ML050820213

Transmittal of Improvement Initiatives Commitments

ML050820213
Person / Time
Site:	Kewaunee
Issue date:	03/18/2005
From:	Lambert C Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-05-035
Download: ML050820213 (21)

Text

Commtted to N Kewaunee Nuclear Power Plant

-e to

. Ex -Operated by Nuclear Management Company, LLC March 18, 2005 NRC-05-035 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Kewaunee Nuclear Power Plant Docket 50-305 License No. DPR-43 Kewaunee Improvement Initiatives -- Commitments On March 3, 2005, discussions were held with Nuclear Regulatory Commission (NRC)

Region IlIl representatives, relative to the Kewaunee Nuclear Power Plant (KNPP) improvement initiatives. The Nuclear Management Company, LLC (NMC) discussed.

the actions being taken that will be completed prior to unit re-start, and post unit re-start improvement areas.

As a follow-up to these discussions, the NMC is providing as an enclosure to this letter, a listing of commitments, which have been developed and will be completed, to address the following focus areas: Operations, Configuration Management, Engineering, Corrective Action, and Manager/Supervisor Effectiveness.

Summary of Commitments The NMC commitments are provided in Enclosure 1.

Lb i 44e Craig bert Site Vice-President, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosure (1) cc: Administrator, Region ll, USNRC Project Manager, Kewaunee, USNRC Senior Resident Inspector, Kewaunee, USNRC N490 Highway 42 . Kewaunee, Wisconsin 54216-951 0 Telephone: 920.388.2560

ENCLOSURE 1 Kewaunee Nuclear Power Plant Improvement Initiatives Commitments to the NRC 19 pages follow

FOCUS AREA: Operations Leadership

Title:

Improve Conduct of Operations and Operational Leadership Item 1 _ _ _ _ _

Objective

_ _ _ __ _ _ _ _ _ _ _Action Summary andStepsStatus of Complete Date Methods to Verify Objective Met 1.a Implement NMC Fleet To provide an immediate Prior to . Fleet NOS observations.

Operations Mentoring improvement in the Conduct of Startup from

• Documented feedback from Program to improve Conduct Operations, experienced SRO the Spring mentors.

of Operations. License holders from the NMC fleet 2005 mentors.

have been temporarily placed on Forced

• Conduct a follow-up shift with the Kewaunee Operations Outage assessment for an crews to provide mentoring and effectiveness review 3Q05.

feedback.

1.b Raise standards of This objective will be achieved by: 2Q05

• Revised Conduct of performance within 1. conducting a gap analysis Operations Procedure issued.

Operations. between current conduct of

• Assess as part of mentor Operations and industry best follow-up effectiveness review practices, 3Q05.

2. improving annunciator response expectations,

3. improving turnover and pre-shift brief expectations, and

4. improving log keeping expectations and "operator at the controls" expectations.

Page 1 of 19

Cont'd Objective Action Steps Complete Methods to Verify Objective Met 1.c Improve understanding of To gain a broader perspective and 2Q05

• Trip reports documenting what an Operations - led improved understanding of what an benchmarking trip results, organization looks like. Operations - led organization is, all including improvement Shift Managers will participate in a actions.

benchmarking trip to plants recommended by INPO or other industry groups.

1.d Improve Operations training. To improve performance of the 2Q05

• Documented feedback from Operations Department, mentors.

experienced personnel from INPO and the NMC fleet have been

• Self-assessment of the temporarily placed with Kewaunee Operations Training Programs.

Operations Training staff. This will The self-assessment will provide an immediate improvement include industry peers.

in the conduct of Operations Training, recognizing that additional actions will be initiated based on the scheduled self-assessment.

1.e Improve the effectiveness of The Kewaunee Operational 3Q05

• Operational Decision Making operational decision making. Decision Making procedure will be Procedure revision issued.

upgraded to align with a more effective operational decision . Training/briefing attendance making model, based on industry records.

practices. Appropriate training . Effectiveness review.

and/or briefing will be conducted upon implementation.

Page 2 of 19

Title:

Operability Determinations Item 2 Objective Summary and Status of Complete Methods to Verify Objective Met ec eAction Steps Date__ _ _ _ _ _ _ _ _ _ _ _ _ _

2.a Improve the quality of Combined Engineering and Prior to . Training attendance records.

Operability Determinations. Operations training on Operability Startup from Determinations and the Spring

• Effectiveness review 4Q05.

Recommendations has been 2005 Forced conducted. The audience for this Outage training was and will be Shift Managers, Shift Technical Advisors, and those Engineers qualified to perform Operability Recommendations.

2.b Validate the quality of To confirm quality and applicability Prior to . Documented summary of existing open Operability of the operability determinations for Startup from reviews.

Determinations. all Operable but Degraded and the Spring PORC concurrence of open Operable but Non-conforming 2005 Forced operability determinations.

conditions, an independent review Outage of the associated operability recommendations will be completed.

This review will encompass those which will remain open following startup from the spring 2005 forced outage.

Page 3 of 19

FOCUS AREA: Configuration Management

Title:

Extent of Condition Reviews Item 3 Objective Summary and Status of Complete Methods to Verify Objective Met

____Action Steps Date 3.a Confirm prior NRC A representative sample of existing Prior to

• Documented assessment commitments have been commitments will be performed to Startup from results.

implemented as required. confirm the implementation of prior the Spring commitments that Kewaunee has 2005 made to the NRC. Forced Outage 3.b Confirm assumptions made A validation will be performed of all Prior to . Documented assessment in critical engineering time critical operator actions Startup from results of top 19 components calculations, that require assumed in engineering calculations the Spring prior to startup from the operator actions to be for the top 19 high risk / low margin 2005 current outage.

performed within specific components prior to startup from the Forced times, reflect actual operator current outage. Outage response times.

The balance of the top 50 high risk 4Q05 . Documented results of top assessment 50 components components will be completed by 4Qo5.

4Q05.

Page4of 19

Item 3 Summary and Status of Complete (Cont'd) Objective Action Steps Date Methods to Verify Objective Met 3.c Provide reasonable Assessments and plant walk downs Prior to . Documented walk down assurance of design basis are being conducted to identify Startup from results.

compliance for high energy significant issues with high energy the Spring line breaks, tornados, line break, tornados, seismic and 2005 flooding, and seismic events. flooding. The walk downs are Forced designed to identify: Outage

1. potential vulnerabilities to pipe whip, and/or postulated concurrent equipment failures, and

2. potential component or structural failures that could impact the operability of safety-related equipment.

Page 5 of 19

Title:

Auxiliary Feedwater & Turbine Building Flooding Modifications Item 4 Objective Summary and Status of Complete Methods to Verify Objective Met Action Steps Date 4.a Resolve auxiliary feedwater Modifications will be implemented to Prior to

• Modification documents.

system operability concerns restore operability of the auxiliary Startup from due to loss of suction from feedwater system. The scope of the the Spring the Condensate System. modification will include re-routing of 2005 the auxiliary feedwater pump Forced suction piping, and installation of a Outage low suction pressure trip function.

4.b Address the turbine building Modification and repairs will be Prior to

• Modification documents.

flooding concerns. completed to address the turbine Startup from building internal flooding issue. the Spring 2005 Forced Outage Page 6 of 19

Title:

Design Basis Documentation & Validation Item 5 Objective Summary and Status of Complete Methods to Verify Objective Met jeieAction Steps Date _______________

5.a Validate and improve A project plan will be developed and 4Q06

• Internal flooding topical report documentation of the design implemented to complete design completed 4Q05.

basis for: basis topical reports.

• High energy line break topical

1. Internal Flooding, report completed 4Q05.

2. High Energy Line

• Station blackout topical report Breaks, completed 2006.

3. Station Blackout,

• Tornado topical report

4. Tornados, and completed 3Q06.

5. Seismic Events

• Seismic topical report completed 4Q06.

5.b Complete documentation A project plan will be developed and 3Q07

• Interim progress review.

and validation of the license implemented for the documentation bases for the safety and field validation of license bases . AFW System completed 1Q06.

functions of the most risk for the safety functions of the

• SW System completed 2Q06.

significant safety systems. Auxiliary Feedwater System, Service Water System, Residual Heat . RHR System completed 3Q06.

Removal System, Component

• CCW System completed 4Q06.

Cooling Water System, and Emergency Diesel Generators, 4kV

• EDG completed 1Q07.

electrical system and DC electrical

• 4kV System completed 2Q07.

system. DC System completed 4Q07.

Page 7 of 19

(Cont'd) Objective Summarycand Statusof CDmapete Methods to Verify Objective Met 5.c Improve retrievability and The following will be completed: 1Q06

• Electronic database population control of calculations of 1. Complete populating the current complete.

record. safety related calculations into

• Cross-referencing between the calculation database, and calculations in database

2. Incorporating cross-reference complete.

information of inputs/outputs

• Effectiveness review.

between calculations.

7-Page 8 of 19

Title:

Electrical Calculations Item 6 Objective Summary and Status of Complete Methods to Verify Objective Met Action Steps Date 6.a Complete AC electrical Complete AC electrical calculations 1Q07

• Interim progress review.

models and calculations to for:

• Calculations completed, provide clear bases for 1 load flow, validated, and issued.

safety related settings and loads. 2. short-circuit currents,

3. EDG loading,

4. relay setting,

5. protection coordination,

6. control circuit voltage drops,

7. cable ampacity, and

8. thermal overload relays.

6.b Complete DC electrical Complete DC electrical calculations 4Q07

• Interim progress review.

models and calculations to for:

• Calculations completed, provide clear bases for 1 battery sizing, validated and issued.

safety related settings and loads. 2. charger sizing,

3. voltage drop,

4. short-circuit currents,

5. control circuit voltage drops, and

6. breaker and fuse coordination.

Page 9 of 19

FOCUS AREA: Engineering Effectiveness

Title:

Engineering Organizational Effectiveness Item 7 Objective Summary and Status of Complete Methods to Verify Objective Met

__ ___ _ __ _ __ _Action Steps Date _ _ _ _ _ _ _ _ _ _ _ _ _ _

7.a Improve the quality of . An assessment of engineering Prior to

• Completed assessment report.

Engineering products. has been conducted using NMC Startup from fleet and external expertise to the Spring identify the key areas for 2005 improvement and to develop Forced associated action plans. Outage

• To improve the quality of Prior to Engineering quality Engineering products, an interim Startup from effectiveness review 4Q05.

Independent Review Group the Spring (IRG) has been established to 2005 provide an in-line independent Forced review or engineering products, Outage including:

1. Operability Recommendations,

2. 10 CFR 50.59 evaluations,

3. calculations important to safety, and

4. modifications important to safety.

• Training will be conducted to 4Q05

• Training attendance records.

reinforce expectations regarding Engineering product quality.

Page 10 of 19

Item 7 Objective Summary and Status of Complete MethodstoVerifyObjectiveMet (Cont'd) OecieAction Steps Date MehdtoVrfObcivMt 7.b Improve Engineering Training will be conducted on design 4Q05

• Training attendance records.

knowledge and and licensing bases for Engineering . Effectiveness review 2Q06.

understanding of design personnel.

and licensing bases.

7.c Improve the interface Roles and responsibilities for 3Q05

• Roles and responsibilities between Operations, Operations, Maintenance, and documented.

Maintenance, and Engineering as they relate to Engineering. Engineering support will be

• Effectiveness review 4Q05.

examined and re-defined as necessary.

Page 11 of 19

FOCUS AREA: Corrective Action Program Effectiveness

Title:

Initiation & Screening Effectiveness Item 8 Objective Summary and Status of Complete Methods to Verify Objective Met

_ _ _ _ _Action Steps Date __ _ _ _ _ _ _ _ _ _ _ _ _ _

8.a Ensure station personnel Actions will be taken to ensure that 3Q05

• Employee briefings completed.

are aware of their roles station personnel are aware of their and responsibilities in the roles and responsibilities as they

• New employee training program Corrective Action Program pertain to the Corrective Action revised.

(CAP). Program.

8.b Validate the An independent review of all open Prior to

• Documented results of the appropriateness of the conditions adverse to quality in the Startup assessment.

significance level assigned Corrective Action Program is being from the for all currently open completed. Spring conditions adverse to 2005 quality in the Corrective Forced Action Program. Outage 8.c Assure CAP trends are Trend information related to repeat Prior to

• Generation of adverse trend identified and used in the CAP items will be provided to the Startup CAPs.

significance and level of daily CAP screen team. from the effort assigned during CAP Spring

• Effectiveness review 4Q05.

screening. 2005 Forced Outage Page 12 of 19

(Cont'd) Objective Action Steps Complete Methods to Verify Objective Met 8.d Assure that managers Training on risk significance will be 3Q05

• Training attendance records.

recognize the significance provided to the management team.

of long standing issues. This training is also part of the significant CAP prioritization corrective actions to prevent essments todiave:

recurrence from the containment errors. Goal is to have:

equipment hatch close root cause

• No level "A" evaluation. misclassifications

• 2 90% level "B" issues properly classified.

Page 13 of 19

Title:

CAP Resolution Effectively Addresses Problems Item 9 Objective Summary and Status of Complete Methods to Verify Objective Met Action Steps Date 9.a Improve the quality of The Corrective Action Program Prior to

• Criteria established for ACE Apparent Cause screening team will select Apparent Startup reviews to be completed by Evaluations (ACEs). Cause Evaluations that will be from the CARB.

brought to the Corrective Action Spring Review Board (CARB) for review 2005 . Average ACE quality grade is 2 upon completion. Feedback on the Forced 85 sustained over a 3-month quality and grading will be provided Outage period.

to the authors.

9.b Assure corrective actions Nuclear Oversight (NOS) will 4Q05 . NOS reports documenting have effectively resolved perform a review of corrective results of the reviews.

the issues. actions to ensure that the corrective actions taken effectively resolve the condition identified.

Page 14 of 19

Title:

Timeliness of Resolution of Significant Issues Item 10 Objective Summary and Status of Complete Methods to Verify Objective Met jeieAction Steps Date _______________

10.a Validate the timeliness for An independent review is being Prior to . Documentation of results from resolution of current open conducted of all open corrective Startup the review.

significant issues. actions from level "A"and "B" action from the requests to validate the timeliness of Spring resolution for significant issues. 2005 Forced Outage 10.b Assure operable but Administrative procedures have 4Q05 . Revision to procedure GNP degraded / non-conforming been revised to include 11.08.01 issued.

issues are corrected in a requirements for timely resolution of timely manner. operable but degraded / non- operable but degraded I non-conforming issues. As of March 15, conforming conditions reduced 2005, 28 open OBDs remain. by 50%. c Page 15 of 19

FOCUS AREA: Manager / Supervisor Effectiveness

Title:

Individual Behavior Excellence Item 11 Objective Summary and Status of Complete Methods to Verify Objective Met

_______ __________________Action Steps Date _______________

11.a Communicate Kewaunee Action steps to meet this objective 2Q05

• Training attendance records.

"Picture of Excellence" to include communicating and employees to help facilitate reinforcing the "Picture of sustained performance Excellence" to improve improvement. accountability and individual behaviors. Training for managers and supervisors has begun, and will be completed prior to unit startup.

Page 16 of 19

Itemd 11 Objective Actiorn Steps Date Methods to Verify Objective Met 11 .b Provide the necessary The implementation steps include: 2Q05

• D-15 meetings implemented.

infrastructure and tools required to execute and . Incorporating ACEMAN into . ACEMAN grading employed at reinforce the "Picture of daily Plan Of the Next Day POND meetings.

Excellence". (POND) meetings, and "Picture of Excellence" and

• Implementation of a daily ACEMAN incorporated into meeting (D-15) between station Performance supervisors and individual Management Plans.

contributors. The purpose of the D-15 meetings is to improve communication between employees, supervisors and managers. They are designed to enhance the information flow between employees and all levels of management and create an environment for open communication.

• Alignment of Performance Management Plans to the "Picture of Excellence"

• Establishing monthly Picture of Excellence Review Group (PERG) meetings to foster accountability for implementation of the site Excellence Plans.

Page 17 of 19

Title:

Leadership Capabilities Item 12 Objective Action Steps Date Methods to Verify Objective Met 12.a Improve the leadership A leadership assessment will be Operations . Documented results of the capability of supervisors in: conducted for the: and assessments.

1. Operations, 1. Assistant Operations Managers, Operations

• Individual Performance

2. Operations Training, 2. Shift Managers, be Management Plans updated and 3. Control Room Supervisors, completed with improvement areas.

3. Engineering. 4. Operations Instructors,

5. Engineering Managers, and Engineering

6. Engineering Supervisors. will be The assessment will focus on completed leadership capabilities and capacity 3Q05 to implement a continuous improvement culture. Results of the assessments will be factored into individual improvement plans.

Page 18 of 19 I

Title:

Nuclear Oversight Effectiveness Item 13 Objective Summary and Status of Complete Methods to Verify Objective Met Action Steps Date 13.a Improve Nuclear Oversight Implement mentors, assign 3Q05

• Rotation policy in-place.

(NOS) effectiveness. assessors to a functional area, and implement a rotation plan. An

• Assessors assigned to improvement plan will be developed functional areas.

which will include additional actions. . Develop improvement plan.

• Nucleaf Industry Evaluation Program (NIEP) audit 3Q06.

Title:

Conservative Decision Making Item 14 Objective Summary and Status of Complete Methods to Verify Objective Met Action Steps Date 14.a Improve understanding of Site management will conduct 2Q05 . Training attendance records.

conservative decision training on conservative decision making by managers and making for managers and supervisors. supervisors.

Page 19 of 19