states that pump 1C is tested under "miniflow" condi-tions. With high head, low flow conditions, this pump vibrates considerably more than under nonnal flow conditions. Baseo on the fact that the vibration test under "miniflow" conditions is not representative of the pump's condition, therefore, it is recommend-

. ed to grant relief to measure vibration amplitude at refueling out-ages in lieu of Code requirement.

This pump is tested monthly under "miniflow" conditions. Under these conditions, the pump is run for as short a time as possible to prevent pump damage, and consequently the bearing temperature is constantly rising. Based on the above, it is recommended that 5

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relief be granted to measure bearing temperature at refueling out-ages when the pump is tested at full flow and is run long enough for test parameters to stabilize.

In the event that the time period between refueling outages exceeds one year, this item is a relief request, otherwise, the indicated frequency meets the intent of the Code.

1.4 Service Water System Pumps 1.4.1 Relief Request: Inlet pressure, outlet pressure, differential pressure, flow rate, bearing temperature and lubricant level will

  • not be measured in accordance with code requirments for pumps 1A1, 1A2, 1B1, 182.

Code Requirement: See Code Requirement, T. tem 1.1.1.

Licensee Basis for Relief Request: The service water pumps are vertical design with no means 0+ direct inlet pressure measurement as required by IWP-4200. Inlet pressure to these pumps will be es-tablished by reference to the level of water above the pump suc-tion. As the measurement of the level of water above suction is to be used to detemine the inlet pressure, relief is required from meeting pressure tap construction and location requirements of IWP-4211 and IWP-4212.

The outlet pressure of the individual Service Water pumps cannot be recorded and consequently differential pressure cannot be estab-lished. Instrumentation is available to monitor system pressure at the coamon outlet header of the four service water pumps and this parameter can be recorded. It must be recognized that the design heat load is such that multiple pumps must be in operation at all times. There is no plant operating conditions when a single pump could be run to determine performance parameters as required by IWP-3400(a). Additionally, the heat load is constantly varying dependent on plant power levels, lake water temperatures and ambi-ent conditions such that perfomance parameters are not readily re-peatable. There is no instrumentation to monitor flow rate in the plant systs as designed and constructed. As indicated above, the system heat load is such that multiple pumps must be in operation at all times and operating parameters will vary with plant power l evel s , etc .

The service water pumps are open line shaft pumps that depend primarily on the liquid being pumped for the lubrication of the pump and lineshaft bearings. The bearing lubricating water flow -

can be verified by sight glass but pressure cannot be onitored.

All pump bearings are submerged and lubricant is allowed to leak of f into the sump and is not piped back, such that temperatures cannot be monitored.

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Evaluation: Service Water pumps 1A1,1A2,1B1,182 are vertical design with no means of direct inlet pressure measurement. Inlet pressure to these pumps is established by reference to the level of water above the pump suction. Due to the impracticality of direct measuremert of inlet pressure due to plant design, it is recom-mended that relief De granted frua meeting pressure tap construc-tion and location requirenents of IWP-4211 and IWP-4212, and to allow inlet pressure to be determined by tank level . The system outlet pressure measurement can be used as an individual outlet pressure measurement, and will satisfy the intent of the . code, if some means of measuring flow, either individually or in groups can be devised. It is apparent that flow rate measurements for individual pumps for this system do not exist, and that total flow rate depends not only on pump condition, but on system demand. This situation is not tenable under the ASME Code, since, at los system demands, the fact that one of the groups of pumps is de-grading in hydraulic performance, can go undetected for long peri-ods of time. Unless it is shown by the licensee that instrumenta-tion cannot be installed, or other means for measuring flow (such as motor current, or heat exchanger tmperature) are inaccurate and therefore unacceptable, it is recommended that this relief request be denied. These pumps are open shaft pumps which are lubricated / cooled by water. Satisfactory pump operation is indicative of suficient bearing lubrication, therefore, it is recmmended that relief from measuring and recording lubricant level be granted. The bearing lubricating water is allowed to leak off into the sump and is not piped back. Based on the impracticality of measuring bearing tem-perature due to p1 ant design, it is recommended that relief from measuring this test parameter be granted. 1.5 Component Cooling System Pumps 1.5.1 Relief Request: The bearing temperature of pumps APCCl-1A and APCC2-1B will not be measured. Code Requirements: Bearing temperature shall be measured during at least one inservice test each year. Licensee Basis for Relief Request: There is no installed instru-mentation to monitor this parameter. The design of the pump is such that article IWP-3500 cannot be met. Evaluation: Component Cooling pumps APCCl-1 A and APCC2-1B have no provisions for measuring bearing temperature. Based on this, we conclude that it is not practical to obtain bearing temperatures as required by the Code. In addition, other pump parameters including vibration are measured as required by the Code, indicating pump performance and bearing condition. Therefore, we recmmend that relief be granted not to measure bearing temperature of these pumps. 7 1317 H4

1.6 Containment Spray System Pumps 1.6.1 Relief Request: The flow rate and bearing temperature of pumps 1A and IB will not be measured. Vibration amplitude will ha measured under a reference recirculation condition. Code Requirement: See Code Requirment, Item 1.1.1. Licensee Basis for Relief Request: Under the operating mode in which these pumps will be tested the system will have fixed re-sistance. As allowed by footnote 1 of Table IWP-3100-1, this para-meter will not be recorded. ~ The containment spray pumps are performance tested by running the pump taider recirculation "miniflow" conditions. Vibration measure-ments will be taken under a reference recirculation condition, however, it is expected that vibration will be higher under these conditions. No remote bearing temperature instruments exist and measurements would not be meaningful since these pumps cannot be run under these conditions long enough to stabilize. Evaluation: Since pumps 1A and 1B will be tested with fixed resis-tance, as per footnote 1 of Table IWP-3100-1, flow rate wil1 not be measured. This is not a relief request. The Containment Spray pumps have no provisions for measuring bearing temperature and measurements would not be meaningful since these pumps cannot be run long enough to stabilize conditions for testing. Based on the above statements, we conclude that it is not practical to ob'.ain bearing temperatures as required by the Code. Therefore, we recmmend that relief be granted not to measure bearing temperature of these Containment Spray pumps. These pumos are tested under "miniflow" conditions. Vibration measurements will be taken under a refererce condition, although it is expected that vibration will be higher under these conditions. We conclude that this is the most practical means of meeting the intent of the Code requirements and, therefore, it is recommended that relief be granted as requested. 

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2.0 VALVES, INSERVICE TESTING PROGRAM 2.1 General 2.1.1 The scope of this review is limited to those valves which perform a safety-related function. Safety-related valves, for the purpose of IST, have been defined as those valves that are necessary to func- ~ tion to safely shutdown the plant and/or mitigate the consequences of an accident. As a minimum, all vu.ves that receive a contain-ment isolation signal or a safety injection signal shall be in-cluded in the IST program. 2.1.2 Leak Testing of Valves which Perform a Pressure Isolation Function There are several safety systems connected to the reactor coolant pressure boundary that have design pressures that are below the re-actor coolant system operating pressure. It is required that there be edundant isolation valves forming the interface between these high and low pressure systems to prevent the low pressure systems from being subjected to pressures which exceed their design limits. In this role, the valves are performing a pressure isolation func-tion. The redundant isolation provided by these valves regarding their pressure isolation function is important. It is considered neces-sary to provide assurance that the condition of each of these valves is adequate to mair.tain this redundant isolation and system integrity. For this reason it is believed tnu+ some method, such as a leak testing, should be used to assure the r condition is suf-ficient to maintain this pressure isolation funct Mn. In the event that leak testing is selected as the appropriate procedure for reaching this objective, the staff believes that the following valves should be categorized as A or AC and leak tested in accordance with IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are: Valve Valve SI-22A SI-16B SI-22 B SI-303 A SI-21A SI-303B SI-218 SI-304A SI-13A SI-304B SI-138 RHR 1A - SI-12A RHR 18 SI-12B RHR 2A SI-16A RHR 2B We have discussed this matter and identified the valves listed above to the licensee. In the resubmittal of February 9,1979, the licensee has not reviewed this request. It is again requested that the licensee respond to the possible recategorization of the indicated valves. zg

2.1.3 Containment Isolation Valves The Appendix J review for this plant is a cmpletely separate re-view from this IST program review. However, the determinations made by that review are directly applicable to the IST program. The present IST submittal should be acceptable until the Appendix J review is cmpleted. At that time, the licensee will be required to amend this IST program to reflect the conclusions of the , Appendix J review. 2.1.4 Category A Valve Leak Check Requirements for Ccntainment Isolation ' Valves (CIV) All CIVs shall be classified as Category A valves. The Category A valve leak rate test requirements of IWV-3420 (a-e) have been superceded by Appendix ' requirements for CIVs. The staff has con-cluded that the applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J. Relief from para-graph IWV-3420 (a-e) for CIVs presents no safety problem since the intent of IWV-3420 (a-e) is met by the Appendix J requirements. Sections # and g of IWV-3420 must be met by the licensee otherwise relief mu..t b2 requested from these paragraphs. It should be noted that these par 6 graphs are only applicable where a type C Appendix J leak test is perfomed. The safet, .metion of CIVs and thus passive CIVs is to perfom leak limiti.., barriers. These are valves, which are normally closed, thus in their safety position, and are not required to open to mitigate the consequences of an accident or to safely shutdown the pl ant. Therefore, the operability of these valves is inconse-quential with regard to the safety function for which they perfom. It is thus concluded that the quarterly stroke and stroke time measurement are meaningless for passive CIVs. 2.1.5 Stroke Requirements for Passive Valves These valves are normally closed and thus in tneir safety-related position, and are not required to change position, that is to open or close to mitigate the consequences of an accident or to safely shutdown the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function for which they perfo rm . It is thus concluded that the quarterly stroke and stroke time measurement are aeaningless for passive valves. 2.1.6 Valves to be Tested at Cold Shutdowns - V lve testing should commence not later than 48 hours after shut-down, and continue until cmplete or plant is ready to return to . power. Completion of all valve testing is not a prerequisite to return to power. Any testing not cmpleted at one cold shutdown should be performed during subsequent cold shutdowns to meet the Code specified testing frequency. 717 

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In the case of valves exercised less frequently than cold shutdown (i.e., refueling), relief from the Code requirement must be re-quested. T: lese cases are treated as such in this review. 2.1.7 Valve Cxercising Requirements ASME Code, Section XI, Subsection IWV-3410(a) requires that Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-1), (e), and (f). 1WV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3420(b). IWV-3700 - requires no regular testing for Ccde Category E valves. Opera-tional checks, with appropriate record entries, shall record the positicn of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code pemits the valves to be tested at cold shutdown where:

a. It is not practical to exercise the valves to the position re-quireed to fulfill their function or to the partial position during plant operation.
b. It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

2.1.8 Changes to the Technical Specifications In a Ncvember 1976 letter to the Wisconsin Public Service Corpora-tion the NRC provided an attachment entitled "HRC Staff Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that when one train of a redundant system such as in the ECCS in inoperable, nonredundant valves in the remainino train should not be cycled sir.ce their failure would cause a loss of total system function. For example, during power operation in some plants, there are stated minimum requirements for systems which make up the ECCS which allow certain limiting conditions for operation to exist at any one time and if the system is not restored to meet the requirements within the time period specified in a plant's Technical Specification the reactor is required to be put in somt. other mode. Furthermore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation. For such plants this situation would be contrary to the NRC guideline as stated in the document mentioned above. The Kewaunee Plant's Technical Specifications may have requirements that are contrary to the above mentioned guidelines. We have dis-cussed this situation with the licensee and the licensee has agreed to review the Technical Specifications and to consider the need to propose Technical Specification (TS) changes which woulu have the effect of preluding such testing. 11 1317 71"

If, after making this consideration, the licensee detemines that the TS should not be changed because the guidelines are not appli-cable or if that the guidelines cannot be followed, the licensee shall submit to the flRC the reasons that led to their determination for each potentially affected valve. In the licensee submittal , the potentially affected sections of the TS, in addition to the valves, should be identified. 2.1.9 Containment Isolation Valves In our review, w have found deviations from the containment isola-tion criteria set forth in General Design Criteria (G.D.C.) and the - requirements of Appendix J, particularly, the type C test. We have detemined that it is not in the scope of the IST program to evalu-ate the licensee's Appendix J program or the contairrnent isolation criteria set forth in G.D.C. The Appendix J review is a completely separate review, however, the detenninations made by that review are directly applicable to the IST program. The present IST submit-tal is acceptable, until the Appendix J review is cmpleted, at that time, we will require the licensee to amend his IST program to reflect the conclusions of the Appendix J review for this plant. In particular, the following valves are recmmended for review and possible classification as containment isolation valves: Valve System flG-304 Reactor Coolant System MU-1011 Reactor Coolant System SW-903A Service Water System SW-903C Service Water System SW-903C Service Water System SW-903D Service Water System SW-901A Service Water System SW-901B Service Water System SW-901C Service Water System SW-901D Service Water Systen MS-1A Main, Auxiliary Steam ard Stean Pump System MS-1B Main, Auxiliary Steam and Steam Pump System 2.2 Safety Injection System (28-M) 2.2.1 Code Relief: Category A Valves 2.2.1.1 Relief Request: Val ves SI-204, SI 9.01 A, SI-201B, SI-202A, and SI-202B will not be exercised as required by Section XI of the ASME B&PV Code. . 12 

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Code Requirement: Category A valves shall be exercised at least once every 3 months with the exceptions as shown in the following pa rag raph. Ti~ / shall be leak-tested at the same (or greater) fre-quency as scheduled refueling outages but not less than once every two years. Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant opera-tion. If only limited operation is practical during plant opera-tion the valve shall be part stroke exercised during plant opera-tion and full stroked during each cold shutdown; in case of fre-quent cold shutdcwns these valves need not be exercised more often than once every 3 months. Valves that cannot be operated during nonnal plant operation shall be specifically identifi d by the Owner and shall be full stroke exercised during each c.1d shutdown; in case of frequent cold shutdowns these valves need not be exer-cised more of ten than once every 3 months. Licensee Basis for Relief Request: This valve provides no safety function except as a containment pressure boundary in case of line ru pture. It is nonnally closed to perfonn this function, thus re-quires no exercise testing. Evaluation: Valves SI-204, SI U1B, SI-202A, and SI-202B are passive valves. Therefore, i t . . :anmended, per item 2.1.4 that relief be granted from the str % ? , requirements of the Code. 2.2.1.2 Relief Request: The stroke time of air-operated valve NG-107 will not be measured. Code Requirements: - IWV-3410(c) (2) - The stroke time of all power operated valves shall be measured to the nearest second or 10% of the maximum allowable stroke time, whichever is less, whenever such a valve is full stroke tested. Licensee Basis for Relief Request: The stroke time of this air operated valve varies depending on the air pressure at the valves and is a neaningless valve. The only meaningful measurement is the closure time for air operated isolation valves such as this one. Alternate Testing: Acceptance criteria wil1 be established and valve closure time will be measured to ensure acceptable operation. Evaluation: The measurement of " Closure" time is an acceptable al ternative to the code required " stroke" time. It is recommended - that this relief request be granted. 2.2.2 Code Relief: Category C Valves 2.2.2.1 Relief Request: Valves SI 22A, SI-22B, SI-21 A, and SI-21B will be exercised at refueling outages rather than quarterly. 13 1317

Code Requirement: Check valves shall be exercised at least once every 3 months, with the excepticns as shown in the following para-graph. Check valves shall be exercised to the position required to fulfill tMir function unless such operation is not practical during plant operation. If only limited operation is practical during plant operation the check valve shall be part stroke exercised during plant operation and full stroked during each cold shutdown. In case of frequent cold shutdowns these check valves need not be ex-ercised more of ten than once every 3 .nr ths. Check valves that ~ cannot be operated during normal plant operation shall be specific-ally identified by the Owner and shall be full stroke exercised during each cold shutdown. In case of frequent cold shutdowns these check valves need not be exercised more of ten than once every 3 months. Licensee Basis for Relief Request: Operation of these normally closed check valves will be verified n.h refueling outage. Ope ra-tion will be verified by establishing and observing flow through the individual line. Establishing flow through these check valves would introduce safety injection flow into the reactor coolant sys-tem. IWV-3410(b) states that nonnally closed valves that cannot be oper-ated during normal plant operation shall be specifically identified by the owner and exercised during each cold shutdown. The tenn 

       " cold shutdown" covers a wide variety of plant conditions which can exist wi th the reactor coolant temperature equal to, or less than, 200'F. Under cold shutdown conditions, the system may be " solid" such that introducing flow into the systen to exercise check valves would have a high probability of overpressurizing the system.

These tests can only be perfonned when the reactor coolant system is vented to the containment atmosphere and partially drained such as for a refueling. Similarly, under cold shut down conditions reactor coolant pumps may be in operation and closing normally open valves in systems sening these canponents would jeopardize their safe operation. Full open or full stroke position cannot be identified on these val ve s. Operability will be verified by obsening a tank level change, as N the case of the Accumulator discharge check valves. Evaluation: The test proposed is an acceptable proof of operabil-ity and since it can only be done when a substantial flow and level change in a task (i.e., at refueling) it is recommended that relief ~ be granted to test these valves for operability at refueling out-ages. 2.2.2.2 Relief Request: Val ves SI-12 A, SI-128, SI-13 A, SI-13B, SI-16 A, 

       $1-168, SI-303A, SI-303B, SI-304A, and SI-304B will be full-stroke exercised at refueling outages, in lieu of code requirements.

14 1317

Code Requirements: See Code Requirements, Its 2.2.2.1. Licensee Basis for Relief Request: None of these check valves should be exercised during normal plant op0 ration. They can only be tested at refueling outages by isolatirg portions of the safety injection system (making that portion unavailable in case of an accident) and creating upstream pressures higher than the Reactor Cooling System. This would introduce unconditioned water into the reactor coolant system which is unacceptable. Evaluation: The staff agrees with the licensee's basis and it is ' recommended that relief be granted to full-stroke exercise these valves at refueling outages. 2.2.2.3 Relief Request: Valves SI-6A and SI-6B will be full-stroke exer-cised at refueling outages, in lieu of code requirements. Code Requirement: See Code Requirement, Item 2.2.2.1. Licensee Basis for Relief Request: Full-stroke exercising of these valves quarterly is not practical during nomal plant operation. Evaluatior.: Check Valves SI-6A and SI-6B are on the HPSI dis-charge. The HPSI pumps are tested on miniflow. Full flow through 

           ....sa valves requires reactor shutdown. Therefore, based on the impracticality of exercising these valves during nomal plant oper-ation, relief is recmimended to full-stroke exercise them at re-fueling outages.

2.2.2.4 Relief Request: Valves SI-301A and SI-301B will be full-stroke exercised at refueling outages, in lieu of Code requirements. Code Requirements: See Code Requirments, Item 2.2.2.1. Licensee Basis for Relief Request: Full-stroke exerci sing of these valves quarmrly is not practical during normal plant operations. Evaluation: Check valves SI-301A and SI-301B are on the line from the RWST to the RHR pumps. These pumps are tested on miniflow. Full flow through these vaives from the RWST is possible only at r2 actor shutdowns. Therefore, based on the impracticality of exer-cising these valves during normal plant operation, relief is recom- 

          '1 ended to full-stroke exercise them at refueling outages.

2.3 Residual Heat Removal System (18L) 2.3.1 Code Relief: Category B Valves. ~ 2.3.1.1 Relief Request: Valves RHR-300A and RHR-3008 will be full-stroke exercised at refueling outages, in lieu of code requriements. 15 1317 m

Code Requirement: Category B valves shall be exercised at least once every 3 months with the exceptions as shown 11 the following pa rag raph. Valves sha'.1 be exercised to the position required to ful fill their function unless such operation is not practical during plant opera-tion. If only limited operation is practical during plant opera-tion the valve shall be part stroke exercised during plant opera-tion and full stroked during each cold shut; in case of frequent - cold shutdowns these valves need not be exercised more often than once every 3 months. Valves that cannot be operated during nomal plant operation shall be specifically identified by the Owner and , shall be full stroke exercised during each cold shutdown; in case of frequent cold shutdowns these valves need not be exercised more of ten than once every 3 months. Licensee Basis for Relief Request: Failure of either of these valves in an open position during operational testing would provide an open connection between the RHR system and the suction side of the SI pumps. The operating pressure of the RHR system under nomal conditions is in excess of the design pressure of the SI system suction piping and an open cross connection would prevent operation of the RHR system for it's function of nomal co61 ha of the reactor system. Evaluation: The staff agrees with the Licensees basis and it is recanmended that relief be granted as requested. 2.3.2 Code Relief: Category C Valves ?. 3.2.1 Relief Request: Valves RHR-401A and RHR-401B will be stroked at refueling outages in lieu of Code requirements. Code Requirements: See Code Requirements, Item 2.2.2.1. Licensee Basis for Relief Request: It is impractical to exercise these valves quarterly as per code requirement. Evaluation: Check valves RHR-401A and RHR-401B are located en the RHR supply line to the ICS pumps. They cannot be stroked during nomal operation because containment spray would be activated. Based on the impracticality of exercising these valves during nomal plant operation, it is reconmended that relief be granted to stroke these valves at refueling outages. Stroking will be accom-plished by flow testing of lines. Failure of flow test will also indicate failure of valves to operate unless further tests are - ac compl i shed . 2.4 Reactor Coolant System (10-N): 2.4.1 Code Relief: Category A Valves 2.4.1.1 Relief Request: Valves NG-304 and MU-1011 will not be exercised il accordance 4th the code requirements. 16 717 

                                                                          ]}]/

Code Requirement: See Code Requirenent, Item 2.3.1.1. Licensee Basis for Relief Request: These valves provide no safety function except as a containment pressure boundary in case of line ru pture. They are nomally closed and stay closed to perfom this function, thus they require no exercise testing. Evaluation: Check valves NG-304 and MU-1011 of the Reactor Cooling System are passive valves. Therefore, it is reconmended, per item 2.1.4, that relief be granted from the stroking requirements of the Code. 2.4.1.2 . Relief Request: The stroke time of air-operated valves MG-(R)-512, MR-(R)-513, NR-302 and MU-1010-1 will not be measured. Code Requirements: See Code Requirements, Item 2.2.1.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Reque st, I tem 2.2.1.2. Evaluation: The measurement of ' closure" time is an acceptable alternative to the Code required " stroke" time. It is recommended that this relief request be granted. 2.5 Waste Disposal System (131FF) 2.5.1 Code Relief: Category A Valves 2.5.1.1 Relief Request: The stroke time of air-operated valves MG-(R)-503, MG-(R)-504, MG-(R; 509, MG-(R)-510, RC-507, RC-508, M0-(R)-134, M0-(R)-135 will not be measured. Code Requirement: See Code Require ent, Item 2.2.1.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Request, Item 2.2.1.2. Evaluation: The measurement of " closure" time is an acceptable alternative to the code requireri " stroke" time. It is reconmended that this relief request be granted. 2.6 Sampling System (44-G) 2.6.1 Code Relief: Category A Valves 2.6.1.1 Relief Request: The stroke time of air-operated RC-402, RC-403, RC-412, RC-413, RC-422, and RC-423 valves will not be measured. Code Requirements: See Code Requirenents, Item 2.2.1.2. 17 1317 " '

Licensee Basis for Relief Recuest: See Licensee Basis for Relief Request, Item 2.2.1.2. Evaluation: The measurement of " closure" time is an acceptable alternative to the code required " stroke" time. It is recommended that this relief request be granted. 2.7 Chemical and Volume Control System (CVCS) , 2.7.1 Code Relief: Category A Valves 2.7.1.1 Relief Request: The stroke time of air-operated valves LD-4A, - LD-4B, LD-4C will not be measured. Code Requirement: See Code Requirenent, Itan 2.2.1.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Request, Item 2.2.1.2. Evaluation: The measurement of " closure" time is an acceptable alternative to the code sp s fied " stroke" time. It is recommended that this relief request be granted. 2.7.1.2 Relief Request: Valve LD will be full stroke exercised at re-f ue l i ng ou tages. Valve stroke time of this valve will not be measured. Code Requirement: See Code Requirements, Item 2.2.1.1. See Code Requi renent, Item 2.2.1.2. Licensee Basis for Relief Request: This CVCS valve must remain open as long as the Reactor Coolant pumps are running. The stroke time of this air operated valve is variable depending on the air pressure at the valves and is a meaningless valve. The only meaningful measurement is the closure time for air operated isola-tion valves such as this one. Alternate Testing: Acceptance criteria will be established and valve ciisce time will be measured to ensure acceptable operation. Evaluation: Valve LD-6 is on the line to the letdown heat ex-changer, and as such, it should not be closed during normal plant operation. If this valve were to fail closed, it could cause re-actor shutdown. Due to the impracticality of exercising this valve quarterly, it is recommended relief be granted to pennit full-stroke exercising at refueling outages. The stroke time of this - air operated valve is variable depending on the air pressure at the valves and is a meaningless vahe. The only meaningful measurement is the closure time for air operated isolation valves such as this , one. Alternate Testing: Acceptance criteria will be established and valve closure time will be measured to ensure acceptable opera-tion. 18 1317

2.7.1.3.1 Relief Request: Valves CVC-211 and CVC-212 will be full stroke ex-ercised at refueling outages. Code Requirement: See Code Requirement, Item 2.2.1.1. Licensee Basis for Relief Request: These CVCS valves must remain open as long as the Reactor Coolant pumps are nJnning. Evaluation: Valves CVC-211 and CVC-212 are motor operated valves of the CVCS. A cessation of flow caused by stroking these valves affects the seal water to the Reactor Coolant pumps. A change in seal water flow could damage these pumps, therefore, partial strok-ing or full stroking at quarterly intervals is not practical . Based on the above, it is recommended that relief be granted to full stroke exercise these valves at refueling outages. 2.7.1.3.2 Relief Request: Valve stroke time of valve CVC-211 and CVC-212 will not be measured. Code Requirement: See Code Requirement, Item 2.2.1.'. Licensee Basis for Relief Request: The stroke time of these valves is only a few seconos. When timing these valves, reaction time for the person timing the valves is a major error. Evaluation: These valves are 3" motor operated valves. The licen-see states that stroking time is low enough such that reaction time for the timer significantly affects stroking time. However, the licensee fails to give actual data to justify his claim. There-fore, until such time that additional justification from the licensee is received, reviewed and acted upon, it is recmmended that relief for timing be denied. 2.7.1.4 Relief Request: Valves CVC-205A and CVC-2058 will not be exer-cised, but they will be leak tested at refueling outages. Code Requirement: See Code Requirment, Item 2.2.1.1. Licensee Basis for Relief Request: These check valves reain in an open position during all pnases of plant operation and remain open to fulfill their function following an incident. Alternate Testing: (i) The Service Water System piping for the fan coil coolers wilich are located within containment shall ~ be inspected for leakage during each major refueling outage. The 

.            inspections shall be performed by closure of the fan coil cooler outlet isolation valve during nonnal operation of the service water supply system and visually inspecting the piping within contain-ment.    (ii) The total leakage fra the systs piping within cor.-

tainment shall not exceed one gallon per hour. (iii) Any repairs necessary to neet this specified leak rate shall be accmplished prior to resumption of power operation. 1" 19 

                                                                      ){]

Evaluation: Check valves CVC-205A and CVC-205B of the Chemical and Control Volume System are passive valves. Therefore, it is recom-mended, per Item 2.1.4, that relief be granted fra the stroking requirements of the Code. Due to the fact that these valves cannot be pressurized on one side to leak check, it is recmmended that the licensee's proposal for leak checking be accepted. 2.7.1.5 Relief Request: Valve LD-60 will not be leak tested in accordance wi th Code requirements. Code Requirements: See Code Requirment, Item 2.2.1.1. Licensee Basis for Relief Request: This CVCS valve must remain open as long as the Reactor Coolant pumps are running. Leak Testing: The Chemical and Volume Control Charging System pip-Ing fra the charging pump discharge to the Reactor Coolcnt System shall be inspected for leakage during the startup following each major refueling outage when the charging system is in service and the Reactor Coolant System is at normal temperature and pressure. Leakage shall be detennined by visual inspection. Evaluation: The leak testing that the licensee describes for valve LD-60 does not adequately insure that this valve is leak tight and it is recmmended that relief for leak testing be deined and that this valve be tested to code requirements. 2.8 Service Water System (202-QQ) 2.8.1 Code Relief: Category A Valves 2.8.1.1. Relief Request: Valve SW-6MO will not be exercised, but it will be leak tested at refueling outages. Code Requirement: See Code Requirment, Item 2.2.1.1. Licensee Basis for Relief Request: This valve provides no safety function except as a containment isolation pressure boundary in case of time nJpture. It is nonnally closed and stays closed to perform this function, this requires no exercise testing. Evaluation: Valve SW-6010 of the Service Water System is a passive valve. Therefore, it is recommended, per item 2.1.4, that relief be granted from the stroking requirements of the Code. . 2.8.1.2.1 Relief Request: Val vas SW-901 A, SW-901B, SW-901C, and SW-901D will not be full stroke exercised quarterly as per code requirements. , Code Reouirement: See Code Requirment, Its 2.2.1.1. 20 7'7 7

Licensee Basis for Relief Request: These check valves remato in an open position curing all phases of plant operations and remain open to fulfill their function following an incident. Evaluation: Check valves SW-901 A, SW-9018, . SW-901C, and SW-901D are passive valves. Therefore, it is recommended, per item 2.1.4 that relief be granted from the stroking requirements of the Code. 2.8.1.2.2 Relief Request: Valves SW-901 A, SW-901B, SW-901C and SW-901D will not be leak checked in accordance with code requirements. . Code Requirement: See Code Requirement, Item 2.2.1.1. Licensee Basis for Relief Request: These check valves remain in an open position during all phases of plant operations and reain open to fulfill their function following an incident. Alternate Testing: The Service Water System piping for the fan coil coolers which are located within contaiment shall be in-spected for leakage during each major refueling outage. The inspections shall be perfomed by closure of the fan coil cooler outlet isolation valve during nomal operation of the service water supply system and visually inspecting the 11 ping within contain-ment. Evaluation: The leak testing that the licensee describes does not adequately assure that these valves are leak-tight. Therefore, it is recommended that relief for leak testing valves SW-901A, SW-901B, SW-901C, and SW-9010 be denied at tnis time and that these valves be tested to Code requirements. 2.8.2 Code Relief: Category B Valves 2.8.2.1 Relief Request: Valves SW-1300A and SW-13008 will be full-stroke exercised at refueling outages, in lieu of Code requirments. Code Requirement: See Code Requirment, Item 2.3.1.1. Licensee Basis for Relief Request: Cooling of the CC heat ex-changers is nomally accmplished by 4-inch bypass valves. Opening of these 10 inch valves could cause themal shock to the heat ex-changers and thereby the Reactor Coolant Pumps. Evaluation: These valves are normally closed and should not be opened during nomal operation since this would reduce temperatures . in the heat exchangers and cause shock as described by the Licen-see. It is recmmended that this relief request be granted. 2.9 Reactor 3nd Shield Building Ventilation (M602-Q) 2.9.1 Code Relief: Category A Valves 21 }3}7

2.9.1.1 Relief Request: Valve stroke time for valves AS-1, AS-2, and AS-32 w111 not be measured. Code Pequirement: See Code Requi . .... ant, Item 2.2.1.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Reque st, I tem 2.2.1.2. 

                                                                                      ~

Evaluation: The measurement of " closure" time is an acceptable alternative to the code specified " stroke" time. It is recommended that this relief request be granted. , 2.9.1.2 Relief Request: Valve stroke time for valves RBV-1, RBV-2, RBV-3, RSV-4, VB-10A, and VB-10B will not be measured. Code Requirement: See Code Requirement, Item 2.2.1.2. Licensee Basis for Relief Request: See Licensee Basis for Relief Reque st, I tem 2.2.1.2. Evaluation: The measurement of " closure" time is an acceptable alternative to the code specified " stroke" time. It is recommended that this relief request be granted. 2.10 Secondary Sampling Systems (M219-N) 2.10.1 CodeRelig: Category B Valves 2.10.1.1 Relief Request: Valve stroke time for valves BT-31B, BT-32B, BT-31 A, and BT-32A will not be measured. Code Requirement: See Code Requirement, Item 2.2.1.2. Licensee Basis for eklief Request: See Licensee Basis for Relief Reque st, I tem 2.2.1.2. Evaluation: The measurement of " closure" time is an acceptable alternative to the code specified " stroke" time. It is recommended that this relief request be granted. 2.11 Instrument Air System 2.11.1 Cod" Relief: Category A Valves 2.11.1.1 Relief Request: Valves IA-102 and IA-103 will not be tested other than Append 1x J leak testing at refueling outages.

  • Code Requirement: See Code Requirement, Item 2.2.1.1.

1317

Licensee Basis for__ Relief Request: The only safeguard function re-quired for these cFeWyalves is to provide containment isolation. Operability tests are not perfomed during plant operation or shut-down o nce these lines are required to be open. Evaluation: Leak checking valves IA-102 and 11-103 at refueling outages also includes exercising them to the position required for safety. These valves must remain open at all times. Based on the impracticality of exercising these valves quarterly, it is recom-mended that relief be granted as requested. - 2.12 Internal Containment Spray System (M217-T) 2.12.1 Code Relief: Category C Valves 2.12.1.1 Relief Request: Valves ICS-4A, ICS-4B, ICS-3A, and ICS-3B will be part-strokea quarterly. Code Requirement: See Code Requirement, Item 2.2.2.1. Licensee Basis for Relief Recuest: The operation of these check valves will be partially verified during performance testing of the pumps. These valves are of a split disc design and the low flow at pump test conditions will only require limited actuation of the valves. Evaluation: Check valves ICS-3A and ICS-3B are Containment Spray Pump Suction valves and must be part-stroke exercised monthly dur-ing performance testing of the ICS pumps. These valves and check valves ICS-4A and ICS-4B cannot be full-stroke exercised due to the fact that water would be sprayed into containment. Since these valves exist, with similar stroke problems, in otner plants it is recommended that the staff review the system unavailability of only part stroking these valves. To this end, it is recommended that this item remain open until further study is completed. 2.12.1.2 Relief Request: Valves ICS-8A and ICS-8B will nat be full stroke exercised as per Code requirements. Code Requirements: See Code Requirements, Item 2.2.2.1. Licensee Basis for Relief Request: Check valves ICS-8A and ICS-8B are on the ICS discharge line to the spray header. These valves are the final valves before entering containment. They cannot be even partially stroked otherwise water would be sprayed into con-tainment. Due to the split disc design of these valves, utilizing a compressible gas would provide assurance of only minimal movement of the valve discs. Alternate Testing: These check valves will be physically inspected to observe freedom of disc movement every five years. 23 l3l[

Evaluation: The staff agrees that testing these valves by flowing through them is impractical . The alternate proposed should be acceptable, as being better than no test at all . (Licensee first proposal). The adequacy of the test interval is unknown at this time. Too frequent a test interval will carry with it a higher possibility of incorrect re-assembly of the valves. It is recom-mended that the staff review this interval with the PAS branch be-fore granting approval for a five year cycle. , 1317 731 24

3.0 COLD SHUTDOWN TESTING OF VALVES

3.1 General

3.1.1 Valves shal' De exercised to the position required to fulfill their function unless such operation is not practical during plant opera-tion. If only limited operation is practical during plant opera-tion, the valve shall be part-stroke exercised during plant oper- - ation arut full-stroke exercised during cold shutdowns. Valves that cannot be exercised during plant operation shall be full-stroke exercised during cold shutdowns. Full-stroke exercising during . cold shutdowns for valves not full-stroke exercised during plant operation shall be on a frequency detennined by the intervals between shutdowns as follows: for intervals of 3 months or longer, exercise during each shutdown; for intervals of less than 3 months, full-stroke exercise is not required unless 3 months have passed since last shutdown exercise. The intent of this section is to satisfy the requirements of the NRC letter dated January 13, 1978, i.e., "NRC Stsff Guidance For Preparing Pump and Valve Testing Program Descriptions and Asso-ciated Relief Requests Pursuant to 10 CFR 50.55 a(g)," specific-ally section 5, page 7. 3.2 Residual Heat Removal System (18-L) 3.2.1 Category B Valves 3.2.1.1 Valves: RHR-1A, RHR-1B, RHR-2A, and RHR-2B. Code Requirement: See Code Requirement, Item 2.3.1.1. Licensee Basis: The RHR system oterating pressure limits prohibit operation of these valves above 400 psig. Evaluation: Valves RHR-1A, RHR-1B, RHR-2A and RHR-28 of the RHR system cannot be partial or fully stroked during normal operations due to the fact they serve as pressure isolation valves and cannot be opened at system pressures which are above 400 psig. Since it is not practical to test these valves during normal operation, it is recommended, per NRC guidelines, to allow full-stroke exercising of these valves at cold shutdowns. 3.2.2 Catecory C Valves 3.2.2.1 Valves: RHR-3A, RHR-3B, RHR-5A, and RHR-5B. Code Requirement: See Code Requirement, Item 2.2.2.1. Licensee Basis: The RHR system operating pressure limits prohibit operation of these valves above 400 psig. 25 779 3 7

Evaluation: Valves RHR-3 A, RHR-38, RHR-SA, and RHR-5B of the RHR system cannot be partial or fully stroked during normal operations due to the fact they serve as pressure isolation valves and cannot be opened at system pressures which are above 400 psig. Since it is not practical to test these valves during nonnal operation, it is recommended, pe: NRC guidelines, to allow full-stroke exercising of these valves at cold shtudowns. 3.3 Chemical and Volume Control System (35-J) - 3.3.1 Category A Valves 3.3.1.1 plve: LD-60 Code Requirement: See Code Requirement, Item 2.2.1.1. Licensee Basis: This CVCS systen valve must renain open as long as the Reactor Coolant pumps are running. Evaluation: Valve LD-60 is on the line from the Residual Heat Re-moval Heat exchangers, and as such, it should not be closed during normal plant operation. If this valve were to fail closed, it could cause reactor shutdown. Since it is not practical to test this valve during nonnal operation, it is recommended, per NRC guidelines, to allow full-stroke exercising at cold shutdowns. 3.4 Service Water System (202-QQ) 3.4.1 Category C Valves 3.4.1.1 valves: SW-501A and SW-501B Code Requirement: See Code Requirenent, Item 2.2.2.1. Licensee Basis: These valves cannot be exercised during nonnal operation. Evaluation: Valves SW-501 A and SW-5018 allow service water to flow to the auxiliary feedwater pumps. These valves should not be exer-cised unless the auxiliary feedwater pumps are operating. These pumps are for energencies only and should not be operated during normal plant operation. Based on the impracticality of exercising these valves during nonnal plant operation, it is reconmended, per NRC guidelines, to allow full stroke exercising of these valves at cold shutdowns. 

                                                                             ~

3.5 Reactor and Shield Building Ventilation (M602-Q) 3.5.1 Category A Valves , 26 1317 79

3.5.1.1 Valves: RBV-1, RBV-2, RBV-3, RBV-4, VB-10A, and VB-10B. Code Requirement: See Code Requirement, Item 2.2.1.1. Licensee Basis: These valves cannot be stroked quarterly due to the fact that upon opening these valves, containment is vented to the atmosphere. Evaluation: Valves RBV-1, RBV-2, RBV-3, RBV-4, VB-10A, and BV-10B cannot be full stroke exercised quarterly since opening these valves would allow contaiment atmosphere to leak into the atmos- - phere which is undesireable. Based on the above, it is recom-mendcd, per NRC guidelines, to allow full stroke exercising these valves at cold shutdowns. 3.6 Main, Auxiliary Steam and Steam Dump System (M203-Z-1) 3.6.1 Category A Valves: 3.6.1.1 Valves: MS-1A and MS-1B Code Requirement: See Code Requirement, Item 2.2.1.1. Licensee Basis: These main steam valves occasionally require valve stem packing adjustment. These adjustments are perfomed during plant operation and do not allow full-stroke testing. Evaluation: These v.lves are on the main steam line whose flow should never be internJpted during nomal plant operation, due to the possiblity of causing reactor trip. It is recommended, per NRC guidelines, to allow full stroke exercising at cold shutdowns. 3.7 Feedwater System (M205-X) 3.7.1 Category B Valves 3.7.1.1 Valves: FW-12A and FW-12B Code Requirement: See Code Requirenent, Item 2.3.1.1. Licensee Basis: These feedwater isolation valves occasionally re-quire valve stem adjustments. These adjustments are perfomed dur-ing plant operation and do not allow full-stroke testing. Evaluation: Valves FW-12A and FW-128 are on the line to the steam genera to rs . It is not desirable to interrupt flow to these steam generato rs. Based on the possibility of reactor trip, it is recem-mended, per NRC guidelines, to allow full-stroke exercising at cold shutdowns. 3.7.2 Category C Valves 27 774 

                                                                           ]}}/

3.7.2.1 Valves: AFW-4 A, AFW-4B, AFW-1 A, AFW-1B, a nd AFW-1C. Code Requirement: See Code Requirement, Item 2.2.2.1. Licensee Basis: Operation of these nonnally closed check valves will be verified by establishing and observing flow through the individual line prior to startup of the plant. Evaluation: Valves AFW-4A and AFW-4B allow auxiliary feedwater to

  • go to steam generators. Valves AFW-1 A, AFW-1B and AFW-1C are located at the auxiliary feedwater pump discharge. It is not de-sirable to operate the auxiliary feedwater system during normal -

plant operation. Based on the impracticality of operating these valves during normal plant operation, it is recommended, per NRC guidelines, to allow full-stroke exercising these valves at cold shu tdowns . 77" 1317 O 28

4.0 PROGRAM BREAKDOWN 4.1 Safety Injection System (-28M, -29E) 4.1.1 The following a.*e valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category SI-20A E SI-3 E SI-20B E SI-300A B - SI-11A E SI-300B B SI-11B E SI-350A A SI-15A B SI-350B A SI-15B B SI-351A A SI-106A C SI-351B A SI-106B C SI-106A C 51-312 C SI-106B C SI-9A E SI-201A A St-4A B SI-201B A SI-4B B SI-202A A SI-2A B SI-202B A SI-2B B 4.1.? The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category Valve Category SI-106A C SI-201B A SI-106B C SI-202A A SI-201A A SI-202B A 4.1.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as beng non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Val ve Testing. . . ," dated January 13, 1978). Valve Valve SI-9B SI-302A SI-5A SI-302B SI-5B 4.1.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category SSI-22A C 551-304B C 551-22B C SI-201A A SSee Item 2.1.2 29 77(

Valve Category Valve, Category SSI-21 A C SI-2018 A SSI-218 C SI-202A A SSI-13 A C SI-202B A SSI-138 C NG-107 A SSI-12 A C SI-6A C SSI-12B C SI-6B C SSI-16 A C SI-301 A C , SSI-16B C SI-301B C SSI-303A C SI-204 A SSI-303B C SSI-304A C , 4.2 Residual Heat Removal System (-18L) 4.2.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirenent. Valve Category Valve Category RHR-33 C RHR-11 AE RHR-400A B RHR-401A C RHR-400B B RHR-401B C 4.2.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category Valve Category RHR-401 A C RHR-4018 C 4.2.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Valve Testing. . . ," dated January 13, 1978). Valve Valve RHR-8A RHR-101 RHR-8B RC over-pressure relief 4.2.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Valve Category Valve ' Category - RHR-1A B RHR-3 A C RHR-1B B RHR-3B C - RHR-2 A B RHR-5A C RHR-2B B RHR-5B C 55ee Item 2.1.2. 777

4.2.5 The following are valves in tt.e IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category RHR-300A B RHR-401A C RHR-300B B RHR-401B C 4.3 Reactor Coolant System (10-N) 4.3.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category PR-3A C PR-3B C 4.3.2 The following are valves in the IST submittal that cannot meet the requirenents of Section XI and relief has been requested. Valve Category Valve Category NG-304 C MG-(R)-513 A MU-1011 C NG-302 A MG-(R)-512 A MU-1010-1 A 4.4 Waste Disposal System (-131FF) 4.4.1 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category MG-(R)-503 A RC-507 A MG-(R)-504 A RC-508 A MG-(R)-509 A MD-R-134 A MG-(R)-510 A MD-R-135 A 4.5 Sampling System (44-G) 4.5.1 The following are valves in the IST submittal that cannot meet the requirements of Section XI ar.d relief has been requested. Valve Category Valve Category 

.       RC-402            A                   RC-413            A RC-403            A                   RC-422            A RC-412            A                   RC-423            A 31 77"
                                                                      ]}}/

4.6 Chemical and Volume Control System (35-J) 4.6.1 The following are val'ies in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Valve Category LD-60 A 4.6.2 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. . Valve Category Valve Category LD-6 A LD-4A A CVC-212 A LD-4 B A CVC-211 A LD-4C A CVC-205A AC LD-60 A CVC-205B AC 4.7 Auxiliary Cooling System (19-G1) 4.7.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valvc Category CC-400A B CC-400B B 4.7.2 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Val ve Testing.. . ," dated January 13, 1978). Valve Valve CC-601A CC-612B CC-601B CC-612C CC-601C CC-6120 CC-601D CC-653 CC-612A CC-651 4.8 Service Water System (-202-QQ) 4.8.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. 32 1317

Valve Category valve Category SW-903 A B SW-301A B SW-903B B SW-301B B SW-903C B SW-901 A C SW-9030 B SW-901B C SW-601A B SW-901C C SW-601B B SW-901D C - SW-502 B SW-301A B SW-4A B SW-301B B SW-4B B 4.8.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category Valve Category SW-901 A C SW-9010 C SW-901B C SW-301A B SW-901C C SW-301B B 4.8.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Valve Testing. . . ," dated January 13, 1978). Valve Valve SW-900A SW-900C SW-900B SW-9000 4.8.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Addi tional information is required by the NRC to verify the impracticality of full stroke exercised every 3 months. Valve Category SW-501A C SW-501B C 4.8.5 The following are valves in the IST submittal that cannot Peet the requirements of Section XI and relief has been requested. Valve Category Valve Category SW-6010 A SW-901D AC SW-901A AC SW-1300A B SW-901B AC SW-1300B B SW-901C AC 33 1317 7M

4.9 Reactor Building Vent System (M403-D) 4.9.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category RBV-14-1 A LOCA-3A A RBV-14-2 A LOC A-3 B A LOCA-2A A LOCA-10A A LOC A-2 B A LOC A-10B A 4.10 Reactor and Shield Building Ventilation (M602-Q) 4.10.1 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI. Valve Category Valve Category RBV-1 A RBV-4 A RBY-2 A BV-10A A RBV-3 A BV-10B A 4.10.2 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category AS-1 A RBV-3 A AS-2 A RBV-4 A AS-32 A VB-10A A RBV-1 A VB-10B A RBV-2 A 4.11 Main. Auxiliary Steam and Steam Dump System (M203-Z-1) 4.11.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category BT-2A A SD-1A2 C BT-28 A SD-1A3 C BT-3 A A SD-1A4 C BT-3B A SD-1 A5 C . MS-100A B SD-181 C MS-1008 B SD-182 C MS-102 B SD-1B3 C , MS-101A B S0-184 C MS-101B B SD-1B5 C SD-1A1 C 34 TdI 3}}

4.11.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category MS-102 A MS-101A B MS-101B B 4.11.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Val ve Testing.. . ," dated January 13, 1978). Valve Valve MS-2A MS-2B 4.11.4 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirsuents of Section XI. Valve Category MS-1A B 14S-1 B B 4.12 Secondary Sampling System (M219-N) 4.12.1 The following are valves in the Ist submittal that cannot meet the requirements of Section XI and relief has been requested. Valve Category Valve Category BT-31A B BT-32A B BT-31B B BT-328 B 4.13 Feedwater System (M205-X ) 4.13.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category 

-                          AFW-10A              B AFW-10B              B 1317 7M' 35

4.13.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category Valve Category AFW-1A C AFW-10A B AFW-1B C AFW-108 B AFW-1C C 4.13.3 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements af , Section XI. Valve Category Valve Category FW-12A B AFW-1 A C FW-12B B AFW-1B C AFW-4A C AFW-1C C AFW-4B C 4.14 Instrument Air System 4.14.1 The following valve was listed in the IST submittal and was deleted from the IST program as being non-safety related ( safety related as defined by "NRC Staff Guidance For Preparing Pump / Valve Test-i ng . . . ," da ted J a nua ry 13, 1978). Valve IA-101 4.14.2 The following are valves in the IST submittal that cannot meet the reuirements of Section XI and relief has been requested. Valve Category IA-102 AC IA-103 AC 4.15 Internal Containment Spray System (M217-T) 4.15.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement. Valve Category Valve Category . ICS-5A B ICS-6A B IC S-5 B B IC S-6 B B , 36 )))]

4.15.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore have been added to the resubmittal as shown. Valve Category IC S-4 A C ICS-48 C e 4.15.3 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-safety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Val ve Testing.. . ," dated January 13, 1978). Valve CI-1003 CI-1001A CI-1001B 4.15.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requestec. Valve Category Valve Category ICS-3A C ICS-4B C IC S-3 B C IC S-8A C ICS-4A C ICS-8B C 4.16 Service Air System 4.16.1 The following are valves that were listed in the IST submittal and were deleted from the IST program as being non-saety related (safety related as defined by "NRC Staff Guidance For Preparing Pump / Valve Testing.. . ," dated January 13, 1978). Valve Valve SA-471 SA-472 1317 "# 37

Conclusion The Inservice Testing Program submitted by the Wisconsin Public Service Corporation for the Kewaunee Nuclear Power Plant, and modified by this evalua-tion report is in general conpliance with the requirenents of Section XI of the 1974 Edition and Addenda through the Summer of 1975 of the ASME Boiler and . Pressure Vessel Code as required by 10 CFR 50.55 a(g), and NRC Staff guidance letters and briefings. Those items not found to be in compliance with the above require further evaluation. , 

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p 38

Acknowledgement The authors would like to acknowledge Mr. Thomas Schwork's assistance in researching and preparing this report. 13 \ 7 e 39

DISTRIBUTION E. Adensam 1 R. Cerbone 1 P. Check 1 C. Cheng 5 A. Copoola 1 G. Edison 1 D. Eisenhut 1 B. Grimes 1 R. Hall 2 W. Kato 1 G. Lainas 1 V. Lettieri 3 V. Noonan 1 W. Osborne 1 T. Restivo 1 V. Stello 1 T. Schwork 1 T. Telford 1 H. Todosow 2 A. Wang 1 NRC - Division of Technical Information and Control 2 

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