ML053190099

Update on Improvement Initiatives

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.

5 0 0 0 I ) o r n i n ~ o nBoulevdrd, Glen Allen, VA 2 3060 November 14, 2005 D Dominion U. S. Nuclear Regulatory Commission Serial No.05-762 Attention: Document Control Desk KPS/LIC/RR: R4 Washington, DC 20555 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, II Iinois 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

Attachment 1 Serial No.05-762 Update on Improvement Initiatives Dominion Energy Kewaunee, Inc.

Kewaunee Power Station

Attachment 1 Serial No.05-762 Docket No. 50-305 Attachment 1 Improvement Initiatives FOCUS AREA: Operations Leadership

-rove Conduct of Operations and Operational Leadership Commitment Methods to Verify Item 1 0bjective Summary of Commitment Steps Completion Commitment Met Date 1.a Implement NMC Fleet To provide an immediate improvement in 0 Fleet NOS Complete Operations Mentoring the Conduct of Operations, experienced observations.

Program to improve Conduct SRO License holders from the NMC fleet of Operations. have been temporarily placed on shift with 1 0 Documented Complete the Kewaunee Operations crews to provide feedback from mentoring and feedback. mentors.

~

Conduct a follow- Complete up assessment for an effectiveness review 3Q05.

Page i of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Item 1 Commit ment Objective Summary of Commitment Steps Methods to Verify (Contd) Commitment Met Completion Date 1.b Raise standards of This objective will be achieved by: 0 Revised Conduct of Complete performance within Operations Operations. 1. conducting a gap analysis between Procedure issued.

current conduct of Operations and industry best practices, Assess as part of Complete mentor follow-up

2. improving annunciator response effectiveness expectations, review 3Q05.

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

4. improving log keeping expectations anG operator at the controls expectations.

5. Implement Check Operator Program to Check Operator 4Q05 provide feedback on standard Program adherence. implemented.

6. Implement Dominion Nuclear DNOS approved 4Q06 Operations Standards (DNOS). and issued.

1.c mprove understanding of To gain a broader perspective and Trip reports Complete Nhat an Operations - led improved understanding of what an documenting irganization looks like. Operations - led organization is, all Shift benchmarking trip Managers will participate in a benchmarking results, including trip to plants recommended by INPO or improvement Dther industry groups. actions.

Page 2 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Commitment Methods to Verify Summary of Commitment Steps Completion Commitment Met Date To improve performance of the Operations 0 Documented Complete Department, experienced personnel from feedback from INPO and the NMC fleet have been mentors.

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 Self-assessment of the Operations Training Programs.

The self-assessment will include industry peers.

Page 3 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Commitment Item 1 Methods to Verify 0bjective Summary of Commitment Steps Completion (Cont 'd) Commitment Met Date 1.e Improve the effectiveness of The Kewaunee Operational Decision Effectiveness Complete operational decision making. Making procedure will be upgraded to align review of original with a more effective operational decision procedure.

making model, based on industry practices. ~

Appropriate training and/or briefing will be Operational Complete conducted upon implementation. Decision Making Procedure revision issued.

0 Training/briefing 1Q06 attendance records.

1.f Improve the understanding Develop a training instrument to increase 0

0 Effectiveness review.

Developed training.

I lQo6 1Q06 of License Requirements at understanding of Technical Specifications.

KPS.

Conduct training. 0 Training 3Q06 attendance records.

Perform effectiveness review. Effectiveness 4Q06 review completed.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Commitment Item 1 Methods to Verify (Contd) 0bjective Summary of Commitment Steps Completion Commitment Met Date Improve Operations 1. Implement Westinghouse Owners procedures Group (WOG) Revision 2 into Kewaunee Power Station Integrated Plant Emergency Operating Procedures (IPEOP) a Draft IPEOP based on WOG 0 Revision drafted. 2Q06 Emergency Response Guideline Revision 2.

Validate revised procedures.

Procedures 3Q06 validated.

Incorporate comments and approve 0 Procedures procedures. 4Q06 approved.

Train on and implement EOP.

Training attendance 1 Q07 records.

2. Implement Dual Column Format Abnormal Procedures

. Benchmark other Dominion and Industry sites for lists of typical Benchmarking documented.

2Q06

. EOP/AOPs (non-IPEOP).

Establish a list of KPS EOP/AOPs. List published. 2Q06 Establish a Work-off curve to revise Work-off curve XI06 the listed KPS EOP/AOPs into 2- established.

column format.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 1 (Cont'd)

Objective Summary of Commitment Steps 1 Methods to Verify Commitment Met Commitment Completion Date 1.h Improve Non-Licensed Revise the Nuclear Auxiliary Operator Program revised. 4Q05 Operator Continuing training Training Program Description to improve program the focus on systems.

Develop, review, and approve the 2006- Develop, review 4Q05 2007 Non-Licensed Operator continuing and approve plan.

Two-Year Training Plan.

Perform effectiveness review. Effectiveness 2Q06 review completed.

Page 6 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 1

Title:

Operability Determinations ~

Item 2 Objective Summary of Commitment Steps Methods to Verify Commitment Commitment Met Completion Date 2.a Improve the quality of Combined Engineering and Operations Training Complete Operability Determinations. training on Operability Determinations and attendance Recommendations has been conducted. records.

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 2.b Validate the quality of To confirm quality and applicability of the Documented Complete existing open Operability operability determinations for all Operable summary of Determinations. but Degraded and Operable but Non- reviews.

conforming conditions, an independent review of the associated operability recommendationswill be completed. This review will encompass those which will PORC Complete remain open following startup from the concurrence of spring 2005 forced outage. open operability determinations.

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Attachment 1 Serial No.05-762 Docket No. 50-305 FOCUS AREA: Configuration Management

Title:

Extent of Condition Reviews Item 3 Objective Summary of Commitment Steps Methods to Verify Cornmitment Commitment Met ComDletion Date 3.a Confirm prior NRC A representative sample of existing Documented Complete commitments have been commitments will be performed to confirm assessment implemented as required. the implementation of prior commitments results.

that Kewaunee has made to the NRC.

3.b Confirm assumptions made A validation will be performed of all time Documented Complete in critical engineering critical operator actions assumed in calculations that require engineering calculations for the top 19 high operator actions to be risk / low margin components prior to performed within specific startup from the current outage.

times, reflect actual operator response times.

The balance of the top 50 high-risk components will be completed by 4Q05.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 3 Methods to Verify Commitment 0bjective Summary of Commitment Steps (Contd) Commitment Met Comdetion Date 3.c Provide reasonable Assessments and plant walk downs are Documented walk Complete assurance of design basis being conducted to identify significant down results.

compliance for high-energy line breaks, tornados, flooding, and seismic events.

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.

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Attachment 1 Serial No.05-762 Docket No. 50-305

Title:

Auxiliary Feedwater & Flooding Modifications Item4 1 ~

Objective Summary of Commitment Steps Methods to Verify Commitment Met Commitment Completion Date 4.a Resolve auxiliary feedwater Modifications will be implemented to Modification Complete system operability concerns restore operability of the auxiliary documents.

due to loss of suction from feedwater system. The scope of the the Condensate System. modification will include re-routing of the auxiliary feedwater pump suction piping, and installation of a low suction pressure trip function.

I 4.b Address the turbine building Modification and repairs will be completed 0 Modification Complete flooding concerns. to address the turbine building internal documents.

flooding issue.

4.c Reduce potential for residual Implement modification to reduce flooding 0 Approved design 3Q06 heat removal pump pit potential for RHR pump pits. description, flooding during shutdown. approved 10 CFR 50.59, completed work order.

4.d Submit flooding licensing Submit flooding license amendment 0 LAR submitted. 1Q06 basis. request.

4.e Resolve auxiliary feedwater The auxiliary feedwater system local Local operator No later than local operator actions. manual operator actions as described in actions eliminated. completion of the license amendment request submitted Kewaunee refueling May 5,2005, and supplemented on June outage R-29 9, 2005 will be eliminated.

4.f Update PRA Model. Incorporate turbine building flood PRA Notebook 1Q06 modifications and operations procedure issued.

changes.

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Attachment 1 Serial No.05-762 Docket No. 50-305

Title:

Design Basis Documentation & Validation Item 5 0bjective Summary of Commitment Steps Methods to Verify Commitment Commitment Met Completion Date 5.a Validate and improve A project plan will be developed and Internal flooding 4Q05 documentation of the design implemented to complete design basis topical report basis for: topical reports. completed.

1. Internal Flooding, High-energy line 4Q05 break topical report

2. High Energy Line completed.

Breaks, Station blackout 2Q06

3. Station Blackout, topical report completed.

4. Tornados, and Tornado topical 3Q06

5. Seismic Events report completed.

Seismic topical 4006 report completed.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 5 Methods to Verify Commitment Objective Summary of Commitment Steps (Contd) Commitment Met Completion Date 5.b Complete documentation A project plan will be developed and AFW System 1Q06 and validation of the license implemented for the documentation and completed.

bases for the safety field validation of license bases for the functions of the most risk safety functions of the Auxiliary SW System 2Q06 significant safety systems. Feedwater System, Service Water completed.

System, Residual Heat Removal System, Component Cooling Water System, and Interim project 3Q06 Emergency Diesel Generators, 4kV progress review.

electrical system and DC electrical system. RHR System 3Q06 completed.

CCW System 4Q06 completed.

EDG completed. 1Q07 4kV System completed.

DC System completed. I 4Q07 Page 12 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Item 5 Methods to Verify Commitment Objective Summary of Commitment Steps (Cont'd) Commitment Met Completion Date 5.c Improve retrievability and The following will be completed: Electronic database 1Q06 control of calculations of population complete.

record. 1. Complete populating the current safety related calculations into the calculation database, and Cross-referencing 1Q06

2. Incorporating cross-reference between calculations information of inputs/outputs between in database calculations. complete.

Effectiveness review. 2006 5.d Updating of Environmental Conduct a validation assessment of a Perform assessment 2Q06 Qualification (EQ) Program. sample of completed EQ program of completed file documents for adequacy in incorporating upgrades and plan.

design basis information and assess prioritization of update plan.

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Attachment 1 Serial No.05-762 Docket No. 50-305 1

Title:

Electrical Calculations Objective Methods to Verify Commitment Summary of Commitment Steps Commitment Met Completion Date Complete AC electrical Complete AC electrical calculations for: Interim project 2Q06 models and calculations to progress review provide clear bases for 1. load flow, safety related settings and loads. 2. short-circuit currents, 0 Interim project 4Q06 progress review.

3. EDG loading,

4. relay setting, Calculations 1Q07 completed,

5. protection coordination, validated, and issued.

6. control circuit voltage drops,

7. cable arnpacity, and

9. thermal overload relays.

~~

Complete DC electrical Somplete DC electrical calculations for: Interim project 4Q06 models and calculations to progress review.

xovide clear bases for 1 . battery sizing, safety related settings and

2. charger sizing, 0 Interim project 2Q07 oads.

progress review.

3. voltage drop, Calculations 4Q07

$. short-circuit currents, completed, validated and

5. control circuit voltage drops, and issued.

3. breaker and fuse coordination.

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Attachment 1 Serial No.05-762 Docket No. 50-305 FOCUS AREA: Engineering Effectiveness

Title:

Engineering Organizational Effectiveness Item 7 Objective Methods to Verify Commitment Summary of Commitment Steps Commitment Met Completion Date 7.a Improve the quality of An assessment of engineering has Completed Complete Engineering products. been conducted using NMC fleet and assessment report.

external expertise to identify the key areas for improvement and to develop associated action plans.

0 To improve the quality of Engineering IRG implemented. Complete products, an interim Independent Review Group (IRG) has been established to provide an in-line independent review or engineering products, including:

1. Operability Recommendations, 0 Engineering quality 4Q05 effectiveness

2. 10 CFR 50.59 evaluations, review.

3. calculations important to safety, and

4. modifications important to safet!

Training will be conducted to reinforce 0 Training Complete expectations regarding Engineering attendance product quality. records.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 7 Methods to Verify Commitment Objective Summary of Commitment Steps (Contd) Commitment Met Completion Date 7.b Improve Engineering Training will be conducted on design and 0 Training Complete knowledge and licensing bases for Engineering attendance understanding of design and personnel. records.

licensing bases.

Effectiveness 2Q06 review.

7.c Improve the interface Roles and responsibilities for Operations, Rolesand Complete between Operations , Maintenance, and Engineering as they responsibilities Maintenance, and relate to Engineering support will be documented.

Engineering. examined and re-defined as necessary.

0 Effectiveness 14Q05 review.

7.d Improve Station Engineering Establish System Engineering.

support.

0 0

Dominion Assist Visit.

Implement I 4Q05 1Q06 Dominion Plant Health Reports.

7.e Improve Equipment Establish a Station Equipment Reliability Team established. 1Q06 Reliability. Team (SERT) and Station Equipment Reliability Issues List (SERIL).

List developed.

1 lQo6 Page I6 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 I FOCUS AREA: Corrective Action Program Effectiveness 1

Title:

Initiation & Screening Effectiveness Methods to Verify Commitment Item 8 Objective Summary of Commitment Steps Commitment Met Completion Date 8.a Ensure station personnel are Actions will be taken to ensure that station 0 Employee Complete aware of their roles and personnel are aware of their roles and briefings responsibilities in the responsibilities as they pertain to the completed.

Corrective Action Program Corrective Action Program.

(CAP). New employee Complete training program revised.

Implement a communications campaign to Copies of D-15 2Q06 reinforce roles and responsibilities. and presentation materials.

8.b Validate the appropriateness An independent review of all open 0 Documented Complete 3f the significance level conditions adverse to quality in the results of the assigned for all currently Corrective Action Program is being assessment.

Dpen conditions adverse to completed.

quality in the Corrective 4ction Program.

8 .c 4ssure CAP trends are Trend information related to repeat 0 Generation of Complete dentified and used in the Corrective Action Program items will be adverse trend ignificance and level of provided to the daily Corrective Action CAPS.

3ffort assigned during CAP Program screen team.

screening. 0 Effectiveness review.

I 4Q05 Page i i of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Item 8 Methods to Verify Commitment Objective Summary of Commitment Steps (Contd) Commitment Met Comdetion Date 8.d Assure that managers Training on risk significance will be 0 Training Complete recognize the significance provided to the management team. This attendance of long standing issues. training is also part of the corrective actions records.

to prevent recurrence from the containment equipment hatch close root cause evaluation.

0 Assessments 4Q05 indicate no significant CAP prioritization errors. Goal is to have:

. No level A misclassifications

. 2 90% level B issues properly classified.

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Attachment 1 Serial No.05-762 Docket No. 50-305

~

Title:

CAP Resolution Effectively Addresses Problems Methods to Verify Commitment Item 9 Objective Summary of Commitment Steps Commitment Met Completion Date 9.a Improve the quality of The Corrective Action Program screening Criteria Complete Apparent Cause Evaluations team will select Apparent Cause established for (ACEs). Evaluations that will be brought to the ACE reviews to Corrective Action Review Board (CARB) for be completed by review upon completion. Feedback on the CARB.

quality and grading will be provided to the authors. AverageACE 2Q06 quality grade is 2 85 sustained over a 3-month period.

9.b Determine the effectiveness Nuclear Oversight (NOS) will review a Nuclear 4Q05 of the actions taken in 9.a. selected sample of CARB-approved ACEs Oversight report to determine the effectiveness of the documenting actions taken and determine if the average results of the quality of ACEs has been sustained at 2 85 reviews.

over at least 3 months.

~

9.c Improve the quality of causal Implement Dominion Nuclear 2Q06 evaluations. Administrative Procedure (DNAP) 1604, and issued.

Dominion Cause Evaluation Program.

1Q07 effectiveness review.

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Attachment 1 Serial No.05-762 Docket No. 50-305

Title:

Timeliness of Resolution of Significant Issues Item 10 1 Objective I Summary of Commitment Steps Methods to Verify Commitment Met Commitment Completion Date 1O.a Validate the timeliness for An independent review is being conducted 0 Documentation of Complete resolution of current open of all open corrective actions from level A results from the

, significant issues. and 6action requests to validate the review.

timeliness of resolution for significant issues.

1O.b Assure operable but Administrative procedures have been 0 Revision to 4Q05 degraded / non-conforming revised to include requirements for timely procedure GNP issues are corrected in a resolution of operable but degraded / non- 1 1.08.01 issued.

timely manner. conforming issues. As of March 15,2005, March 15,2005 4Q05 backlog of open operable but degraded / non-conforming conditions reduced by L 50%.

I I 1o.c Upgrade the KPS Conduct training. Training completed. 6 months after NRC Emergency Action Levels approval.

(EAL) to the NEI 99-01 EAL scheme as submitted to Implement new EALs. Procedure revised. 6 months after NRC NRC on October 26, 2004. approval.

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Attachment 1 Serial No.05-762 Docket No. 50-305 I FOCUS AREA: Manager I Supervisor Effectiveness I

Title:

Individual Behavior Excellence Item 11 1 Objective 1 Summary of Commitment Steps Methods to Verify Commitment Met Commitment Completion Date 1l.a Communicate Kewaunee Action steps to meet this objective include Training Complete Picture of Excellence to communicating and reinforcing the Picture attendance employees to help facilitate of Excellence to improve accountability records.

sustained performance and individual behaviors. Training for improvement. managers and supervisors has begun, and will be completed prior to unit startup.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 11 Methods to Verify Commitment 0bject ive Summary of Commitment Steps (Contd) Commitment Met Completion Date 1l.b Provide the necessary The implementation steps include: D-15 meetings Complete infrastructure and tools implemented.

required to execute and Incorporating ACEMAN into daily Plan reinforce the Picture of Of the Next Day (POND) meetings, and Excellence. ACEMAN grading Complete Implementation of a daily meeting (D-

15) between supervisors and individual employed at contributors. The purpose of the D-15 POND meetings.

meetings is to improve communication between employees, supervisors and 0 Picture of Complete managers. They are designed to Excellence and enhance the information flow between ACEMAN employees and all levels of incorporated into management and create an station environment for open communication. Performance Management Alignment of Performance Management Plans.

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.

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Attachment 1 Serial No.05-762 Docket No. 50-305 Item 11 Methods to Verify Commitment (Contd) 0bjective Summary of Commitment Steps Commitment Met Comdetion Date 1 1.c Build depth in Emergency Assess staffing needs and qualification in 0 Assessment 2Q06 Response Organization. Emergency Preparedness positions. report.

Train additional personnel. Training 3Q06 attendance records.

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Attachment 1 Serial No.05-762 Docket No. 50-305

Title:

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

1. Operations 1. Assistant Operations Managers, Individual

2. Operations Training 2. Shift Managers, Performance Management

3. Engineering 3. Control Room Supervisors, Plans updated with improvement

4. Operations Instructors, areas.

5. Engineering Managers, and

6. 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.

Page 24 of 26

Attachment 1 Serial No.05-762 Docket No. 50-305 Item 12 Methods to Verify Commitment Objective Summary of Commitment Steps (Cont'd) Commitment Met Completion Date 12.b Improve the leadership A leadership assessment will be conducted Documented capability of supervisors in: for: results of the assessments.

1. Maintenance 1. Maintenance Supervision 2Q06 Individual

2. Chemistry 2. Chemistry Supervision Performance 3Q06 Management

3. Outage and Planning 3. Outage and Planning Supervision Plans updated with improvement

4. Emergency Planning 4. Emergency Planning Supervision areas. 2Q06

5. Radiation Protection 5. Radiation Protection Supervision 3Q06 12.c Improve line manager Implement DNAP 01 14, Dominion Nuclear 0 DNAPapproved 4Q05 ownership and Self-Evaluation Program. and issued.

accountability.

Station Self 4Q05 Evaluation Meeting (SSEM) held.

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Attachment 1 Serial No.05-762 Docket No. 50-305

Title:

Nuclear Oversight Effectiveness Item 13 Objective Summary of Commitment Steps Methods to Verifv 1 Commitment 13.a Improve Nuclear Oversight Implement mentors from other NMC sites (NOS) effectiveness. for a period of 6 weeks, assign assessors to place.

a functional area, and implement a rotation plan. An improvement plan addressing Assessors assigned Complete assessor performance will be developed to functional areas.

which will include additional actions.

0 Develop assessor Complete improvement plan.

0 Review 3Q06 effectiveness of Nuclear Oversight processes.

13.b Strengthen Nuclear Implement Dominion Nuclear Oversight 0 Establish and fill 1Q06 Oversight assessment model which includes separate Specialist specialist positions.

processes. Assessment and Audit Programs.

Title:

Conservative Decision Making

~

Item 14 I 0bjective Summary of Commitment Steps Methods to Verify Commitment Met Commitment Completion Date 14.a Improve understanding of Site management will conduct training on 0 Training Complete conservative decision conservative decision making for managers attendance making by managers and and supervisors. records.

supervisors.

Page 26 of 26

Attachment 2 Serial No.05-762 Summary of New Commitments and Administrative Clarifications Dominion Energy Kewaunee, Inc.

Kewaunee Power Station

Attachment 2 Serial No.05-762 Docket No. 50-305 Attachment 2 Summary of New Commitments and Administrative Clarifications New commitments have been made in the following areas:

1.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).

1.f New Objective to Improve the understanding of License Requirements at KPS.

14 New Objective to Improve Operations procedures.

1.h New Objective to Improve Non-Licensed Operator Continuing training program.

4.c New Objective to Reduce potential for residual heat removal pump pit flooding during shutdown.

4.d New Objective to Submit flooding licensing basis.

4.e New Objective to Resolve auxiliary feedwater local operator actions.

4.f New Objective to Update PRA Model.

5.d New Objective to Updating of Environmental Qualification (EQ) Program.

7.d New Objective to Improve Station Engineering Support.

7.e New Objective to Improve Equipment Reliability.

8.a New Commitment Step to Implement a communications campaign to reinforce roles and responsibilities.

9.c New Objective to Improve the quality of causal evaluations.

1o.c 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.

1l.c New Objective to Build depth in Emergency Response Organization.

12.b New Objective to Improve the leadership capability of supervisors in Maintenance, Chemistry, Outage and Planning, Emergency Planning, and Radiation Protection.

12.c New Objective to Improve line manager ownership and accountability.

13.b New Objective to Strengthen Nuclear Oversight assessment processes.

Clarifications have been made to the table as listed below:

1.e A completion date of 1Q06 has been identified for the training/briefing attendance records and an effectiveness review.

4 Title changed from Auxiliary Feedwater & Turbine Building Flooding Modifications to Auxiliary Feedwater & Flooding Modifications.

5.b The final completion date has been changed to 4Q07.

5.c A completion date of 2Q06 has been identified for the effectiveness review.

6.a The interim progress review was clarified and commitment completion dates were added.

6.b The interim progress review was clarified and commitment completion dates were added.

7.a Added IRG Implemented as a Method to Verify the Commitment Met.

8.d 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

Attachment 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 (NIEP) 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 Summary of Commitment Steps.

2) The column titled Methods to Verify Objective Met has been changed to Methods to Verify Commitment met.

3) The column Complete Date is now Commitment Completion Date and has been moved to the far right of the table with all completion dates identified there.

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