ML051650258

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Reply to a Notice of Violation; EA-05-021
ML051650258
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 06/06/2005
From: Gaffney M
Nuclear Management Co
To:
Document Control Desk, NRC/RGN-III
References
ea-05-021, IR-04-009, NRC-05-061
Download: ML051650258 (5)
v • d • e


Text

sSM NMC Committed to Nuclear Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC June 6, 2005 NRC-05-061 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Kewaunee Nuclear Power Plant Docket 50-305 License No. DPR-43 Reply to a Notice of Violation: EA-05-021

References:

1) Letter from James L. Caldwell (NRC) to Craig W. Lambert (NMC),

"Kewaunee Nuclear Power Plant Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report 05000305/2004009),"

dated May 5, 2005

2) Letter from Thomas Kozak (NRC) to Craig W. Lambert (NMC),

"Regulatory Conference to Discuss a Preliminary Greater than Green Finding (NRC Inspection Report 50-305/2004-09) - Kewaunee Containment Equipment Hatch Interference," dated March 29, 2005

3) Letter from Mark A. Satorius (NRC) to Craig W. Lambert (NMC),

Preliminary Significance Determination For A Greater Than Green Finding (NRC Inspection Report 50-305/2004-09) - Kewaunee Containment Equipment Hatch Interference," dated February 18, 2005

4) Letter from Thomas Kozak (NRC) to Craig W. Lambert (NMC),

"Kewaunee Nuclear Power Plant NRC Integrated Inspection Report 05000305/2004009," dated February 14, 2005 Reference 1 transmitted a Notice of Violation, regarding the inability to rapidly close the containment equipment hatch, during cold shutdown conditions due to an interference, at the Kewaunee Nuclear Power Plant. Previously, Reference 2 had transmitted documentation of the associated Regulatory Conference held at the NRC Region III office on March 17, 2005. The Regulatory Conference had been requested, based on the options presented in Reference 3. Details of the issue relative to the containment equipment hatch were discussed in Reference 4, Section 1R20.b.2.

N490 Highway 42

  • Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2560 1

Document Control Desk Page 2 In accordance with 10 CFR 2.201, "Notice of Violation," the Nuclear Management Company, LLC (NMC) provides its response to the identified violation in the enclosure to this letter.

NMC does not contest the Notice of Violation.

This letter and enclosure contain no new commitments and no revisions to existing commitments. This letter and enclosure also do not include any personal privacy, proprietary, or safeguards information.

I declare under penalty of perjury that the foregoing is true and accurate. Executed on June 6, 2005.

Michael G.& fp)

Site Vice Presinewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosure cc: Administrator, Region Ill, USNRC Senior Resident Inspector, Kewaunee, USNRC Project Manager, Kewaunee, USNRC

ENCLOSURE I KEWAUNEE NUCLEAR POWER PLANT REPLY TO NOTICE OF VIOLATION EA-05-021 During an NRC Inspection conducted from October 1 through December 31, 2004, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Title 10 CFR Part 50, Appendix B, Criterion V, (Instructions, Procedures, and Drawings) requires, in part, that activities affecting quality be prescribed by documented instructions, or procedures of the type appropriate to the circumstances and shall be accomplished in accordance with these instructions, or procedures.

Kewaunee Nuclear Power Plant (KNPP) Procedure CMP-89A-02, "Containment Building Inner Equipment Door Opening and Closing Instructions", a procedure affecting quality, required that any equipment which passes through and could obstruct containment hatch closure be designed to allow rapid removal in order to ensure expeditious containment building equipment hatch closure should it become necessary to do so.

Contrary to the above, on October 11, 2004, the licensee installed in the containment an interior steel runway track, equipment which could obstruct the containment hatch closure, which was not designed to allow rapid removal in order to ensure expeditious containment building equipment hatch closure.

Specifically, the design of the interior steel runway track obstructed the containment hatch closure and could not be rapidly removed in order to permit an expeditious closure of the containment hatch should it become necessary to do so. In addition, the licensee did not develop or have in place procedures or plans to effect a rapid removal of the interior portion of the steel rail system to eliminate the interference.

This violation is associated with a White Significance Determination Process finding.

THE REASON FOR THE VIOLATION:

The violation occurred due to the following factors:

  • The interference between the interior steel runway track system and the equipment hatch, was not detected and corrected prior to the detensioning of the reactor vessel head.

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  • There was a failure to recognize what constitutes a potentially risk significant or consequential condition outside of the Technical Specifications or licensing basis.

Plant management, procedures, and training focused attention on the risks as described in the licensing basis as opposed to other possible or probable risk significant scenarios. The foundation for risk determination using Probabilistic Risk Assessment (PRA) is based on Core Damage Frequency as opposed to Large Early Release Frequency (LERF), Large Early Release Probability (LERP), and other risk significant conditions.

  • Kewaunee has selectively incorporated elements of industry guidance documents, such as those by Nuclear Energy Institute (NEI), Nuclear Management and Resources Council) NUMARC, Institute of Nuclear Power Operations (INPO), etc., without a sound documented basis for the parts of the recommendations or guidance that the site determines are not necessary. Incorporation of NUMARC 91-06 guidance is an example of this deficiency.

THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The following corrective actions have been completed:

  • The track runway was modified, by removing a portion of the interior runway to remove the interference, such that the equipment hatch door could be closed.

Removal of the runway section was accomplished via use of an acetylene torch.

Calculations were revised and design changes were made to allow for reinstallation of the removed portion of the runway. This action was completed on October 14, 2004.

  • An Extemal Operating Experience notification has been submitted to INPO (reference item OE20155).
  • Root Cause Evaluation RCE-668 relative to this event was completed and reviewed by the Kewaunee Corrective Action Review Board.
  • An Independent Review Group (IRG) was established to review engineering products to ensure the quality and completeness of the work.
  • Procedure CMP-89A-02, "Containment Building Inner Equipment Door Opening and Closing Instructions", has been revised. A step is added to ensure a physical clearance check, by closing and reopening the door, to validate possible interference from future obstructions (e.g. runways, scaffold, stored equipment, etc.).

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THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The following additional corrective actions will be taken:

  • Design, develop and deliver training to KNPP management staff on at-power and shutdown risk models for KNPP.
  • Revise the Shutdown PRA to specifically include LERF / LERP, and utilize this revised Shutdown PRA for schedule development for the next regular scheduled refueling outage.
  • Correct program / process risk vulnerabilities by implementing procedure and process changes, to explicitly recognize the risks already known to the industry in the Significant Determination Process, such as Emergency Preparedness, Security, etc.
  • Revise the Pre-Job Brief Checklist to emphasize the risk significance of the task /

work being performed.

  • Design, develop and deliver training to KNPP Operations staff on at-power and shutdown risk models for KNPP. The technical bases for this training would be the IPE, IPEEE, PRA, Shutdown PRA, Generic Letter 88-17, and NUMARC 91-06.
  • Develop and implement an industry guidance document review process.
  • Using the findings from a review of prior NEI, NUMARC, etc. commitments (gap analysis), and using the industry guidance document review process, modify site procedures to incorporate the applicable industry guidance.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

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