IR 05000305/2013011

IR 05000305-13-011, on 12/31/2014, Kewaunee Power Station, NRC Inspection Report

ML14069A225
Person / Time
Site:	Kewaunee
Issue date:	03/10/2014
From:	Robert Orlikowski NRC/RGN-III/DNMS/MCID
To:	Heacock D Dominion Energy Kewaunee
Bonano E
References
IR-13-011
Download: ML14069A225 (33)

Text

UNITED STATES rch 10, 2014

SUBJECT:

NRC INSPECTION REPORT NO. 05000305/2013011(DNMS) - KEWAUNEE POWER STATION

Dear Mr. Heacock:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities for October through December 2013, at the permanently shut down Kewaunee Power Station (KPS) in Kewaunee, Wisconsin. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with Mr. A. Jordan and other members of your staff on February 4, 2014.

During the inspection period, the NRC inspectors reviewed the following aspects of onsite activities: organization, management and cost control at the site; safety reviews, design changes and modifications; self-assessments, audits and corrective actions; decommissioning performance; maintenance and surveillance; and spent fuel pool safety. The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observation of work activities, and interviews with personnel.

Based on the results of this inspection, the NRC identified two Severity Level IV violations of NRC requirements. However, because of their very low safety significance and because the issues were entered into your corrective action program (CAP), the NRC is treating the issues as Non-Cited Violations (NCV), in accordance with Section 2.3.2 of the NRC's Enforcement Policy. No response is required for the non-cited violations. However, if you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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

Sincerely,

/RA/

Robert J. Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Docket No: 50-305 License No: DPR-43

Enclosure:

Inspection Report No. 05000305/2013011(DNMS)

REGION III==

Docket No: 050-00305 License No: DPR-43 Report No: 05000305/2013011(DNMS)

Licensee: Dominion Energy Kewaunee, Inc., (DEK)

Facility: Kewaunee Power Station (KPS)

Location: Kewaunee, WI Dates: October 1, 2013 through February 4, 2014 Inspectors: Rhex A. Edwards, Reactor Inspector (DNMS)

Robert G. Krsek, Senior Resident Inspector Jeremy R. Tapp, Health Physicist Navid N. Tehrani, Health Physicist James L. Beavers, Emergency Preparedness Inspector Approved by: Robert Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY Kewaunee Power Station NRC Inspection Report 05000305/2013011 Kewaunee Power Station (KPS) operated at full power until May 7, 2013, when Kewaunee shutdown and permanently ceased power operation. On May 14, 2013, Kewaunee certified the permanent removal of fuel from the reactor vessel (ADAMS Accession No. ML13135A209). On May 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) notified Kewaunee that the Operating Reactor Assessment Program had ceased and that implementation of the Decommissioning Power Reactor Inspection Program would begin on June 1, 2013 (ADAMS Accession No. ML13151A375).

Currently, the KPS is a permanently shut-down and defueled power reactor facility that was maintained in a Safe Storage of Spent Fuel (SAFSTOR) condition with spent fuel in wet storage and at an Independent Spent Fuel Storage Installation.

Organization, Management and Cost Controls

• The licensee adequately implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the Technical Specifications (TSs). (Section 1.0)

Safety Reviews, Design Changes, and Modifications

• A Severity Level IV violation was identified by the NRC for the failure to obtain prior NRC approval for certain changes made to the Kewaunee Power Station (KPS) Emergency Plan since the May 7, 2013, cessation of operations. Although KPS performed the analyses required by Title 10 of the Code of Federal Regulations (CFR) 50.54(q)(3), the licensee largely based many of its analyses on changes made to the plant design and operations that had been implemented under the authority granted by the 10 CFR 50.59 change process.

The licensees §50.54(q)(3) analyses erred in assuming that the §50.59 change process modified the approved emergency plans licensing basis. If the analyses had been based on the approved emergency plans licensing basis, the licensee would have likely recognized that the changes were reductions in effectiveness requiring prior NRC staff approval. This does not prejudge the technical suitability of the changes made; rather, it is focused on the licensees failure to follow the prescribed process for effecting emergency plan changes. (Section 2.2.a)

• A Severity Level IV violation was identified by the NRC for the failure to follow and maintain the effectiveness of the KPS emergency plan by maintaining an acceptable on-shift staffing analysis since the May 7, 2013, cessation of operations. The licensee modified its on-shift staffing based on accident sequences that had been removed from the Updated Safety Analysis Report and failed to maintain a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. (Section 2.2.b)

Self-Assessment, Auditing, and Corrective Action

• Issues were identified by the licensee at appropriate thresholds and entered into the corrective action program (CAP). Issues were screened and prioritized commensurate with safety significance. Licensee evaluations determined the significance of issues, and included appropriate remedial corrective actions. (Section 3.0)

Plant Procedures

• The licensee reviewed and approved technically adequate procedures in accordance with technical specifications and regulatory requirements. (Section 4.0)

Spent Fuel Pool Safety

• The licensee maintained spent fuel pool equipment (SFP) utilized to maintain SFP water level and cooling in a safe manner. (Section 5.0)

Maintenance and Surveillance

• Maintenance and surveillance for structures, systems, and components were adequate and resulted in the safe storage of spent fuel and proper operation of radiation monitoring and effluent control equipment. Workers followed work plans, surveillance procedures, and industrial safety protocols; and were aware of job controls specified in work instructions.

(Section 6.0)

Decommissioning Performance and Status Review

• The inspectors determined that the licensee and supplemental workforce conducted decommissioning activities in accordance with the regulations and license requirements.

The inspectors also verified that the licensee and supplemental work force activities to transition to a SAFSTOR condition were in accordance with TSs, the Updated Safety Analysis Report (USAR) and the Post Shutdown Decommissioning Activities Report (PSDAR). Finally, the inspectors conducted frequent plant tours to verify that the materiel condition of structures, systems, and components supported the safe storage of spent fuel and conduct of safe decommissioning. (Section 7.0)

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

• The licensee controls, monitors, and quantifies releases of radioactive materials released to the environment to ensure offsite doses are within regulatory limits and As Low As Reasonably Achievable (ALARA). (Section 8.0)

Fire Protection Program

• The licensee adequately implements the approved Fire Protection Program. (Section 9.0)

Followup on Enforcement Actions

• The inspectors determined that the licensees Root Cause Evaluation (RCE) in response to a violation documented in previous communications dated January 24, 2013, and April 4, 2013, (NRC Inspection Report (IR) Nos. 05000305/2012503 and 05000305/2013504), was conducted to a level of detail commensurate with the significance of the problem, and reached reasonable conclusions as to the root and contributing causes of the event. The inspectors also concluded that the licensee identified reasonable and appropriate corrective actions for each root and contributing cause, and that the corrective actions appeared to be prioritized commensurate with the safety significance of the issues.

No other instance of the violations was identified. This violation is closed. (Section 10.0)

Report Details Summary of Plant Activities During the inspection period, the licensee took actions to place the unit in SAFSTOR conditions.

Major onsite activities included implementation of the following: site organizational changes; preparation and submission of license amendments and regulatory exemptions; changes to the USAR following the docketing of the permanent cessation of operations and permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a); reclassification of remaining onsite systems; implementation of system abandonment plans, which included isolation, draining, and abandonment of systems no longer in use; and the development and implementation of modifications to support placing the unit in a SAFSTOR condition.

1.0 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (IP 36801)

1.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Procedures and processes the licensee established to resolve employee and safety concerns, and to assess the licensees effectiveness at resolving identified problems;

• Implementation of CAP procedures;

• Implementation of a cost and personnel reduction strategy that did not adversely challenge public health and safety;

• Regulatory requirements were properly implemented with respect to the site organization, staffing, and staff qualifications;

• Future licensee plans for decommissioning organization and staffing would continue to meet regulatory requirements;

• Certified fuel handler and employee training programs were implemented in accordance with licensee procedures and NRC requirements;

• Licensee appropriately implemented TS, Technical Requirements Manual, PSDAR, and fire protection plan requirements and commitments;

• Licensee continued implementation of regulatory requirements that remained applicable as described in NRC Bulletins, Generic Letters, and Orders;

• Licensee decommissioning activities were initiated, sequenced and performed in a manner consistent with the PSDAR; and As part of the inspection, the inspectors verified that licensee programs and procedures were appropriately implemented by licensee staff. In addition, the inspectors verified

that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

1.2 Observations and Findings The inspectors determined through: direct licensee observation; reviews of newly established licensee programs and procedures; sampling of training programs, qualification matrices, and corrective action documents; and interviews with licensee personnel that the appropriate regulatory requirements and commitments were followed.

No findings were identified.

1.3 Conclusions The licensee adequately implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the TSs.

2.0 Safety Reviews, Design Changes, and Modifications (IP 37801)

2.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Determination that licensee procedures and processes conform to the regulation and guidance associated with 10 CFR 50.59;

• Evaluation of the licensees onsite safety review committee to ensure the committee was appropriately staffed and trained to fulfill the charter;

• Procedures that control and implement design changes and modifications to assess that the procedures provided adequate guidance for implementation, review and approval;

• Implementation of a sampling of design change modifications to verify that procedures and controls were followed; and confirm that the applicable changes were effectively implemented in the field and in plant procedures, drawings, and training programs if applicable;

• Verification that changes made under 10 CFR 50.59 did not require prior NRC approval;

• Verification that changes to preventive maintenance, corrective maintenance, and operational procedures for required equipment were implemented in accordance with the licensees processes and procedures; and

• Evaluation of emergency preparedness and response equipment, personnel, and procedural changes were effectively reviewed, conducted, managed, and controlled during plant decommissioning as to maintain compliance with NRC regulations

• The inspectors verified that when issues were identified that licensee personnel appropriately documented the issue in the CAP.

2.2 Observations and Findings The inspectors reviewed the licensees programs for changes; attended a sampling of licensee weekly onsite safety review committee meetings throughout the inspection period to verify that requirements were met; and performed a review of procedure and modification changes on a sample of licensee-approved changes. The inspectors determined that when issues were identified, the issues were documented by the licensee in the CAP at an appropriate threshold.

a. Failure to Obtain Prior NRC Approval for Emergency Plan Changes A Severity Level IV violation was identified by the NRC for the failure of Dominion Energy Kewaunee, Inc., (DEK) to obtain prior NRC approval for certain changes made to the KPS emergency plan since the May 7, 2013, cessation of operations. Although KPS performed the analyses required by 10 CFR 50.54(q)(3), the licensee based many of its analyses on changes made to the plant design and operations that had been implemented under the authority granted by 10 CFR 50.59. The licensees §50.54(q)(3)

analyses erred in assuming that the changes made under the authority granted by

§50.59 had also modified the approved emergency plans licensing basis. If the analyses had been based on the approved emergency plans licensing basis, the analysis would have concluded that the changes were reductions in effectiveness requiring prior NRC staff approval.

This enforcement action does not prejudge the technical suitability of the changes made; rather, it is focused on the licensees failure to follow the prescribed regulatory process for effecting emergency plan changes.

The NRC based resident inspector identified concerns regarding changes to the KPS Emergency Plan implemented on September 24, 2013. These changes:

(1) re-designated several emergency response organization (ERO) positions from 30-minute responders to 60-minute responders, and, (2) eliminated an ERO position.

Region III sent an emergency preparedness inspector to KPS to perform an inspection of the emergency plan changes and their documentation. This inspection was conducted between October 2, 2013, and December 20, 2013.

During this inspection, the inspectors identified a common process error in the change process for the following three changes:

• An increase in augmentation response times for the ERO Electrical and Instrument &

Control positions from 30 minutes to 60 minutes (Screening/Evaluation No. KW-13-030);

• An increase in augmentation response times for the In-Plant Radiation Emergency Team (IRET) and IRET support from 30 minutes to 60 minutes (Screening/Evaluation No. KW-13-031); and

• An elimination of the ERO Core Assessment position (Screening/Evaluation No KW-13-033).

The §50.54(q)(3) evaluations for these three changes stated, in part, that because the KPS license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, the KPS USAR was modified to reflect the applicable accidents / transients applicable to KPS in a permanently defueled condition. The licensee implemented these changes under the authority provided by the §50.59 change process. The appropriateness of these changes to the USAR was not at issue here.

However, the licensee incorrectly determined that these USAR changes also modified the licensing basis of the KPS Emergency Plan. As stated in §50.59(c)(4), that change process does not apply when the applicable regulations establish more specific criteria for accomplishing such changes. For changes to the emergency plan, the applicable regulation is §50.54(q)(3), which allows a licensee to change its emergency plan only if the licensee performs and retains an analysis demonstrating it does not reduce the effectiveness of the emergency plan and that the plan continues to meet applicable regulations. The term emergency plan is defined in §50.54(q)(1)(ii), which includes, in part, the plan as originally approved by the NRC and all subsequent changes made by the licensee with, and without, prior NRC review and approval. The term is also included in §50.54(q)(2) - (6) and, accordingly, each of these paragraphs is informed by this definition.

On October 23, 1979, the NRC published a Policy Statement (44 FR 61123) that concurred in, endorsed, and directed the staff to incorporate, the guidance contained in NUREG-0396 / EPA 520/1-78-016, Planning Basis for the Development of State and Local Government Radiological Response Plans in Support of Light Water Nuclear Power Plants. This study report concluded that there was no single accident that could be isolated, and that the planning basis should be based on the potential consequences, timing, and release characteristics of a spectrum of accidents ranging from minor transients, design basis accidents, and severe accidents. This planning basis was subsequently summarized in Section I.D of NUREG-0654 / FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, and was incorporated into the planning standards of §50.47(b) and in the evaluation criteria provided in NUREG-0654.

The NRC approval of the KPS Emergency Plan was based largely upon the licensees compliance with the regulations. In making this determination, the NRC used this guidance, except where the applicant proposed an alternative acceptable to the NRC.

Accordingly, this planning basis is inherently embedded in the licensing basis of the approved KPS Emergency Plan.

Regulatory Guide (RG) 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, describes a method that the NRC considers acceptable to implement the requirements of §50.54(q). The NRC staff uses this guidance in the absence of an alternative method found acceptable by the staff. Section 1.6.a of RG 1.219 provides that the licensee cannot properly evaluate a proposed change if it has not considered the basis of the staffs approval of the original plan or the basis for any subsequent change. The section provides a tabulation of typical plant licensing basis documents that may establish emergency plan conditions and commitments that

need to be considered. Similarly, Section 5.2.c.(2) of the guide provides that the licensing basis for each existing program element being changed be determined using the guidance of Section 1.6 of the guide.

Based on the above, the applicable regulations, informed by the regulatory guidance, require that each proposed change be evaluated against the NRC-approved plan and subsequent changes using the existing licensing basis of the emergency plan. Any change that has the effect of reducing the effectiveness of the emergency plan is required to be submitted for prior NRC approval by 10 CFR 50.54(q)(3). If the change does not reduce the effectiveness of the emergency plan and the changed plan meets the applicable regulations, then the licensee may implement the change without prior NRC approval. For the changes addressed in this enforcement action, the licensee inappropriately relied on the removal of accidents from the USAR instead of assessing the changes against the most recent NRC-approved emergency plan and the licensing basis supporting that plan in determining whether a reduction in effectiveness was involved and whether the plan, as changed, still met the applicable regulations.

Therefore, the changes to increase responder responses and eliminate the ERO positions from those described in the NRC approved emergency plan and associated basis was considered a reduction in effectiveness of the emergency plan that required NRC approval prior to being implemented.

The inspectors determined that DEKs failure to obtain prior NRC approval for these KPS emergency plan changes was a violation of 10 CFR 50.54(q)(3). Since the oversight of KPS is no longer provided by the Reactor Oversight Process, this violation was evaluated using the guidance in the NRC Enforcement Policy. This violation was deemed to be more-than-minor as the violation impacted the NRCs ability to perform its regulatory functions. The violation was dispositioned as a Severity Level IV violation according to Section 6.6, Emergency Preparedness, Example 6.6.d.1, of the NRC Enforcement Policy, because the changes implemented were deemed to reduce the effectiveness of the KPS emergency plan.

Title 10 CFR 50.54(q)(3) states, in part, that the licensee may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements in Appendix E to this part and, for nuclear power reactor licensees, the planning standards of §50.47(b).

Contrary to 10 CFR 50.54(q)(3), on September 24, 2013, the licensee made changes to its emergency plan without NRC approval based on an analysis that did not demonstrate that the changes do not reduce the effectiveness of the plan.

Specifically, the licensee increased the ERO augmentation response times for the electrical, instrument and control, IRET, and the IRET support positions from 30 minutes to 60 minutes; and eliminated the Core Assessment position. The licensee did not perform an analysis demonstrating that the changes do not reduce the effectiveness of the emergency plan. These changes were not submitted to the NRC for approval prior to implementation.

Because this violation was of very low safety significance and it was entered into the licensees CAP (CR 538809), this violation is being treated as an Non-Cited Violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy

(NCV 5000305/2013011-01; Failure to Obtain Prior NRC Approval for Emergency Plan Changes).

b. Failure to Maintain an Acceptable On-Shift Staffing Analysis A Severity Level IV violation was identified by the NRC for the failure of DEK to follow and maintain the effectiveness of the KPS emergency plan by maintaining an acceptable on-shift staffing analysis that meets the requirements in 10 CFR 50.54(q)(2) associated with Section IV.A.9 of Appendix E since the May 7, 2013, cessation of operations.

Although KPS performed the analyses in 2012, KPS subsequently reduced the on-shift staffing and did not revise the supporting on-shift staffing analysis.

Section IV.A.9 of Appendix E to 10 CFR Part 50 requires the licensee to include in its emergency plan by December 24, 2012, a detailed analysis demonstrating that on-shift personnel assigned to emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. At the time the rule was issued, the NRC issued guidance on meeting this rule in NSIR/DPR-ISG-01, Interim Staff Guidance:

Emergency Planning for Nuclear Power Plants. The ISG found NEI 10-05, Assessment of On-Shift Emergency Response, an acceptable methodology for performing these analyses. This guidance, which was written for operating nuclear power reactor licensees, provided an acceptable method for demonstrating compliance with the rule. This guidance identified a series of accident sequences and event that were to be considered in preparing an acceptable staffing analysis. In the absence of an acceptable alternative method proposed by the licensee, the NRC uses this guidance in assessing compliance with the regulation.

In performing an inspection conducted between October 2, 2013, and December 20, 2013 the inspector identified that on-shift staffing had been reduced from the staffing as described in the licensees on-shift staffing analysis. Specifically, based on accident sequences removed from the USAR, the on-shift staffing was reduced to only support a fuel handling accident, a design basis threat, an aircraft probable threat (§50.54(hh)),

and a station blackout. As a result, the actual on-shift staffing was no longer consistent with the on-shift staffing analysis described in Section IV.A.9 of Appendix E.

Specifically, the Unit Supervisor, Shift Technical Advisor, two Reactor Operator, and Chemistry Technologist positions identified in the On-Shift Staffing Analysis are no longer present in the current KPS Shift Staff and ERO Position figure. As a result of these changes, DEK failed to maintain their on-shift staffing analysis.

The inspectors determined that DEKs failure to follow and maintain the effectiveness of the KPS emergency plan by maintaining an acceptable on-shift staffing analysis is a violation of 10 CFR 50.54(q)(2) associated with Section IV.A.9 of Appendix E. Since the oversight of KPS is no longer provided by the Reactor Oversight Process, this violation was evaluated using the guidance in the NRC Enforcement Policy. This violation was deemed to be more-than-minor as the violation impacted the NRCs ability to perform its regulatory functions. The violation was dispositioned as a Severity Level IV violation according to Section 6.6, Emergency Preparedness, Example 6.6.d.1, because the licensee did not meet a regulatory requirement.

Title 10 CFR 50.54(q)(2) states, in part, that the licensee shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part.Section IV.A.9 of Appendix E to 10 CFR Part 50 requires that the KPS emergency plan include a detailed analysis demonstrating that on-shift personnel assigned to emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. Contrary to 10 CFR 50.54(q)(2), since the May 7, 2013, cessation of operations, KPS implemented changes to its emergency plan that failed to maintain the on-shift staffing analysis.

Specifically, the licensee modified its on-shift staffing and failed to maintain a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

Because this violation was of very low safety significance and it was entered into the licensees CAP (CR 538810), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 5000305/2013011-02; Failure to Maintain an Acceptable On-Shift Staffing Analysis).

c. Emergency Action Level and Emergency Plan Changes The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of revisions to the Emergency Plan and various Emergency Plan Implementing Procedures (EPIPs) located under ADAMS Accession Numbers ML130300467 and ML13037A619, as listed in the Attachment to this report. These reviews were conducted between January 1, 2013 and May 31, 2013.

The licensee transmitted the EPIP revisions to the NRC pursuant to the requirements of 10 CFR Part 50, Appendix E, Section V, Implementing Procedures. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment to this report.

No findings were identified.

2.3 Conclusions A Severity Level IV violation was identified by the NRC for the failure to obtain prior NRC approval for certain changes made to the KPS Emergency Plan since the May 7, 2013, cessation of operations. Although KPS performed the analyses required by 10 CFR 50.54(q)(3), the licensee largely based many of its analyses on changes made to the plant design and operations that had been implemented under the authority granted by the 10 CFR 50.59 change process. The licensees §50.54(q)(3) analyses erred in assuming that the §50.59 change process modified the approved emergency plans licensing basis. If the analyses had been based on the approved emergency plans licensing basis, the licensee would have likely recognized that the changes were reductions in effectiveness requiring prior NRC staff approval. This does not prejudge the technical suitability of the changes made; rather, it is focused on the licensees failure to follow the prescribed process for effecting emergency plan changes.

A Severity Level IV violation was identified by the NRC for the failure to follow and maintain the effectiveness of the KPS emergency plan by maintaining an acceptable on-shift staffing analysis since the May 7, 2013, cessation of operations. The licensee modified its on-shift staffing based on accident sequences that had been removed from the USAR and failed to maintain a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

3.0 Self-Assessments, Audits, and Corrective Actions (IP 40801)

3.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Administrative procedures prescribed actions for the identification, evaluation and resolution of problems;

• License procedures prescribed thresholds for the performance of self-assessments, audits, and surveillances;

• License management reviewed self-assessments, audits, and corrective actions to remain knowledgeable of plant performance;

• Self-assessments were conducted with technically qualified personnel and sufficient independence from the licensee;

• Issues or problems were identified and corrected in accordance with the licensees CAP through a sampling of select issues;

• Quality assurance personnel audited changes in the status of decommissioning and licensee organization; and

• Licensee management observed maintenance and surveillance activities, operations evolutions and training.

The inspectors reviewed CAP documents on a daily basis to determine: if a sufficiently low threshold for problem identification existed; the quality of follow-up evaluations including extent-of-condition; if the licensee assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue. Issues that were repetitive and those with the potential for safety or regulatory consequence were evaluated further to assess apparent and/or common cause and significance. The inspectors also observed a sample of licensee corrective action review team and corrective action review board meetings to ascertain if the CAP documents were implemented appropriately.

3.2 Observations and Findings The inspectors determined that issues were identified by the licensee at an appropriate threshold within various functional areas of the site and entered into the CAP. Issues were effectively screened, prioritized and evaluated commensurate with safety significance. The scope and depth of evaluations were adequate in that the evaluations reviewed addressed the significance of issues and assigned an appropriate course of remedial action.

The inspectors verified that self-assessments conducted during the inspection period were performed with technically qualified personnel; and when appropriate, utilized personnel independent of the licensee. Finally, the inspectors verified that quality assurance personnel continued to audit changes implemented at the plant.

No findings were identified.

3.3 Conclusions Issues were identified by the licensee at appropriate thresholds and entered into the CAP. Issues were screened and prioritized commensurate with safety significance.

Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions.

4.0 PLANT PROCEDURES (IP 42700)

4.1 Inspection Scope The inspectors performed a sample selection of revised licensee procedures as a result of the permanent cessation of operations. The inspectors reviewed revised procedures across several workgroups to evaluate the technical content, adequacy, and usability of procedures. Specifically, the inspectors reviewed procedures associated with:

• the General conduct of operations;

• Startup, operation, and shutdown of equipment important to spent fuel pool cooling;

• Abnormal operations;

• the Emergency plan;

• the Fire Protection Program; and

• Maintenance As part of the review, the inspectors reviewed the applicable documentation to determine if the appropriate regulatory change process, such as 10 CFR 50.59, was used by the licensee to evaluate whether the changes required prior NRC approval.

4.2 Observations and Findings The inspectors determined that the licensee established a methodical process for the revision of procedures.

No findings were identified.

4.3 Conclusions The inspectors verified that plant procedure revisions were reviewed and approved in accordance with TSs and regulatory requirements.

5.0 Spent Fuel Pool Safety (IP 60801)

5.1 Inspection Scope The inspectors verified the safe wet storage of spent fuel in the auxiliary building. The review included: SFP siphon and draindown protection; cold weather preparations; SFP instrumentation, alarms, and leak detection systems; SFP chemistry and cleanliness controls; SFP criticality controls; and SFP system operation and electrical power supply adequacy.

5.2 Observations and Findings The inspectors reviewed the service water system, the SFP cooling system, and SFP design drawings in addition to performing periodic walk downs of the SFP, accessible SFP cooling system piping, and areas of SFP makeup water piping to evaluate whether conditions existed that represented a siphon or drain path.

The inspectors reviewed SFP drawings and instrument alarm setpoints for the SFP level and temperature detectors. The inspectors concluded that the setpoints were appropriate and provided the licensee adequate time to implement abnormal operating procedures and restore SFP level or cooling if needed. The inspectors also validated through a review of operator logs and condition reports that the licensee was monitoring the leak detection collection container in the auxiliary building basement for signs of increased SFP liner leakage.

The inspectors reviewed the results of the SFP chemistry analyses. The results of the analyses reviewed indicated that all parameters were within procedural and technical specification limits. The inspectors also confirmed that the general housekeeping practices, foreign material exclusion, combustible material control, and SFP chemistry procedures adequately protect the integrity and cooling of the spent fuel.

The inspectors reviewed electrical circuit drawings for the SFP pumps and confirmed that the pumps were still powered from their pre-shutdown vital buses. The inspectors verified that redundant power supplies were available and capable of supporting spent fuel cooling should they be needed. The inspectors also reviewed SFP procedures and operational strategies and confirmed that no significant changes occurred since the plant permanently shutdown.

No findings were identified.

5.3 Conclusions The inspectors determined that the licensee was safely storing spent fuel in wet storage.

Specifically, the SFP was adequately protected from a siphon or drain down event. The SFP instrumentation, alarms, and leakage detection systems were maintained and adequate. The SFP chemistry and cleanliness controls were implemented and adequate. The SFP cooling system electrical power supplies were reliable; and licensee SFP operational strategies were consistent with those used during reactor power operations.

6.0 MAINTENANCE AND SURVEILLANCE (IP 62801)

6.1 Inspection Scope The inspectors conducted plant tours, interviews, and directly observed maintenance and surveillance throughout the inspection period to evaluate the effectiveness of the licensee in maintaining structures, systems, and components important to the safe storage of spent fuel and proper operation of radiation monitoring and effluent control equipment.

During walkdowns, the inspectors evaluated material condition and housekeeping, assessed area radiological conditions, radiological access control and associated posting/labeling, and reviewed the overall condition of systems, structures, and components that support decommissioning. Independent radiation measurements were periodically made by the inspectors in areas toured to determine if those areas were controlled properly and posted as prescribed in 10 CFR Part 20.

The inspectors also reviewed the maintenance history, work prioritization, and surveillance activities for the major components at the station required to be available and/or operable following the permanent cessation of operation, which included:

emergency diesel generators A and B; service water pumps A and B; fire protection pumps A and B; spent fuel pumps A and B; required 480-Volt and 4160-Volt switchgear; equipment important to emergency preparedness; and station batteries. These activities included reviews of revised preventive maintenance schedules, routine walkdowns of the equipment, and observation/review of surveillance activities.

6.2 Observations and Findings The inspectors noted that throughout the inspection period housekeeping remained satisfactory and changing radiological conditions were addressed in a prompt and timely manner by licensee staff.

The inspectors noted that the licensee appropriately prioritized corrective maintenance on the remaining systems required for permanent cessation of operations. The inspectors also verified that equipment, which remained available following the shutdown had the appropriate preventive maintenance schedules established with input from equipment vendors. The inspectors also verified that available equipment had checklists available to establish operability prior to any irradiated fuel movement. Finally, the

inspectors verified that when equipment issues occurred, the licensee staff implemented the appropriate troubleshooting procedures to identify and correct the equipment deficiency identified.

At the end of the inspection period, the licensee was still revising the maintenance rule program.

No findings were identified.

6.3 Conclusions Plant material condition and housekeeping were adequate and had not adversely impacted safe decommissioning or transition to SAFSTOR. Workers followed work plans, surveillance procedures, and industrial safety protocols and were aware of job controls specified in work instructions.

7.0 Decommissioning Performance and status reviews (IP 71801)

7.1 Inspection Scope The inspectors conducted document reviews, observations, and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Status of decommissioning through the observation of licensee meetings that planned, reviewed, assessed and scheduled the conduct of facility decommissioning;

• Whether licensee activities were in accordance with license conditions and docketed commitments, as well as, within the bounds of the docketed post shutdown activity report;

• Operability and functionality of systems necessary for safe decommissioning was assessed through control room and plant walkdowns including the following systems:

radioactive effluent monitoring, spent fuel pool cooling, level and temperature control, radiation protection monitors and alarms, equipment important to emergency preparedness, and equipment that provided normal and standby electrical power;

• Operator logs and data taking for normal facility operations, surveillances, maintenance and verification that data out of specification was appropriately dispositioned and resolved;

• Assessed ongoing in-plant work activities to ensure work activities were evaluated for risk in accordance with 10 CFR 50.65(a)(4), operational work risk assessments were performed, and operations shift turnovers appropriately communicated pertinent plant status;

• Verified appropriate plant staffing was maintained and that appropriate management oversight of licensee and supplemental activities were performed;

• Verified pre-job briefs were conducted for facility operations including maintenance, surveillance, operations, and decommissioning activities;

• Performed plant tours to assess field conditions and decommissioning abandonment activities;

• Observed in progress field work to verify activities were conducted in accordance with approved work instructions and workers were knowledgeable of tasks;

• Plant material condition of structures, systems, and components was maintained at a high level to ensure safe storage of spent fuel;

• Reviewed updated fire plan and procedures to ensure the current status of the facility was reflected;

• Verified the storage of combustibles and flammables were in accordance with plant procedures and the fire plan for the subject location;

• Verified firefighting equipment and stations were properly maintained, inventoried and readied for use;

• Verified that the installed fire detection and suppression systems were effectively maintained, surveillances performed and were capable of performing their intended function; 7.2 Observations and Findings The inspectors determined through the plant tours and activities observed that the licensee conducted activities in accordance with the regulatory requirements and plant procedures No findings were identified.

7.3 Conclusions The inspectors determined that the licensee and supplemental workforce conducted decommissioning activities in accordance with the regulations and license requirements.

The inspectors also verified that the licensee and supplemental work force activities to transition to a SAFSTOR condition were in accordance with TSs, the USAR and the PSDAR. Finally, the inspectors conducted plant tours to verify that the materiel condition of structures, systems and components supported the safe storage of spent fuel and conduct of safe decommissioning.

8.0 RADIOACTIVE WASTE TREATMENT, AND EFFLUENT AND ENVIRONMENTAL MONITORING (IP 84750)

8.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Determined whether radioactive waste treatment systems were maintained and operated to keep offsite doses ALARA;

• Determined whether the licensee effectively controlled, monitored, and quantified releases of radioactive materials in liquid, gaseous, and particulate forms to the environment;

• Determined whether the radiological environmental monitoring programs were effectively implemented to ensure effluent releases were being adequately performed as required to minimize public dose; As part of the inspection, the inspectors verified that licensee programs and procedures were appropriately implemented by licensee staff. In addition, the inspectors verified that when issues were identified licensee personnel appropriately documented the issues in the corrective action program and adequate corrective actions were taken.

Specifically, the inspectors reviewed the following radioactive effluent equipment and associated pathway:

• Radiation monitor R-20 for the Auxiliary Building Service Water Standpipe

• Radiation monitor R-13 for the Auxiliary Building Vent 8.2 Observations and Findings The inspectors noted during walkdowns of the above radioactive effluent equipment and pathways that they were configured as described in the Offsite Dose Calculation Manual (ODCM) and were in good material condition. In addition, the inspectors noted that during a review of past Annual Radiological Effluent Release Reports, no anomalous results, unexpected trends or abnormal releases were identified. For the inter-laboratory comparison results reviewed, the inspectors noted the program contained the appropriate radioisotopes for current plant conditions and it was performed bi-annually as required.

No findings of significance were identified.

8.3 Conclusions The licensee maintained effluent monitoring and control systems as provided in the General Design Criteria. The effluent flow paths and monitoring systems reviewed aligned with descriptions in the ODCM and were functional. Annual Radioactive Effluent Reports were timely submitted for the two years preceding the inspection and satisfied ODCM and Technical Specification informational requirements. The effluent monitors

reviewed were functional, calibrated, and alarm set points conservatively set to meet regulatory requirements. The licensee participated in an inter-laboratory comparison program in accordance with the ODCM requirements.

9.0 Fire Protection Program (IP 64704)

9.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance and:

• Verify that the licensee has developed technically adequate procedures to implement the fire protection program;

• Verify the proper installation, operability, and maintenance of fire protection systems and equipment; and

• Review adequacy and implementation of the quality assurance program for fire protection.

9.2 Observations and Findings The inspector toured the carbon dioxide storage tank room, 1A diesel generator (DG)

and DG day tank rooms, and the screen house to verify the plant was in compliance with the fire protection program and NRC requirements. The inspector verified, in the above listed areas, that all fire protection equipment (doors, extinguishers, manual trip stations, and hose stations) were in working order and located as described in the fire protection program.

No findings were identified.

9.3 Conclusions The inspectors determined that the licensee maintained the fire protection program within requirements. The inspectors also verified that the licensee maintained the fire protection equipment in sound material condition and was available for use as described in the fire plan.

10.0 Followup on Enforcement Actions (IP92702)

10.1 Inspection Scope This inspection was conducted in accordance with IP 92702, Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders. The inspection objectives were to:

• Determine that adequate corrective actions have been implemented for enforcement actions including violations;

• Verify that the root causes of these enforcement actions have been identified, that their generic implications have been addressed, and that the licensee's programs and practices have been appropriately enhanced to prevent recurrence; and

• Provide assurance that the extent-of-condition and extent-of-cause of risk-significant issues are identified; and provide assurance that licensee corrective actions to risk-significant performance issues are sufficient to address the root causes and contributing causes, and to prevent recurrence.

KPS entered the Regulatory Response column of NRCs Action Matrix in the fourth quarter of 2012 as the result of one inspection finding of low to moderate safety significance (White). The finding was associated with an unidentified loss of indication necessary to classify one general emergency and one site area emergency condition by KPS. This condition existed for approximately 30 days. The details of the finding are documented in previous communications dated January 24, 2013, and April 4, 2013, in NRC IR Nos. 05000305/2012503 and 05000305/2013504 respectively. On May 31, 2013, the NRC issued a letter describing the termination of the Reactor Oversight Process for KPS and that the conduct of the inspection for the emergency preparedness White finding would be using IP 92702, "Follow-Up on Corrective Actions for Violations and Deviations," to verify appropriate corrective actions are being implemented instead of IP 95001.

By letter dated November 7, 2013, the licensee notified the NRC that it had completed its evaluation of the performance deficiencies with the unidentified loss of indication and was ready for the NRC to assess the licensees evaluation and subsequent corrective actions. In preparation for the inspection, the licensee performed RCE 001094, Adverse System Particulate, Iodine, and Noble Gas (SPING) monitor indications on the Plant Process Computer System (PPCS) and Radserv went undetected by KPS personnel for an extended period of time, which allowed the deficiencies to exist without compensatory measures or the initiation of corrective maintenance.

The inspectors reviewed the licensees RCE, in addition to other evaluations conducted in support, and as a result, of the RCE. The inspectors reviewed corrective actions that were taken or planned to address the identified causes. The inspectors also held discussions with licensee personnel to ensure that the root and contributing causes, and the contribution of safety culture components, were understood and corrective actions taken or planned were appropriate to address the causes and prevent recurrence.

10.2 Observations and Findings a. Evaluation of Inspection Requirements: Problem Identification The inspectors determined whether the evaluation identified who (i.e., licensee, self-revealed, or NRC), and under what conditions the issue was identified. Specifically the licensee acknowledged that a violation of 10 CFR 50.54(q)(2), for a failure to follow and maintain the effectiveness of its emergency plan associated with risk-significant planning standard 10 CFR 50.47(b)(4), and 10 CFR 50.47(b)(8), was identified by the NRC at the conclusion of in-office and on-site NRC reviews of site procedures, documents, and corrective actions related to the licensees response to the loss of the auxiliary building

and reactor building SPING indications on the PPCS and Radserv stations. Condition report (CR) 490887 documented the issue in the CAP and as a result, RCE 001094 was performed. The failures of the licensee to identify this issue and its precursors were documented in the RCE event description. The inspectors agreed with the RCE conclusion that the NRC identified a failure to follow and maintain the effectiveness of its emergency plan in response to the unidentified loss of the SPING indications.

The inspectors determined whether the evaluation documented how long the issue existed and, whether there were any prior opportunities for identification. Specifically the licensees RCE determined that the SPING indication was lost from February 28, 2011 to March 30, 2011, when the system engineer was performing a walkdown of the system and noted the failed indication. This was not considered a repeat event as there were no prior cause evaluations for this component or specific failure. Kewaunee procedure PA-AA-300, Cause Evaluation, Revision 7, defines a repeat issue as a previously identified issue (failure, problem, or deficiency) that was investigated (evaluated by an ACE/RCE [Apparent Cause Evaluation]) that had the same or similar cause and recurred due to ineffective correction actions.

Several condition reports were identified in the RCE where the licensee identified that a continuous and sufficient flow of data existed to identify the possibility of this failure.

Furthermore the licensee acknowledged that, although several opportunities existed, the site failed to recognize the importance of the SPINGs with respect to the emergency plan.

The inspectors determined that the licensees RCE was adequate with respect to identifying how long the issue existed and prior opportunities for identification.

The inspectors determined whether the licensees RCE documented the plant specific risk consequences and compliance concerns associated with the issue. Specifically, the NRC determined this issue was a low to moderate (White) finding, as documented in Inspection Report (IR) No. 05000305/2012503, and the licensees RCE also documented that the finding associated with this issue had White safety significance. In addition, the RCE acknowledged that the loss of indication inhibited the ability of the station to perform emergency classifications associated with radiological effluent emergency action levels (EALs).

The inspectors concluded that the licensee appropriately documented the risk consequences and compliance concerns associated with the issue.

No findings were identified.

b. Evaluation of Inspection Requirements: Root Cause, Extent-of-Condition, and Extent-of-Cause Evaluation The inspectors determined whether the licensees root cause evaluation applied systematic methods in evaluating the issue in order to identify root causes and contributing causes. Specifically, the licensee used the following systematic methods to complete RCE 001094:

• Why Staircase;

• Barrier Analysis;

• Human Performance Assessment Tool; and

• Failure Mode - Cause Based on the extensive, documented efforts, the inspectors determined that the licensee evaluated the issue using a systematic methodology to identify root and contributing causes.

The inspectors determined whether the licensees root cause evaluation was conducted to a level of detail commensurate with the significance of the problem. Specifically, the licensees RCE included a why staircase, barrier analysis, human performance assessment tool, and failure mode - cause as discussed in the previous section.

The RCE identified the following root causes: (1) programmatic requirements to periodically monitor instrument availability was inappropriate for equipment prioritized as emergency preparedness Category A and guidance provided for an alarming condition was inadequate to ensure status of equipment was understood, evaluated, and compensatory actions put in place; and (2) the system platform was obsolete and difficult to maintain. The RCE identified the following contributing causes: (1) frequent nuisance alarms from the SPING monitors challenged the recognition of actual degradations of the SPING units leading to desensitization resulting in periods of non-functionality; and (2) PPCS alarm points for the SPING clear when the alarm is acknowledged, but do not lock-in.

Based on the extensive work performed for this RCE, the inspectors concluded that the RCE was conducted to a level of detail commensurate with the significance of the problem and the root causes combined with the contributing causes adequately addressed the finding.

The inspectors determined whether the licensees root cause evaluation included consideration of prior occurrences of the problem and knowledge of prior operating experience. Specifically, several condition reports were identified in the RCE where the licensee identified that a continuous and sufficient flow of data existed to identify the existence of this failure. Furthermore the licensee acknowledged that, although several opportunities existed, the site failed to recognize the importance of the SPING monitors with respect to the emergency plan.

Additionally a review of external industry operating experience was performed; however, the site did not identify any past issues related to this issue in the industry.

Based on the licensees detailed evaluation and conclusions, the inspectors determined that the licensees RCE included a consideration of prior occurrences of the problem and knowledge of prior operating experience.

The inspectors determined whether the licensees RCE addressed extent-of-condition and extent-of-cause of the problem. Specifically, the licensees RCE considered the extent-of-condition associated with unidentified adverse conditions related to EALs and also included all emergency preparedness-related equipment. All 48 channels of the SPING monitors were affected by the failure but were restored on the same day.

Additional equipment important to emergency preparedness with potential vulnerabilities was also identified. The revised Operations Turnovers, Logs and Briefings drives daily assessment of emergency preparedness equipment with subsequent identified failures processed through the work management procedure. These failures were previously addressed in the procedure, Equipment Important to Emergency Response, which was superseded when the plant entered into decommissioning. Lastly, radiation monitors in the auxiliary and containment buildings were found to be unaffected. All required emergency preparedness equipment was found to be functional upon the beginning of this inspection.

The licensees RCE also considered the extent-of-cause associated with the unidentified adverse conditions. The extent-of-cause took into account all categories of emergency preparedness equipment and vent stack monitors. All equipment was monitored by existing station processes such as control room annunciators and operator daily instrument checks except for the affected SPING monitors.

The inspectors assessed the issues identified during the licensees extent-of-cause and extent-of-condition evaluations and determined no violation of NRC requirements occurred.

Based on the licensees detailed evaluation and actions, the inspectors concluded that the licensees RCE addressed the extent-of-condition and the extent-of-cause of the issue.

The inspectors determined whether the licensees RCE, extent-of-condition, and the extent-of-cause appropriately considered safety culture components. Specifically, the licensees RCE, extent-of-condition, and the extent-of-cause considered safety culture components. The inspectors reviewed the RCE and validated the licensee had systematically considered each of the safety culture components. Four potential aspects, which included decision-making, work practices, CAP, and accountability, were identified. These insights were considered when addressing the root and contributing causes. Associated corrective actions contained appropriate elements to improve overall human performance.

Based on the licensees evaluation and conclusions, the inspectors determined that the licensees RCE, extent-of-condition, and the extent-of-cause appropriately considered safety culture components. The inspectors review of the event did not identify other potential weaknesses in safety culture components.

No findings were identified.

c. Evaluation of Inspection Requirements: Corrective Actions The inspectors determined whether the licensee specified appropriate corrective actions for each root/contributing cause, or that the licensee evaluated why no actions were necessary. Specifically, the licensees RCE specified corrective actions to address the root and contributing causes. The RCE identified the following root causes:

(1) programmatic requirements to periodically monitor instrument availability was inappropriate for equipment prioritized as emergency preparedness Category A and guidance provided for an alarming condition was inadequate to ensure status of

equipment was understood, evaluated, and compensatory actions put in place; and (2) the system platform was obsolete and difficult to maintain. The RCE identified the following contributing causes: (1) frequent nuisance alarms from the SPING monitors challenged the recognition of actual degradations of the SPING units leading to desensitization resulting in periods of non-functionality; (2) PPCS alarm points for SPING clear when the alarm is acknowledged, but do not lock-in.

The RCE identified the following short term corrective action, directing radiation protection (RP) to check Radserv health once per shift and if any indication other than Health OK is displayed, to notify Operations, write a condition report, and document the issue in to the logs per RP standing order 2012-05. The RCE identified the following corrective actions to prevent recurrence: (1) revising the procedure, Operations Turnovers, Logs and Briefings to institute requirements for operations to daily monitor and respond to PPCS Eberline Radiation Monitors screens; (2) institutionalize short-term corrective action RP standing order 2012-05 into the Radserv Control Terminal procedure; and (3) modify or replace the SPING units to improve system reliability. The RCE identified the following corrective actions for contributing causes: (1) conduct a performance analysis regarding the Radserv data and alarm response for inclusion into radiation protection standards, expectations, work control, and training materials; (2) conduct a needs analysis on SPINGS for operations regarding the RCE, local SPING operation, SPING/PPCS interaction and the Instructor Guide for Radiation Monitoring Guidance for inclusion into immediate, initial and continuing training; (3) develop an application for the PPCS so that critical SPING computer points identified in the Equipment Important to Emergency Response procedure cannot be cleared by acknowledging PPCS alarms; this application will lock alarm signal(s) and provide operations personnel a constant reminder of individual point status until condition is cleared.

Based on the licensees evaluation and conclusions, the inspectors concluded that the corrective actions implemented were appropriate to prevent recurrence of this issue.

The inspectors determined whether the licensee prioritized the corrective actions with consideration of the risk-significance and regulatory compliance. Specifically, the licensees RCE prioritized the corrective actions with consideration of the risk-significance and regulatory compliance. The licensees immediate corrective actions restored the SPING indication on the PPCS and Radserv station the same day the loss was identified. Additionally, a monitoring and response standing order for the system was also established on October 19, 2012.

The licensees corrective actions to address the root and contributing causes were prioritized in accordance with the corrective action and RCE procedures. With regard to open corrective actions, the corrective action to prevent recurrence, due September 30, 2014, is expected to be cancelled by the licensees corrective action review board pending approval of changes to KPS EALs submitted to the NRC as a result of the plants decommissioning status. A long term effectiveness review due March 29, 2015, also remains open. All other corrective actions resulting from the RCE were completed by December 6, 2013.

Based on the licensees prioritization and corrective action implementation, the inspectors concluded that the licensee adequately prioritized the corrective actions with consideration of the risk significance and regulatory compliance.

The inspectors determined whether the licensee established a schedule for implementing and completing the corrective actions. Specifically, the licensee adequately established a schedule for implementing and completing the corrective actions. As documented in the RCE, each corrective action identified an action, owner, and due date. All items were either completed or on schedule to be completed.

Based on the licensees documented actions, the inspectors concluded that the licensee adequately established and implemented corrective actions in accordance with the schedule.

The inspectors determined whether the licensee developed quantitative or qualitative measures of success for determining effectiveness of the corrective actions to prevent recurrence. Specifically, the licensees RCE developed quantitative or qualitative measures of success for determining effectiveness of the corrective actions to prevent recurrence. The corrective actions are specific and measurable. Specifically, daily checks of the instruments are now performed and documented which provides for an auditable record. Additionally, measures are in place to modify the equipment to make it more reliable or the licensee may request to change the requirements for this equipment.

Based on the licensees documented actions, the inspectors concluded that the licensee had adequately established measures to validate the effectiveness of the corrective actions to prevent recurrence of the issue.

The inspectors determined that the corrective actions planned or taken adequately addressed a Notice of Violation (NOV) that was the basis for the supplemental inspection. When the issue was identified, the licensee generated CR502665 which lead to the performance of RCE 001094. The licensees RCE documented that the finding associated with this issue had potential White safety significance. The NRC had not yet issued their final determination of safety significance and NOV associated with this issue at the time the RCE was performed. As such, the RCE did not discuss the NOV. However, in IR No. 05000305/2013504, Final Significance Determination of a White Finding with Proposed Followup and NOV, the NRC concluded that information regarding the reasons for the violation, the corrective actions taken and planned to be taken to correct the violation, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC IR No. 05000305/2012503.

No findings were identified.

10.3 Conclusion The inspectors determined that the licensees RCE was conducted to a level of detail commensurate with the significance of the problem, and reached reasonable conclusions as to the root and contributing causes of the event. The inspectors also concluded that the licensee identified reasonable and appropriate corrective actions for each root and contributing cause, and that the corrective actions appeared to be

prioritized commensurate with the safety significance of the issues. No other instance of the violations was identified. This violation is closed. (CLOSED VIO 05000305/2012503-01; DEGRADED EMERGENCY ACTION LEVEL SCHEME)

11.0 Exit Meeting The inspectors presented the results of the inspection to Mr. A. Jordan and other members of your staff at an onsite exit meeting on February 4, 2014. The licensee acknowledged the results presented and did not identify any of the information discussed as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED A. Jordan, Site Vice President R. Simmons, Plant Manager T. Olson, Assistant Plant Manager S. Yuen, Decommissioning Director J. Stafford, Safety and Licensing Director B. Harris, EP Manager M. Hale, Radiation Protection Manager J. Grau, Maintenance Manager M. Aulik, Engineering Manager M. Haese, Licensing R. Repshas, Licensing Manager J. Gadzala, Licensing Engineer E. Treptow, EP/Operations Specialist T. Olsowy, Technical Specialist T. Wattleworth, Fire Protection Design Engineer INSPECTION PROCEDURES (IPs) USED IP 36801 Organization and Management Controls at Permanently Shutdown Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 40801 Self-Assessment, Auditing and Corrective Action at Permanently Shutdown Reactors IP 42700 Plant Procedures IP 60801 Spent Fuel Pool Safety at Permanently Shutdown Reactors IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors IP 64704 Fire Protection Program IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Plants IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 71114.04 Emergency Action Level and Emergency Plan Changes IP 92702 Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders ITEMS OPENED, CLOSED, AND DISCUSSED Opened Type Summary 05000305/2013011-01 NCV Failure to Obtain Prior NRC approval for Emergency Plan Changes (Section 2.2.a)05000305/2013011-02 NCV Failure to Maintain an Acceptable On-Shift Staffing Analysis (Section 2.2.b)

Attachment

Closed Type Summary 05000305/2013011-01 NCV Failure to Obtain Prior NRC approval for Emergency Plan Changes (Section 2.2.a)05000305/2013011-02 NCV Failure to Maintain an Acceptable On-Shift Staffing Analysis (Section 2.2.b)05000305/2012503-01 VIO Degraded Emergency Action Level Scheme (Section 10.0)

PARTIAL LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

- AOI-83-LP045; Instructor Guide for Radiation Monitoring; Revision 3

- 2011 Annual Radioactive Effluent Release Report

- 2012 Annual Radioactive Effluent Release Report

- Calculation No. 2013-07050; Maximum Cladding Temperature Analysis for an Uncovered

- Spent Fuel Pool with no Air Cooling; Revision 2

- CY-KW-000-003, Attachment B; Chemistry Interlab Quality Control Sample Data Sheet;

- Various Documents Dated 4/10/2013

- CR507224; Amount of Sand Accumulation found in R-20 on 2/28/13 Reduced Sensitivity

- CR511025; R-20 Sample Flow on 23163 Sudden Decrease

- CR534828; RCE Extent of Condition

- CR534871; RCR 001094 Root Cause 2 Characterization

- CR533887; 1-501BKR inadvertently Tripped during Relay Maintenance

- CR533890; Radiation Protection Responded to CO2 Alarm

- CR534279: Request Work Orders to Control Check Source Removal During System 45

- Abandonment

- CR534387; Operations On-Shift Staffing and Administrative Controls

- CR531279; CR to Enhance SW Reliability Electrical Modification

- CR530854; Drill with Kewaunee Fire Department

- CR 538809, Failure to Receive Prior NRC Approval for Emergency Plan Changes

- CR 538810, Failure to Maintain the Effectiveness of the Emergency Plan

- DC-KW-12-01162; Cardox Pressure Relief Valve, SV, and Low Point Drain Vent

- Connections; 8/1/13

- DOM-QA-1; Nuclear Facility Quality Assurance Program Description; Revision 14

- Emergency Plan, Revision 37

- Evacuation Time Estimate Study Update, 11/30/2012

- EP-AA-303; Equipment Important to Emergency Response; Revision 5

- EP-AA-101 - Attachment 1, "KW-13-008"

- EP-AA-101 - Attachment 1, "KW-13-029"

- EP-AA-101 - Attachment 1, "KW-13-030"

- EP-AA-101 - Attachment 1, "KW-13-031"

- EP-AA-101 - Attachment 1, "KW-13-033"

- ETE-KW-2013-0020; Applicability of Flood Protection While Permanently Defueled;

- 10/10/13

- Figure EPMPFG-02.06-01, "KPS Shift Staff and ERO Position," Revision 6

- FPP-08-08; FP- Control of Transient Combustible Materials, Revision 11

- HP-05.017; RadServ Control Terminal; Revision 3

- Kewaunee Power Station Fire Protection Program Plan; Revision 12

- Kewaunee Power Station Fire Protection Program Analysis; Revision 10

- KPS On-Shift Staffing Analysis Report; Revision 0

- MA-KW-ICP-RM-057; Radiation Monitor Channel R-20 Sample Chamber Clean and Inspect;

- Revision 4

- MA-KW-MPM-DGM-010A; Barring Over Train A Emergency Diesel Generator; Revision 7

- Offsite Dose Calculation Manual; Revision 15

- NAD-05.13; Revision and Control of REMM and ODCM; Revision 18

- OP-KW-ORT-MISC-007; Operations Turnovers, Logs and Briefings; Revision 14

- OP-KW-OSP-RM-001; Radiation Monitors Monthly Source Check; Revision 0;

- OP-KW-601; Protected Equipment; Revision 7

- OP-KW-NOP-DGM-001A; Diesel Generator A Remote Operation; Revision 12

- OP-KW-OSP-MISC-002; Electrical Power System Weekly Surveillance Test; Revision 17

- OP-KW-AOP-GEN-004; Response to Natural Events; Revision 16

- OP-KW-AOP-GEN-005; Unplanned Barrier Control; Revision 11

- OP-KW-100; Conduct of Operations - SAFSTOR; Revision 3

- OP-KW-ORT-MISC-0015; Cold Weather Operations; Revision 5

- OP-KW-DEC-SYC-001; System Evaluation and Categorization; Revision 2

- ORT-MISC-007 ; Operations Turnovers, Logs and Briefings; Revision 14

- OU-KW-201; Decommissioning Safety Assessment Checklist; Revision 17

- PI-AA-200; Corrective Action; Revision 21

- PI-AA-300; Cause Evaluation; Revision 7

- PI-AA-300-3001; Root Cause Evaluation; Revision 4

- PI-AA-300-3004; Cause Evaluation Methods; Revision 2

- RCE 001094; SPING Monitor Indications; Revision 2

- Radiological Environmental Monitoring Manual; Revision 20

- Results of Radiochemistry Cross Check Program, First Quarter 2013; 4/1/ 2013

- RP Standing Order 2012-05; Revisions 0 and 1

- RP-KW-230; Personnel Contamination Monitoring and Decontamination; Revision 0

- RP-KW-104; Internal Radiation Exposure Control Program; Revision 0

- RP-KW-105; External Radiation Exposure Control Program; Revision 0

- RP-KW-123; Effective Dose Equivalent; Revision 0

- RP-KW-003-005; Dosimetry Record Keeping; Revision 0

- RPI-03-LP001; Emergency Radiation Protection Lesson Plan; Revision G

- SA-KW-FPP-010; Fire Protection Procedure; Revision 5

- SA-KW-EVL-GEN-001; Planned Barrier Impairment Control; Revision 6

- SP-45-049.20; RMS Channel R-20 Aux Building Service Water Return Radiation Monitor

- Quarterly Functional Test; Revision 18; Various Completed Procedures from January 2013

- to November 2013

- SP-45-050.20; RMS Channel R-20 Aux Building Service Water Return Radiation Monitor

- Calibration; Revision 18; Completed Procedure on 6/21/2012

- SP-45-230; Radiation Monitors Monthly Source Check; Various Completed Procedures from

- January 2013 to September 2013

- WM-KW-100; Work Management; Revision 2

- WO-KW-100954518; Pre-fab for DC-KW-12-01162 (Reroute CO2 Relief Valve Vents)

- WO-KW-100954517; DC-KW-01162 Installation (Reroute CO2 Relief Valve Vents)

- WO-KW100962563; KW-13-01061 - Revise Overcurrent Relay Settings for Breaker 1-405

- WO-KW100962765; Monthly Analysis of Spent Fuel Pool LIST OF ACRONYMS USED ACE Apparent Cause Evaluation ADAMS Agencywide Document Access and Management System ALARA As Low As Reasonably Achievable CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DEK Dominion Energy Kewaunee DG Diesel Generator DNMS Division of Nuclear Materials Safety EAL Emergency Action Level EPIP Emergency Plan Implementing Procedure ERO Emergency Response Organization IR Inspection Report IRET In-Plant Radiation Emergency Team KPS Kewaunee Power Station NCV Non-Cited Violation NOV Notice of Violation NRC U.S. Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PARS Publicly Available Records System PPCS Plant Process Computer System PSDAR Post Shutdown Activities Report RCE Root Cause Evaluation RG Regulatory Guide SAFSTOR Safe Storage of Spent Fuel SFP Spent Fuel Pool SPING System Particulate, Iodine, and Noble Gas TS Technical Specification USAR Updated Safety Analysis Report WO Work Order 4