IR 05000305/2007001

EOC Annual Assessment Letter (Report 05000305-07-001)

ML070610250
Person / Time
Site:	Kewaunee
Issue date:	03/02/2007
From:	Satorius M Division Reactor Projects III
To:	Christian D Dominion Energy Kewaunee
References
IR-07-001 IR-07-001
Download: ML070610250 (7)

Text

rch 2, 2007

SUBJECT:

ANNUAL ASSESSMENT LETTER - KEWAUNEE POWER STATION (REPORT 05000305/2007001)

Dear Mr. Christian:

On February 13, 2007, the Nuclear Regulatory Commission (NRC) staff completed its performance review of Kewaunee Power Station. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2006. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated as "Exempt from Public Disclosure in Accordance with 10 CFR 2.390" and marked as "Official Use Only - Security-Related Information" will include the physical protection review and resultant inspection plan.

Overall, Kewaunee Power Station operated in a manner that preserved public health and safety and met all cornerstone objectives with moderate degradation in safety performance. Plant performance for the most recent quarter was within the Regulatory Response Column of the NRCs Action Matrix due to one White PI in the Initiating Events Cornerstone.

On February 28, 2007, we were notified by your staff that your current reviews of corrective actions for the White PI would not be completed for several weeks. Therefore, we will conduct a supplemental inspection 95001 at a time to be determined, pending completion of your root cause analysis. The focus of this inspection will be the actions you have taken to correct the causes of the White PI.

While plant performance for the most recent quarter is within the Regulatory Response Column, Kewaunees safety performance for the first 3 quarters of the 2006 assessment period was within the Degraded Cornerstone Column of the NRCs Action Matrix. This was based on one inspection finding being classified as having low to moderate safety significance (White), and one finding being classified as having substantial safety significance (Yellow), both findings within the Mitigating Systems Cornerstone. The White finding involved the failure to provide adequate design control of the auxiliary feedwater system to ensure that the pumps would have been protected from failure due to air entrainment during tornado or seismic events, or from failure during potential runout conditions. The Yellow finding involved the failure to provide adequate design control to ensure that Class I equipment was protected against damage from tornado or seismic-induced flooding of the turbine building.

A 95002 supplemental inspection was conducted in May 2006, in response to these findings, and concluded that the NRC did not have adequate assurance that the planned corrective actions were sufficient to address the causes of the performance deficiencies associated with the violations. Consequently, these findings remained open. A followup 95002 supplemental inspection was conducted in August 2006, and concluded that adequate actions had been taken by Kewaunee to address deficiencies identified during the original 95002 inspection in May 2006. As a result, the two findings were closed and Kewaunee was removed from the Degraded Cornerstone Column on October 1, 2006.

Additionally, during this assessment period, the staff has continued to identify substantive cross-cutting issues in the areas of problem identification and resolution (PI&R) and human performance. The substantive cross-cutting issue in the PI&R area is a continuation of the cross-cutting issue discussed in our Mid-Cycle Assessment Letter, dated August 31, 2006, and first opened in our Annual Assessment Letter for 2004, dated March 2, 2005. During this assessment period, there were 11 inspection findings that were attributable, at least in part, to weaknesses in PI&R. Based on six of these findings sharing the common aspect of inadequate problem evaluation, the substantive cross-cutting issue in the area of PI&R will remain open.

This substantive cross-cutting issues will remain open until the number of findings with the same cross-cutting aspect is reduced or when the NRC gains confidence in the performance of your corrective action program to evaluate and correct problems. The NRC plans to evaluate your progress through routine baseline inspections, trend reviews, and an expanded biennial PI&R inspection in April 2007.

In our Mid-Cycle Assessment Letter, dated August 31, 2006, we advised you of a substantive cross-cutting issue in the area of human performance. During this assessment period, there were 11 inspection findings that were attributable, at least in part, to weaknesses in human performance, 5 of which were identified in the most recent 2 quarters. Based on seven findings sharing the common aspect of failure to follow procedures, and four findings sharing the common aspect of failure to provide complete, accurate, and up-to-date procedures, the substantive cross-cutting issue in the area of human performance will remain open. This substantive cross-cutting issue will remain open until the number of findings with the same cross-cutting aspect is reduced or when the NRC gains confidence in your ability to identify and correct human performance issues.

Because this end-of-cycle assessment is the fourth consecutive assessment letter identifying a substantive cross-cutting issue in the PI&R area, the Region will hold a public meeting with you in April. The purpose of the meeting will be to discuss your scope of effort and progress, to date, in addressing both substantive cross-cutting issues. We would also like to understand further action that you will take to ensure the repetitive nature of the substantive cross-cutting issues is addressed.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through June 30, 2008. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature.

The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle assessment review.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS) accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Patrick Louden at 630-829-9627 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Mark A. Satorius, Director Division of Reactor Projects Docket No. 50-305 License No. DPR-43 Enclosure: Kewaunee Power Station Inspection/Activity Plan cc w/encl: L. Hartz, Site Vice President C. Funderburk, Director, Nuclear Licensing and Operations Support T. Breene, Manager, Nuclear Licensing L. Cuoco, Esq., Senior Counsel D. Zellner, Chairman, Town of Carlton J. Kitsembel, Public Service Commission of Wisconsin State Liaison Officer, State of Wisconsin Mayor of Kewaunee City Council President Chair, Manitowoc County Board County Executive Chair, Kewaunee County Board Director, Manitowoc County Emergency Management Agency Director, Kewaunee County Emergency Management Agency City Manager of Two Rivers Village President of Mishicot INPO