IR 05000305/2012008

IR 05000305-12-008, 09/10/2012-09/28/012, Kewaunee Power Station, NRC Problem Identification and Resolution

ML12307A132
Person / Time
Site:	Kewaunee
Issue date:	11/01/2012
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Heacock D Dominion Energy Kewaunee
References
IR-12-008
Download: ML12307A132 (39)

Text

ber 1, 2012

SUBJECT:

KEWAUNEE POWER STATION, NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000305/2012008

Dear Mr. Heacock:

On September 28, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Kewaunee Power Station. The enclosed inspection report documents the inspection results, which were discussed at an exit meeting on September 28, 2012, with Mr. A. Jordan and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the team concluded that, overall, the Corrective Action Program at Kewaunee Power Station was effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the Corrective Action Program. Issues entered in the Corrective Action Program were prioritized and evaluated based on plant risk and uncertainty. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the Corrective Action Program and appropriately evaluated. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments, audits, and effectiveness reviews were found to be conducted at appropriate frequencies with sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Kewaunee Power Station. Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised. Although implementation of the Corrective Action Program was determined to be effective overall, based on the samples reviewed, one finding of very low safety significance (Green) was identified during this inspection. The finding was also determined to involve a violation of NRC requirements. However, because of its very low safety significance and because the issue was entered into your Corrective Action Program, the NRC is treating this as non-cited violation in accordance with Section 2.3.2 of the NRC Enforcement Policy. In addition, the team identified several issues that were either minor in nature and/or represented potential weakness of your program, warranting your attention.

If you contest the subject or severity of a non-citied violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Kewaunee Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-305 License No. DPR-43

Enclosure:

Inspection Report No. 05000305/2012008 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-305 License Nos: DPR-43 Report Nos: 05000305/2012008 Licensee: Dominion Energy Kewaunee, Inc.

Facility: Kewaunee Power Station Location: Kewaunee, WI Dates: September 10 through September 28, 2012 Team Leader: R. Ng, Project Engineer Inspectors: K. Barclay, Resident Inspector R. Winter, Reactor Engineer J. Neurauter, Reactor Inspector Approved by: K. Riemer, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000305/2012008; 09/10/2012 - 09/28/2012; Kewaunee Power Station;

NRC Problem Identification and Resolution.

This inspection was performed by three region-based inspectors and the Kewaunee Resident Inspector. One finding of very low safety significance (Green) was identified by the inspectors.

The finding was determined to involve a Non-Cited Violation (NCV) of NRC requirements. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. Assigned cross-cutting aspects were determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems On the basis of the samples selected for review, the team concluded that, overall, the Corrective Action Program at Kewaunee Power Station was effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the Corrective Action Program. Issues entered in the Corrective Action Program were prioritized and evaluated based on plant risk and uncertainty. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the Corrective Action Program and appropriately evaluated. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, the licensees self-assessments, audits, and effectiveness reviews were found to be conducted at appropriate frequencies with sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Kewaunee Power Station. Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised.

Although implementation of the Corrective Action Program was determined to be effective, overall, one finding of very low safety significance (Green) was identified by the inspectors.

The finding was also determined to involve non-citied violation of NRC requirements. In addition, the inspectors identified several issues that were either minor in nature and/or represented potential weakness of the program.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

• Green: The inspectors identified a finding of very low safety significance (Green)and an associated non-citied violation of 10 CFR Part 50, Appendix B, Criterion III,

Design Control, because the licensee failed to ensure that the configuration of the safeguards battery racks was in accordance with the design basis Seismic Category I qualification. Specifically, the Seismic Category I qualification specified that the battery rack end rails be snug against the battery. The inspectors found gaps greater than 1/8 inch and up to approximately 3/8 inch. The vendor instructions directed that the rails should be within 1/8 inch. The licensee entered this into the Corrective Action Program as CR489958 and CR487875 and took short term corrective actions to adjust the battery rack end gaps to within 1/8 inch, and assigned an apparent cause evaluation, which was not complete at the end of the inspection period.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of protection against external factors and affected the cornerstone objective to ensure the availability, reliability, and Corrective Action Programability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to ensure that the batteries were constrained from sliding along the rack to avoid over stressing the battery terminals, battery casing, or rack ends. The inspectors determined the finding could be evaluated using the Significance Determination Process in accordance with Inspection Manual Chapter 0609,

Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions. The inspectors answered Yes to question 1, and screened the finding as having very low safety significance (Green). The inspectors did not assign a cross-cutting aspect because the installation of the battery racks occurred in 2008, and was not representative of current performance. (Section 4OA2.1.b.1.ii)

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of Problem Identification and Resolution as defined by Inspection Procedure 71152, Problem Identification and Resolution.

Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the Corrective Action Program at Kewaunee Power Station to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the Corrective Action Program, such as the Condition Report Review Team meeting, the Corrective Action Assignment Review Team meeting and the Corrective Action Review Board meeting.

Selected licensee personnel were interviewed to assess their understanding of and their involvement in the Corrective Action Program.

The inspectors reviewed selected condition reports across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensees Corrective Action Program. The majority of the risk-informed samples of condition reports reviewed were issued since the last NRC biennial Problem Identification and Resolution inspection completed in September of 2010. The inspectors also reviewed selected issues that were more than five years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, and common cause evaluations. The inspectors assessed the scope and depth of the licensees evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for less significant issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors selected the Emergency Diesel Generator system to review in detail since the Emergency Diesel Generator system was a risk-significant Maintenance Rule system. The primary purpose of this review was to determine whether the licensee was properly monitoring and evaluating the performance of Maintenance Rule systems through effective implementation of station monitoring programs. A 5-year review of Emergency Diesel Generator issues was performed to assess the licensees efforts in monitoring for system degradation due to aging. The inspectors also performed walkdowns, as needed, to verify the resolution of issues.

The inspectors examined the results of self-assessments of the Corrective Action Program completed during the review period. The results of the self-assessments were compared to self revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified non-cited violations and findings to determine whether the station properly evaluated and resolved those issues.

The inspectors performed walkdowns, as necessary, to verify the resolution of the issues.

b.

Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that, in general, the station was effective in identifying issues at a low threshold and entering them into the Corrective Action Program. The inspectors determined that the station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the Corrective Action Program when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were entered into the Corrective Action Program for resolution.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the Corrective Action Program to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors performed a five year historical review of the emergency diesel generator system. As part of this review, the inspectors interviewed the current and prior emergency diesel generator system engineers, reviewed a sample of emergency diesel generator system health reports, condition reports, operating experience, and an apparent cause evaluation. In addition, the inspectors walked down the emergency diesel generator area to visually inspect recent emergency diesel generator related modifications and to verify that identified concerns were tagged and entered into the Corrective Action Program. The inspectors concluded that emergency diesel generator related concerns were identified and entered into the Corrective Action Program at a low threshold, and concerns were resolved in a timely manner commensurate with safety.

i) Observations:

Untimely Corrective Actions to Restore 10 CFR 50, Appendix R Lighting The inspectors identified a minor violation of license condition 2.C(3), which required the licensee to implement and maintain, in effect, all provisions of the approved fire protection program as described in the licensees Fire Plan, and as referenced in the Updated Safety Analysis Report, and as approved through Safety Evaluation Reports dated November 25, 1977, and December 12, 1978, and supplement dated February 13, 1981. The Kewaunee Power Station Fire Protection Plan states that fire protection corrective actions will be identified and addressed in accordance with the Dominion Corrective Action Program. Procedure PI-AA-200, Corrective Actions, 6, Corrective Action Prioritization, would assign a corrective action due date of 180 days for low priority items.

Contrary to the above, from 2007 through 2012, a non-conformance with 10 CFR 50, Appendix R, III, J, Emergency Lighting, was not corrected. Specifically, the licensee erected scaffolding in the north penetration room in preparations for a permanent modification to provide safe platforms for the operators to access the elevated valves.

The initial construction of the scaffold occurred in 2007 and blocked the emergency lighting required by 10 CFR 50, Appendix R, III, J. The inspectors found that the permanent modification was eventually cancelled, due to its complexity and expense, and no corrective actions were created to restore the blocked lighting and compliance with 10 CFR 50, Appendix R. This violation is minor because the licensee had an active fire protection system impairment and had compensatory measures in place, which consisted of having the operators obtain flashlights prior to conducting required actions.

The licensee documented this in their Corrective Action Program as CR489875.

ii) Findings:

Battery Rack Configuration Not in Accordance with Design Bases

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because the licensee failed to ensure that the configuration of the safeguards battery racks was in accordance with the design basis Seismic Category I qualification. Specifically, the Seismic Category I qualification specified that the battery rack end rails be snug against the battery. The inspectors found gaps greater than 1/8 inch and up to approximately 3/8 inch. The vendor instructions directed that the rails should be within 1/8 inch.

Description:

On September 12, 2012, while the inspectors toured the safeguards battery rooms, they observed that the gaps between the batteries and the battery rack rails appeared excessive. The inspectors reviewed the licensees seismic qualification calculation QR 2268581, Revision 1, Seismic Qualification Report of 125 Volt DC LCR 25 Batteries, 2 Step Battery Racks & Single Row Spare Cell Rack, and found that it described the battery end rails as snug to the batteries. The inspectors informed the licensee of their concern, who agreed with the inspectors observations. The licensee found that the gaps on the Train A battery were within the 1/8 inch vendor requirement.

However, gaps on the Train B battery exceeded the vendor requirement. The licensee readjusted the end rails for Train B battery and restored the battery racks to their design basis configuration. The licensee evaluated the as-found condition of the battery racks and determined that the batteries were operable but non-conforming. The inspectors reviewed the work order that replaced the battery in 2008 and found that the work order contained a note and a caution stating the front and end rails should be within 1/8 inch; however, the step to install the rails did not contain any acceptance criteria for end rail installation. The inspectors reviewed the administrative procedure WM-AA-101, Work Order Planning, and found that the procedure instructed that notes not be used to define limitations or special circumstances governing a job step. The procedure also specified that warnings, caution, and notes, do not contain hidden actions. The inspectors concluded that the acceptance criteria for the battery end rail installation should have been contained in the step itself.

Analysis:

The inspectors determined that the failure to ensure that safeguards battery racks were in accordance with its design basis seismic qualification was contrary to 10 CFR Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of protection against external factors and affected the cornerstone objective to ensure the availability, reliability, and Corrective Action Programability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to ensure that the batteries were constrained from sliding along the rack to avoid over stressing the battery terminals, battery casing, or rack ends.

The inspectors determined the finding could be evaluated using the Significance Determination Process in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions. The inspectors answered Yes to question 1, and screened the finding as having very low safety significance (Green). The inspectors did not assign a cross-cutting aspect because the installation of the battery occurred in 2008, and was not representative of current performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, between October 19, 2007 and April 23, 2008, the licensee failed to translate the safeguards battery rack design basis into procedures and instructions.

Specifically, in Work Order 07007948, the licensee did not specify in a job step to place the front and end restraints within 1/8 inch of the battery. Because this violation was of very low safety significance, and the licensee entered it into the Corrective Action Program as CR489958 and CR487875, this violation is being treated as a non-citied violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. The licensee took short term corrective actions and adjusted the battery rack end gaps to be within 1/8 inch, and assigned an apparent cause evaluation, which was not complete at the end of this inspection period. (NCV 05000305/2012008-01: Battery Rack Configuration Not In Accordance With Design Basis)

(2) Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that the station was effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk.

The inspectors determined that the Condition Report Review Team meeting, the Corrective Action Assignment Review Team meeting and the Corrective Action Review Board meeting were generally thorough and maintained a high standard for evaluation quality. Members of the Corrective Action Review Board discussed the issues presented in sufficient detail and challenged presenters regarding their conclusions and recommendations.

The inspectors performed a detailed review of issues entered into the Maintenance Rule (a)(1) category covering roughly the past five years. The review included the longest standing (a)(1) issue, a significant structure, system, and components entered (a)(1) status and returned to (a)(2) and a recent (a)(1) entry. The Inspectors reviewed action plans approved by the expert Panel, associated cause evaluations, Maintenance Rule evaluations, and condition reports. The inspectors noted that the licensee generally showed no reluctance in placing structure, system, and components into Maintenance Rule (a)(1) status. A detailed review of structure, system, and components performance after appropriate corrective actions, addressing preventative maintenance inadequacies or structure, system, and components modifications generally occurred before returning structure, system, and components to (a)(2) status.

The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

The inspectors identified two minor violations of licensees procedures as described in the observations below.

i) Observations:

Assigned Reactivity Event Classification Levels Not In Accordance with Reactivity Management Procedure The inspectors identified two examples of reactivity management events that were not screened at the significance levels prescribed in procedure OP-AP-300, Reactivity Management. The inspectors found that one event, which occurred on August 30, 2011, was related to a control rod exceeding its control bank insertion limits for a longer period of time than allowed by the Technical Specifications. The licensee screened the event as a Significance Level 4 event. However, the inspectors reviewed procedure OP-AP-300 and found examples listed under Significance Level 2 event, Item 2.14, Entry into Reactivity Related TS Action Statement and not Corrected Within TS Time requirements. The inspectors also reviewed the definition of a Significance Level 2 event, which is, A Reactivity Management Event that places the plant outside of the Design, Analysis, or Licensing Basis or significant events that compromise fuel related limits, or directly result in fuel failure. The licensee made a report for the control rod insertion limit event, per 10 CFR 50.73, for condition prohibited by the plants Technical Specifications. Therefore, the inspectors concluded that the plant was outside of its licensing basis and the event should have been screened as a Reactivity Significance Level 2 event.

The second example was an unintentional boron dilution that occurred in the 2009 outage, which the licensee reported, per 10 CFR 50.73, as condition prohibited by the plants Technical Specifications. At the time, the licensee moved fuel after obtaining sample results that showed the boron concentrations were below the minimum requirement. The inspectors were concerned about the incorrect reactivity event classifications because the reactivity classification determines the condition report significance per procedure PI-AA-200, Corrective Actions. Condition reports documenting Reactivity Significance Level 2 events should be screened as Significance Level 1 under the Corrective Action Program and would typically receive a root cause evaluation. The inspectors found that the licensee did not screen the condition reports documenting these two examples as Significance Level 1, nor did they perform a root cause evaluation. The licensee entered this into the Corrective Action Program as CR489442.

Condition Report Significance Assignments Inconsistent with Procedure Guidance The inspectors identified two examples of condition reports where the significance level assigned were inconsistent with procedure PI-AA-200, Corrective Actions, 4, CR Significance Determination. The inspectors found that CR467560, NRC Question on SR 3.6.3.3, which concluded that the licensee missed a TS surveillance requirement, was assigned a Significance Level 3, instead of a Significance Level 2. The inspectors also identified that CR470789, Identified Leak on N31/N35 Detector Cable (1RI087R), which was later determined to be reportable, per 10 CFR 50.73, for any condition prohibited by the plants Technical Specifications, was assigned a Significance Level 3, instead of a Significance Level 2. The inspectors found that the two examples were both situations where a follow-up evaluation or assessment was needed to conclude whether a missed Technical Specification surveillance or a reportable condition existed. The inspectors found that the licensees Corrective Action Program did not have a mechanism to reassess a condition reports significance when future follow-up actions concluded that criteria existed that warranted a higher condition report significance level. The licensee entered this issue into the Corrective Action Program as CR489462.

ii) Findings:

No finding was identified.

(3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was effective in implementing corrective actions in a timely manner to address identified deficiencies, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with the Corrective Action Program and applicable procedural requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

The inspectors also identified that there were over 2900 open corrective action items at the time of the inspection. More than 180 of these open corrective action items were greater than three years old. The inspectors reviewed a sample of these corrective action items and determined that most of the remaining actions were minor non-conformances or enhancements and the due dates for the actions had been extended a number of times due to resource limitations or other emergent issues. While some of these action items were considered long term corrective actions by the licensee, they represented a significant increase (more than four times) from what was observed during the last Problem Identification and Resolution Inspection two years ago. The inspectors verified that the sampled condition reports were evaluated and actions assigned appropriately. The inspectors regarded this aging corrective action issue as an improvement opportunity since the outstanding actions, even when some were considered enhancements, could potentially affect the licensees focus on more important safety issues and complicate resource utilization.

i) Observations:

Untimely Implementation of Corrective Action to Prevent Recurrence The inspectors identified one example of untimely implementation of corrective actions to prevent recurrence. This subject corrective action to prevent recurrence was to replace 43 high risk service water dead leg piping runs. These actions were being performed to address a service water supply piping leak in 2006 that rendered the B emergency diesel generator inoperable and resulted in a unit shutdown.

The licensee determined that the root cause of this event was the failure to implement a robust program to monitor and protect service water dead leg piping. Inadequate program guidance existed for chemical treatment as well as decisions and actions when the inspection program identifies under-deposit corrosion and microbial induced corrosion degradation. Consequently, timely action was not taken to avoid adverse impacts on plant operation.

In November 2007, the licensee developed procedure guidance to identify piping for replacement and created an inspection plan using guided wave inspection technology for these dead leg piping as corrective actions to prevent recurrence. In September 2008, the licensee determined that the guided wave inspection technology was not suitable to detect microbial induced corrosion and there were no reliable methods for detection. The licensee subsequently changed the corrective action to prevent recurrence to replace 43 high risk service water dead leg piping runs preemptively with a target completion date of December 2013.

By December 2010, 15 of the 43 sections of service water piping were replaced.

Engineering management at the time concluded that the replacement process was not sufficient and performed a new walkdown to support rescreening of the lines. However, no replacement was performed since December 2010 and no replacement schedule had been approved at the time of the inspection. The licensee stated that this delay was due to turnover in engineering and not presenting the problem and recovery option to the Corrective Action Review Board for revision.

The inspectors determined that the delay in replacing the service water dead leg piping was a missed opportunity for the licensee to address a significant condition adverse to quality in a more timely manner. This was particularly disappointed considering the root cause of the leak was the failure to implement a robust program to monitor and protect service water dead leg piping which led to untimely action to avoid adverse impacts on plant operation. The inspectors determined that this was not a violation of NRC regulation as the initial timeline for the correction action still could be met. The licensee entered this issue into the Corrective Action Program as CR489877.

ii) Findings:

No finding was identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the Operating Experience program. Specifically, the inspectors reviewed the Operating Experience program implementing procedures, and completed evaluations of operating experience issues and events. The inspectors determined whether the licensee was effectively integrating operating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the operating experience information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of operating experience, were identified and implemented in an effective and timely manner.

b.

Assessment Based on the results of the inspection, the inspectors concluded that in general, operating experience was effectively utilized at the station. The inspectors observed that operating experience was discussed as part of the daily and pre-job briefings. Industry operating experience was effectively disseminated across plant departments and no issues were identified during the inspectors review of licensee operating experience evaluations.

The inspectors reviewed in detail the licensees evaluation of external operating experience related to laminar cracks identified in the shield building at the Davis-Besse Nuclear Power Station. This was performed due to the extensive degradation of the shield building at Davis-Besse and the similarity of the structure with Kewaunees shield building. The inspectors reviewed associated external operating experience evaluation documents, a Kewaunee reactor building design drawing, and interviewed Kewaunee engineers that evaluated the operating experience for applicability to Kewaunee. The licensee concluded that the Kewaunee reactor building shield wall is not susceptible to laminar cracking identified at Davis-Besse since there is no inherent stress concentration needed to generate the radial stress magnitude to initiate laminar crack. The inspectors determined the licensee appropriately evaluated external operating experience for Davis-Besse shield building laminar cracking.

c. Findings

No finding was identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected formal and informal self-assessments, root cause effectiveness reviews, and Nuclear Oversight audits. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the Corrective Action Program.

In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues included weaknesses in management oversight of the Corrective Action Program.

c. Findings

No finding was identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed selected Kewaunee Station personnel to determine if there were any indications that licensee personnel were reluctant to raise safety concerns, both to their management and the NRC, due to fear of retaliation. In addition, the inspectors discussed the implementation of the Employee Concern Program with the Employee Concern Program coordinators, and reviewed Employee Concern Program activities to identify any emergent issues or potential trends. The inspectors also assessed the licensees safety conscious work environment through a review of Employee Concern Program implementing procedures, discussions with Employee Concern Program coordinators, interviews with personnel from various departments, and reviews of condition reports. The inspectors also reviewed the effectiveness of the licensees promotion of the Corrective Action Program and Employee Concern Program.

The inspectors reviewed the licensees safety culture surveys to assess if there were any organizational issues or trends that could impact the licensees safety performance.

b. Assessment The inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety conscious work environment at Kewaunee Power Station. Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concern Program, through which concerns could be raised. In addition, a review of the types of issues in the Employee Concern Program indicated that site personnel were appropriately using the Corrective Action Program and Employee Concern Program to identify issues. The staff also indicated that management had been supportive of the Corrective Action Program by providing time and resources for employee to generate their own condition reports.

The staff also expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be freely communicated to supervision and safety significant issues were being corrected.

Some employees indicated a number of low level items were not being corrected in a timely manner. The inspectors determined that the timeliness of the planned corrective actions for the examples given were commensurate with their safety significance.

c. Findings

No findings were identified.

4OA6 Management Meetings

a.

Exit Meeting Summary

On September 28, 2012, the inspectors presented the inspection results to Mr. A. Jordan, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Jordan, Site Vice President

R. Simmons, Plant Manager

D. Lawrence, Operations Director

J. Stafford, Safety & Licensing Director

S. Yuen, Engineering Director

J. Grau, Maintenance Manager

R. Repshas, Licensing Supervisor

D. Shannon, Radiation Protection Supervisor

K. Zastrow, Organizational Effectiveness Manager

D. Anderson, Nuclear Oversight

NRC

K. Riemer, Branch Chief

R. Krsek, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000305/2012008-01 NCV Battery Rack Configuration Not In Accordance With Design Basis (Section 4OA2.1.b.1.ii)

Closed

05000305/2012008-01 NCV Battery Rack Configuration Not In Accordance With Design Basis (Section 4OA2.1.b.1.ii)

Discussed

None Attachment