ML053190099
| ML053190099 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 11/14/2005 |
| From: | Matthews W Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 05-762 | |
| Download: ML053190099 (32) | |
Text
Dominion Energy Kewaunee, Inc.
5000 I)ornin~on Boulevdrd, Glen Allen, VA 2 3060 November 14, 2005 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 D Dominion Serial No.05-762 KPS/LIC/RR:
R4 Docket No.
50-305 License No.
DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION UPDATE ON IMPROVEMENT INITIATIVES This letter provides a status of the improvement initiative commitments that were initially defined in a letter dated March 18, 2005 (Letter No. NRC-05-035) entitled, Kewaunee Improvement Initiatives - Commitments. These commitments were subsequently endorsed and adopted with clarifications by Dominion Energy Kewaunee, Inc. in a letter from E. S. Grecheck to the NRC dated September 15, 2005 (Serial No.05-447) entitled, Endorsement and Adoption of Licensing Actions.
Kewaunee Power Station (KPS) has conducted several self assessments of performance since being acquired by Dominion. As a result, new commitments have been added to the improvement initiatives in Attachment 1. In addition to identifying the status of current commitments, it has also been reformatted. Attachment 2 provides a summary of the commitment additions and administrative clarifications to the previously submitted listing.
The Kewaunee management team remains committed to sustaining improved station performance.
We believe that these new and revised commitments will further strengthen the continuing performance improvement at Kewaunee.
This letter supersedes previous commitment letters regarding Kewaunee Improvement Initiatives.
If you have questions or require additional information, please feel free to contact Mr. Tom Breene at 920-388-8599.
Very truly yours, WM-Mr. William R. Matthews Sr. Vice President, Nuclear Operations Attachments (2)
Commitments made by this letter: As identified in Attachment 1.
Serial No.05-762 Docket No. 50-305 Page 2 of 2 cc :
Mr. J. L. Caldwell Administrator, Region U. S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road Suite 210 Lisle, I I Ii noi s 60532-4352 Mr. J. F. Stang Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-8-H-4a Washington, D. C. 20555 Mr. S. C. Burton NRC Senior Resident Inspector Kewaunee Power Station Serial No.05-762 Update on Improvement Initiatives Dominion Energy Kewaunee, Inc.
Kewaunee Power Station Serial No.05-762 Docket No. 50-305 1 0 Documented feedback from mentors.
Conduct a follow-up assessment for an effectiveness review 3Q05.
Improvement Initiatives FOCUS AREA: Operations Leadership
-rove Conduct of Operations and Operational Leadership Item 1 1.a 0 bjective Implement NMC Fleet Operations Mentoring Program to improve Conduct of Operations.
Summary of Commitment Steps Methods to Verify Commitment Met Commitment Completion Date To provide an immediate improvement in the Conduct of Operations, experienced SRO License holders from the NMC fleet have been temporarily placed on shift with the Kewaunee Operations crews to provide mentoring and feedback.
0 Fleet NOS observations.
Complete Complete
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Complete Page i of 26 Serial No.05-762 Docket No. 50-305 Item 1 (Contd) 1.b 1.c Objective Raise standards of performance within Operations.
mprove understanding of Nhat an Operations - led irganization looks like.
Summary of Commitment Steps This objective will be achieved by:
- 1.
- 2.
- 3.
- 4.
conducting a gap analysis between current conduct of Operations and industry best practices, improving annunciator response expectations, improving turnover and pre-shift brief expectations, and improving log keeping expectations anG operator at the controls expectations.
- 5. Implement Check Operator Program to provide feedback on standard ad he rence.
- 6. Implement Dominion Nuclear Operations Standards (DNOS).
To gain a broader perspective and improved understanding of what an Operations - led organization is, all Shift Managers will participate in a benchmarking trip to plants recommended by INPO or Dther industry groups.
Methods to Verify Commitment Met 0
Revised Conduct of Operations Procedure issued.
Assess as part of mentor follow-up effectiveness review 3Q05.
Check Operator Program implemented.
DNOS approved and issued.
Trip reports documenting benchmarking trip results, including improvement actions.
Com mi t ment Completion Date Complete Complete 4Q05 4Q06 Complete Page 2 of 26
Summary of Commitment Steps Methods to Verify Commitment Met To improve performance of the Operations Department, experienced personnel from INPO and the NMC fleet have been temporarily placed with Kewaunee Operations Training staff. This will provide an immediate improvement in the conduct of Operations Training, recognizing that additional actions will be initiated based on the scheduled self-assessment.
0 Documented feedback from mentors.
0 Self-assessment of the Operations Training Programs.
The self-assessment will include industry peers.
Serial No.05-762 Docket No. 50-305 Commitment Completion Date Complete Page 3 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Summary of Commitment Steps Item 1 (Con t 'd) 1.e Commitment Completion Date 1.f Conduct training.
Perform effectiveness review.
0 bject ive 0
Training attendance records.
Effectiveness review completed.
Improve the effectiveness of operational decision making.
Improve the understanding of License Requirements at KPS.
The Kewaunee Operational Decision Making procedure will be upgraded to align with a more effective operational decision making model, based on industry practices.
Appropriate training and/or briefing will be conducted upon implementation.
Effectiveness review of original procedure.
~
Operational Decision Making Procedure revision issued.
0 Training/briefing attendance records.
Complete Complete 1 Q06 I lQo6 0
Effectiveness review.
Develop a training instrument to increase understanding of Technical Specifications.
0 Developed training.
1 Q06 3Q06 4Q06 Page 4 of 26 Serial No.05-762 Docket No. 50-305 Item 1 (Contd) 0 bjective Improve Operations procedures Summary of Commitment Steps
- 1. Implement Westinghouse Owners Group (WOG) Revision 2 into Kewaunee Power Station Integrated Plant Emergency Operating Procedures (I P EO P) a Draft IPEOP based on WOG Emergency Response Guideline Revision 2.
Validate revised procedures.
Incorporate comments and approve procedures.
Train on and implement EOP.
- 2. Implement Dual Column Format
. Benchmark other Dominion and Industry sites for lists of typical EOP/AOPs (non-IPEOP).
Establish a list of KPS EOP/AOPs.
Abnormal Procedures Establish a Work-off curve to revise the listed KPS EOP/AOPs into 2-column format.
Methods to Verify Commitment Met 0
Revision drafted.
Procedures validated.
0 Procedures approved.
Training attendance records.
Benchmarking documented.
List published.
Work-off curve established.
Commitment Completion Date 2Q06 3Q06 4Q06 1 Q07 2Q06 2Q06 XI06 Page 5 of 26
Item 1 (Cont'd) 1.h Objective Improve Non-Licensed Revise the Nuclear Auxiliary Operator Program revised.
Operator Continuing training Training Program Description to improve program the focus on systems.
1 Methods to Verify Commitment Met Summary of Commitment Steps Develop, review, and approve the 2006-2007 Non-Licensed Operator continuing Two-Year Training Plan.
Develop, review and approve plan.
Perform effectiveness review.
Effectiveness review completed.
Serial No.05-762 Docket No. 50-305 Commit men t Completion Date 4Q05 4Q05 2Q06 Page 6 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Training attendance records.
1
Title:
Operability Determinations Commitment Completion Date Complete Item 2 2.a 2.b PORC concurrence of open operability determinations.
~
Objective Improve the quality of Operability Determinations.
Complete Validate the quality of existing open Operability Determinations.
Summary of Commitment Steps Combined Engineering and Operations training on Operability Determinations and Recommendations has been conducted.
The audience for this training was and will be Shift Managers, Shift Technical Advisors, and those Engineers qualified to perform Operability Recommendations.
I Effectiveness I4Q05 To confirm quality and applicability of the operability determinations for all Operable but Degraded and Operable but Non-conforming conditions, an independent review 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.
Documented summary of reviews.
Complete Page 7 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met FOCUS AREA: Configuration Management Corn mi tmen t ComDletion Date
Title:
Extent of Condition Reviews Documented assessment results.
Documented Item 3 Complete Complete 3.a 3.b Objective Confirm prior NRC commitments have been implemented as required.
Confirm assumptions made in critical engineering calculations that require operator actions to be performed within specific times, reflect actual operator response times.
Summary of Commitment Steps A representative sample of existing commitments will be performed to confirm the implementation of prior commitments that Kewaunee has made to the NRC.
A validation will be performed of all time critical operator actions assumed in engineering calculations for the top 19 high risk / low margin components prior to startup from the current outage.
The balance of the top 50 high-risk components will be completed by 4Q05.
Page 8 of 26
Item 3 (Contd) 3.c Assessments and plant walk downs are being conducted to identify significant 0 bjective Documented walk down results.
Provide reasonable assurance of design basis compliance for high-energy line breaks, tornados, flooding, and seismic events.
Methods to Verify Commitment Met Summary of Commitment Steps
- 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.
Serial No.05-762 Docket No. 50-305 Com mi tmen t Comdetion Date Complete Page 9 of 26 Serial No.05-762 Docket No. 50-305 4.a
Title:
Auxiliary Feedwater & Flooding Modifications
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Resolve auxiliary feedwater system operability concerns due to loss of suction from the Condensate System.
Item4 1 Objective Modifications will be implemented to restore operability of the auxiliary feedwater system. The scope of the modification will include re-routing of the auxiliary feedwater pump suction piping, and installation of a low suction pressure trip function.
Modification documents.
I 4.b Address the turbine building flooding concerns.
Modification and repairs will be completed to address the turbine building internal flooding issue.
Methods to Verify Commitment Met Summary of Commitment Steps 0
Modification documents.
4.c 4.d 4.e Commitment Completion Date Complete Reduce potential for residual heat removal pump pit flooding during shutdown.
Submit flooding licensing basis.
Resolve auxiliary feedwater local operator actions.
Implement modification to reduce flooding potential for RHR pump pits.
Complete 0
Approved design description, approved 10 CFR 50.59, completed work order.
4.f Submit flooding license amendment request.
Update PRA Model.
0 LAR submitted.
3Q06 1 Q06 The auxiliary feedwater system local manual operator actions as described in the license amendment request submitted May 5,2005, and supplemented on June 9, 2005 will be eliminated.
Incorporate turbine building flood modifications and operations procedure changes.
Local operator actions eliminated.
PRA Notebook issued.
No later than completion of Kewaunee refueling outage R-29 1 Q06 Page i 0 of 26 Serial No.05-762 Docket No. 50-305 0 bjective Validate and improve documentation of the design basis for:
Title:
Design Basis Documentation & Validation Summary of Commitment Steps A project plan will be developed and implemented to complete design basis topical reports.
Item 5 5.a Methods to Verify Commitment Met Internal flooding topical report completed.
High-energy line break topical report completed.
Commitment Completion Date 4Q05 4Q05
- 2. High Energy Line
- 3. Station Blackout,
- 4. Tornados, and
- 5. Seismic Events
- Breaks, Station blackout topical report completed.
Tornado topical report completed.
report completed.
Seismic topical 2Q06 3Q06 4006 Page i i oi 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met AFW System completed.
SW System completed.
Interim project progress review.
RHR System completed.
completed.
EDG completed.
CCW System Objective Item 5 (Con td)
Commitment Completion Date 1 Q06 2Q06 3Q06 3Q06 4Q06 1 Q07 5.b Summary of Commitment Steps Complete documentation and validation of the license bases for the safety functions of the most risk significant safety systems.
A project plan will be developed and implemented for the documentation and field validation of license bases for the safety functions of the Auxiliary Feedwater System, Service Water System, Residual Heat Removal System, Component Cooling Water System, and Emergency Diesel Generators, 4kV electrical system and DC electrical system.
4kV System completed.
I 4Q07 DC System completed.
Page 12 of 26 Serial No.05-762 Docket No. 50-305 Item 5 (Cont 'd) 5.c 5.d Objective Improve retrievability and control of calculations of record.
Updating of Environmental Qualification (EQ) Program.
Summary of Commitment Steps The following will be completed:
- 1. Complete populating the current safety related calculations into the calculation database, and
- 2. Incorporating cross-reference information of inputs/outputs between calculations.
Conduct a validation assessment of a sample of completed EQ program documents for adequacy in incorporating design basis information and assess prioritization of update plan.
Methods to Verify Commitment Met Electronic database population complete.
Cross-referencing between calculations in database complete.
Effectiveness review.
Perform assessment of completed file upgrades and plan.
Commitment Completion Date 1 Q06 1 Q06 2006 2Q06 Page 13 oi 26 Serial No.05-762 Docket No. 50-305 1
Title:
Electrical Calculations Objective Complete AC electrical models and calculations to provide clear bases for safety related settings and loads.
Complete DC electrical models and calculations to xovide clear bases for safety related settings and oads.
Summary of Commitment Steps Complete AC electrical calculations for:
- 1. load flow,
- 2. short-circuit currents,
- 3. EDG loading,
- 4. relay setting,
- 5. protection coordination,
- 6. control circuit voltage drops,
- 7. cable arnpacity, and
- 9. thermal overload relays.
~~
Somplete DC electrical calculations for:
1. battery sizing,
- 2. charger sizing,
- 3. voltage drop,
$. short-circuit currents,
- 5. control circuit voltage drops, and
- 3. breaker and fuse coordination.
Methods to Verify Commitment Met Interim project progress review 0
Interim project progress review.
Calculations completed, validated, and issued.
Interim project progress review.
0 Interim project progress review.
Calculations completed, validated and issued.
Commitment Completion Date 2Q06 4Q06 1 Q07 4Q06 2Q07 4Q07 Page 14 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Completed assessment report.
IRG implemented.
FOCUS AREA: Engineering Effectiveness Com mi tment Completion Date Complete Complete
Title:
Engineering Organizational Effectiveness 0
Engineering quality effectiveness review.
Item 7 4Q05 7.a Objective Improve the quality of Engineering products.
Summary of Commitment Steps An assessment of engineering has been conducted using NMC fleet and external expertise to identify the key areas for improvement and to develop associated action plans.
To improve the quality of Engineering products, an interim Independent Review Group (IRG) has been established to provide an in-line independent review or engineering products, including:
- 1. Operability Recommendations,
- 2. 10 CFR 50.59 evaluations,
- 3. calculations important to safety,
- 4. modifications important to safet!
0 and Training will be conducted to reinforce expectations regarding Engineering product quality.
0 Training attendance records.
Complete Page 15 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Summary of Commitment Steps Item 7 (Con td)
- 7. b 7.c Commitment Completion Date 7.d 0
Training attendance records.
Effectiveness review.
Rolesand responsibilities documented.
7.e Complete 2Q06 Complete Objective Establish System Engineering.
Improve Engineering knowledge and understanding of design and licensing bases.
I 4Q05 0
Dominion Assist Visit.
Improve the interface between Ope rat ion s,
Maintenance, and Engineering.
0 Implement Dominion Plant Health Reports.
Improve Station Engineering support.
1 Q06 Improve Equipment Reliability.
Team established.
1 Q06 Training will be conducted on design and licensing bases for Engineering personnel.
Roles and responsibilities for Operations, Maintenance, and Engineering as they relate to Engineering support will be examined and re-defined as necessary.
0 Effectiveness 14Q05 review.
Establish a Station Equipment Reliability Team (SERT) and Station Equipment Reliability Issues List (SERIL).
1 lQo6 List developed.
Page I6 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Summary of Commitment Steps I FOCUS AREA: Corrective Action Program Effectiveness Commitment Completion Date 1
Title:
Initiation & Screening Effectiveness 0
Generation of adverse trend CAPS.
Item 8 8.a 8.b 8.c Complete Objective Ensure station personnel are aware of their roles and responsibilities in the Corrective Action Program (CAP).
Validate the appropriateness 3f the significance level assigned for all currently Dpen conditions adverse to quality in the Corrective 4ction Program.
4ssure CAP trends are dentified and used in the ignificance and level of 3ffort assigned during CAP screening.
Actions will be taken to ensure that station personnel are aware of their roles and responsibilities as they pertain to the Corrective Action Program.
Implement a communications campaign to reinforce roles and responsibilities.
0 Employee briefings completed.
Complete New employee training program revised.
Copies of D-15 and presentation materials.
Complete 2Q06 An independent review of all open conditions adverse to quality in the Corrective Action Program is being completed.
0 Documented results of the assessment.
Complete Trend information related to repeat Corrective Action Program items will be provided to the daily Corrective Action Program screen team.
I 4Q05 0
Effectiveness review.
Page i i of 26
Objective Item 8 (Contd) 8.d Assure that managers recognize the significance of long standing issues.
Summary of Commitment Steps Training on risk significance will be provided to the management team. This training is also part of the corrective actions to prevent recurrence from the containment equipment hatch close root cause evaluation.
Methods to Verify Commitment Met 0
Training attendance records.
0 Assessments indicate no significant CAP prioritization errors. Goal is to have:
. No level A misclassif ications 2 90% level B issues properly classified.
Serial No.05-762 Docket No. 50-305 Commitment Comdetion Date Complete 4Q05 Page i 8 of 26 Serial No.05-762 Docket No. 50-305
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Title:
CAP Resolution Effectively Addresses Problems Item 9 9.a 9.b 9.c Objective Improve the quality of Apparent Cause Evaluations (ACEs).
Determine the effectiveness of the actions taken in 9.a.
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Improve the quality of causal evaluations.
Methods to Verify Commitment Met Summary of Commitment Steps The Corrective Action Program screening team will select Apparent Cause Evaluations that will be brought to the Corrective Action Review Board (CARB) for review upon completion. Feedback on the quality and grading will be provided to the authors.
Criteria established for ACE reviews to be completed by CARB.
AverageACE quality grade is 2 85 sustained over a 3-month period.
Nuclear Oversight (NOS) will review a selected sample of CARB-approved ACEs to determine the effectiveness of the actions taken and determine if the average quality of ACEs has been sustained at 2 85 over at least 3 months.
Nuclear Oversight report documenting results of the reviews.
Implement Dominion Nuclear Administrative Procedure (DNAP) 1604, Dominion Cause Evaluation Program.
and issued.
effectiveness review.
Commitment Completion Date Complete 2Q06 4Q05 2Q06 1 Q07 Page 19 of 26 Serial No.05-762 Docket No. 50-305 Validate the timeliness for resolution of current open
, significant issues.
Title:
Timeliness of Resolution of Significant Issues I
Item 10 1 Objective I
Summary of Commitment Steps Training completed.
1O.a 6 months after NRC approval.
1O.b Procedure revised.
6 months after NRC approval.
Assure operable but degraded / non-conforming issues are corrected in a timely manner.
1o.c An independent review is being conducted of all open corrective actions from level A and 6 action requests to validate the timeliness of resolution for significant issues.
Administrative procedures have been revised to include requirements for timely resolution of operable but degraded / non-conforming issues. As of March 15,2005, Upgrade the KPS Emergency Action Levels (EAL) to the NEI 99-01 EAL scheme as submitted to NRC on October 26, 2004.
Conduct training.
Implement new EALs.
Methods to Verify Commitment Met 0
Documentation of results from the review.
0 Revision to procedure GNP 1 1.08.01 issued.
March 15,2005 backlog of open operable but degraded / non-conforming conditions reduced by L 50%.
I Commitment Completion Date Complete 4Q05 4Q05 Page 20 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met I FOCUS AREA: Manager I Supervisor Effectiveness I
Commitment Completion Date
Title:
Individual Behavior Excellence Item 11 1 Objective 1
Summary of Commitment Steps 1l.a Communicate Kewaunee Picture of Excellence to employees to help facilitate sustained performance improvement.
Action steps to meet this objective include communicating and reinforcing the Picture of Excellence to improve accountability and individual behaviors. Training for managers and supervisors has begun, and will be completed prior to unit startup.
Training attendance records.
Complete Page 21 of 26 Serial No.05-762 Docket No. 50-305 Item 11 (Con td) 1l.b 0 bjec t ive Provide the necessary infrastructure and tools required to execute and reinforce the Picture of Excellence.
Summary of Commitment Steps The implementation steps include:
Incorporating ACEMAN into daily Plan Of the Next Day (POND) meetings, and Implementation of a daily meeting (D-
- 15) between supervisors and individual 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.
Methods to Verify Commitment Met implemented.
D-15 meetings ACEMAN grading employed at POND meetings.
0 Picture of Excellence and ACEMAN incorporated in to station Performance Man agemen t Plans.
Commitment Completion Date Complete Complete Complete Page 22 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Summary of Commitment Steps 0 bjective Item 11 (Con td)
Commitment Comdetion Date Assess staffing needs and qualification in Emergency Preparedness positions.
0 Assessment report.
1 1.c 2Q06 Build depth in Emergency Response Organization.
Train additional personnel.
Page 23 of 26 Training 3Q06 attendance records.
Serial No.05-762 Docket No. 50-305
Title:
Leadership Capabilities Item 12 12.a Objective Improve the leadership capability of supervisors in:
- 1. Operations
- 2. Operations Training
- 3. Engineering Summary of Commitment Steps A leadership assessment will be conducted for the:
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
Assistant Operations Managers, Shift Managers, Control Room Supervisors, Operations Instructors, Engineering Managers, and Engineering Supervisors.
The assessment will focus on leadership capabilities and capacity to implement a continuous improvement culture. Results of the assessments will be factored into individual improvement plans.
Methods to Verify Commitment Met Documented results of the assessments.
Individual Performance Management Plans updated with improvement areas.
Com mi tmen t Completion Date Complete Page 24 of 26 Serial No.05-762 Docket No. 50-305 Methods to Verify Commitment Met Summary of Commitment Steps Item 12 (Cont'd) 12.b 12.c Com mi tmen t Completion Date Objective Improve the leadership capability of supervisors in:
- 3. Outage and Planning Supervision
- 1. Maintenance
- 2. Chemistry
- 3. Outage and Planning
- 4. Emergency Planning
- 5. Radiation Protection Improve line manager ownership and accountability.
Management Plans updated
- 4. Emergency Planning Supervision
- 5. Radiation Protection Supervision A leadership assessment will be conducted for:
with improvement areas.
2Q06 3Q06
- 1. Maintenance Supervision
- 2. Chemistry Supervision 0
DNAPapproved and issued.
Documented results of the assessments.
4Q05 Individual Performance Station Self Evaluation Meeting (SSEM) held.
2Q06 3Q06 4Q05 Implement DNAP 01 14, Dominion Nuclear Self-Evaluation Program.
Page 25 of 26 Serial No.05-762 Docket No. 50-305
Title:
Nuclear Oversight Effectiveness Item 13 13.a 13.b Objective Improve Nuclear Oversight (NOS) effectiveness.
Strengthen Nuclear Oversight assessment processes.
Summary of Commitment Steps Implement mentors from other NMC sites for a period of 6 weeks, assign assessors to a functional area, and implement a rotation plan. An improvement plan addressing assessor performance will be developed which will include additional actions.
Implement Dominion Nuclear Oversight model which includes separate Specialist Assessment and Audit Programs.
Methods to Verifv 1
Commitment place.
Assessors assigned to functional areas.
Complete 0
Develop assessor improvement plan.
Complete 0
Review effectiveness of Nuclear Oversight processes.
3Q06 0
Establish and fill specialist positions.
1 Q06
Title:
Conservative Decision Making
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Item 14 14.a I
0 bj ect ive Improve understanding of conservative decision making by managers and supervisors.
Methods to Verify Commitment Met Summary of Commitment Steps Site management will conduct training on conservative decision making for managers and supervisors.
0 Training attendance records.
Commitment Completion Date Complete Page 26 of 26 Serial No.05-762 Summary of New Commitments and Administrative Clarifications Dominion Energy Kewaunee, Inc.
Kewaunee Power Station Serial No.05-762 Docket No. 50-305 Summary of New Commitments and Administrative Clarifications New commitments have been made in the following areas:
1.b 1.f 1 4 1.h 4.c 4.d 4.e 4.f 5.d 7.d 7.e 8.a 9.c 1o.c 1l.c 12.b 12.c 13.b Two new Commitment Steps added: to Implement Check Operator Program to provide feedback on standard adherence and to Implement Dominion Nuclear Operations Standards (DNOS).
New Objective to Improve the understanding of License Requirements at KPS.
New Objective to Improve Operations procedures.
New Objective to Improve Non-Licensed Operator Continuing training program.
New Objective to Reduce potential for residual heat removal pump pit flooding during shutdown.
New Objective to Submit flooding licensing basis.
New Objective to Resolve auxiliary feedwater local operator actions.
New Objective to Update PRA Model.
New Objective to Updating of Environmental Qualification (EQ) Program.
New Objective to Improve Station Engineering Support.
New Objective to Improve Equipment Reliability.
New Commitment Step to Implement a communications campaign to reinforce roles and responsibilities.
New Objective to Improve the quality of causal evaluations.
New Objective to Upgrade the KPS Emergency Action Levels (EAL) to the NEI 99-01 EAL scheme as submitted to NRC on October 26,2004.
New Objective to Build depth in Emergency Response Organization.
New Objective to Improve the leadership capability of supervisors in Maintenance, Chemistry, Outage and Planning, Emergency Planning, and Radiation Protection.
New Objective to Improve line manager ownership and accountability.
New Objective to Strengthen Nuclear Oversight assessment processes.
Clarifications have been made to the table as listed below:
1.e 4
5.b 5.c 6.a 6.b 7.a 8.d A completion date of 1Q06 has been identified for the training/briefing attendance records and an effectiveness review.
Title changed from Auxiliary Feedwater & Turbine Building Flooding Modifications to Auxiliary Feedwater & Flooding Modifications.
The final completion date has been changed to 4Q07.
A completion date of 2Q06 has been identified for the effectiveness review.
The interim progress review was clarified and commitment completion dates were added.
The interim progress review was clarified and commitment completion dates were added.
Added IRG Implemented as a Method to Verify the Commitment Met.
Clarification has been added to show that assessments will be performed in the 4Q05 to indicate there are no significant CAP prioritization errors.
Page 1 of 2 Serial No.05-762 Docket No. 50-305 9.a A completion date for Average ACE quality grade is 2 85 sustained over a 3-month period has been identified.
9.b The objective and commitment have been clarified.
10.b One of the Methods to Verify the Commitment Met was clarified from Current to March 15, 2005.
13.a Replaced the Methods to Verify Commitment Met Nuclear Industry Evaluation Program (NI EP) audit 3Q06 with Review effectiveness of Nuclear Oversight processes due 3Q06 and clarified the commitment.
The table of commitments has been reformatted as follows:
- 1) The column titled Summary and Status of Action Steps has been changed to
- 2) The column titled Methods to Verify Objective Met has been changed to Methods
- 3) The column Complete Date is now Commitment Completion Date and has been Summary of Commitment Steps.
to Verify Commitment met.
moved to the far right of the table with all completion dates identified there.
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