ML071380452

Reply to a Notice of Violation (EA-07-058)

ML071380452
Person / Time
Site:	Kewaunee
Issue date:	05/03/2007
From:	Hartz L Dominion Energy Kewaunee
To:	Document Control Desk, NRC/RGN-III
References
07-0285, EA-07-058
Download: ML071380452 (8)

Text

Dominion Energy Kewaunee, Inc.  % omM.Dla N490 Highway 42, Kewaunee,W1 54216-9511 MAY 03 2007 U. S. Nuclear Regulatory Commission Serial No. 07-0285 Attention: Document Control Desk KPS/LIC/RS: R7 Washington, DC 20555 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION REPLY TO A NOTICE OF VIOLATION (EA-07-058)

By letter dated April 3, 2007 (reference 1), the Nuclear Regulatory Commission (NRC) provided the final significance determination and a notice of violation associated with a finding at Kewaunee Power Station. The finding involved a failure of plant personnel to follow procedural requirements and document a fuel oil leak on emergency diesel generator A in the corrective action program when the leak was first identified on June 28, 2006. This failure resulted in the fuel oil leak not being appropriately evaluated and repaired until August 18, 2006.

The notice of violation (EA-07-058) requires a written response be provided to the NRC within 30 days. Attachment 1 provides the required written response.

If you have questions or require additional information, please feel free to contact Mr.

Tom Breene at 920-388-8599.

Very truly yours, Leslie N. Hartz Site Vice President, Kewaunee Power Station

Reference:

1. Letter from James L. Caldwell (NRC) to D. A. Christian (DEK), "Final Significance Determination for a Yellow Finding and Notice of Violation (NRC Inspection Report 05000305/2007009) Kewaunee Power Station," dated April 3, 2007.

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Page 2 of 2

Attachment:

1. Reply to Notice of Violation (EA-07-058), NRC Inspection Report 05000305/2007-009.

Commitments made by this letter:

1. Dominion Energy Kewaunee, Inc. will continue to verify corrective action program action requests are generated for appropriate work requests until Kewaunee Power Station adopts the Central Reporting System and Maximo.

cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Ms. M. H. Chernoff Project Manager U.S. Nuclear Regulatory Commission Mail Stop 8 G9A Washington, D. C. 20555 NRC Senior Resident Inspector Kewaunee Power Station

Serial No. 07-0285 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (EA-07-058)

NRC INSPECTION REPORT 05000305/2007009 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Attachment 1 Page 1 of 5 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 05000305/2007009 By letter dated April 3, 2007 (reference 1), the NRC issued a notice of violation (NOV) associated with a finding of substantial importance to safety (Yellow) to Dominion Energy Kewaunee, Inc. (DEK). This NOV (EA-07-058) requires a written response to be submitted to NRC within 30 days of the date of the NRC letter that issued the NOV. The required written response is provided below.

Statement of Violation (reference 1):

Technical Specification 6.8, Subsection (a), states that written procedures and administrative policies shall be established, implemented, and maintained that meet the requirements and recommendations of Section 5.2.2 of American National Standards Institute (ANSI) N.18.7-1976. Section 5.2.2 of ANSI N.18.7-1976, states that "[p]rocedures shall be followed, and the requirements for use of procedures shall be prescribed in writing."

Kewaunee general nuclear procedure GNP-08.02.01, "Work Order Processing and Planning/Work Execution and Close-out," Revision AD, Step 2.3, states, "complete an Action Request (AR) form for nonconforming conditions as required by GNP-1 1.08.01."

GNP-11.08.01, "Action Request Process," Revision X, Step 3.1.1 specifies an AR for unexpected plant equipment degradation.

Contrary to the above, on June 28, 2006, the licensee did not complete an AR for a fuel oil leak on the "A" emergency diesel generator.

This violation is associated with a Yellow significance determination process finding.

Response to Violation:

1. The reason for the violation, or if contested, the basis for disputing the violation.

Dominion Energy Kewaunee, Inc. (DEK) does not contest the violation. The subject violation occurred because of human error. Kewaunee Power Station (KPS) staff failed to complete an Action Request (AR) form for a non-conforming condition, as required by KPS procedure GNP-11.08.01, "Action Request Process," Revision X, Step 3.1.1.

Not submitting the AR diminished the ability for an appropriate review of the impact of the deficiency on EDG operability and resulted in a risk significant component remaining in a non-conforming condition without appropriate remedial action. This

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Attachment 1 Page 2 of 5 human performance failure does not meet management expectations for appropriate plant risk sensitivity or procedural compliance.

Specifically, on June 28, 2006, two fuel oil leaks were observed on KPS emergency diesel generator (EDG) A. At the time, EDG A was in a standby condition. Two work requests (WRs) were initiated for the leaks identified on June 28. However, no ARs were initiated for these leaks as required by GNP-1 1.08.01. An interview determined the individual who observed the leaks understood the requirement to submit an AR, but he was distracted by other work and failed to submit an AR as required by procedure.

Initiation of an AR requires an immediate evaluation of plant impact and equipment operability by control room personnel, followed by a review by the AR screening team.

As a result, an immediate evaluation of plant impact and equipment operability was not documented by control room personnel in accordance with the corrective action process, nor was that followed by a review by the AR screening team.

On August 17, 2006, EDG A was started to perform a surveillance test and the fuel oil leak rate increased. As a result, EDG A was shutdown after approximately 10 minutes.

The leak was repaired, and the surveillance test was completed on August 18, 2006.

Analysis of the leaking tubing concluded that an approximately 350 degree circumferential crack existed in the copper tubing of the fuel supply line inside a 3/8 inch compression fitting to a pressure gauge. This event was reported to the NRC in references 3 and 4.

A summary of the causes for this violation is as follows:

1. The person who identified the fuel oil leak on June 28, 2006 did not follow procedure GNP-1 1.08.01, "Action Request Process," Revision X, Step 3.1.1.

2. An AR was not initiated for the fuel oil leak identified on June 28, 2006.

Therefore, an immediate evaluation of plant impact and equipment operability was not documented by control room personnel in accordance with the corrective action process, nor was that followed by a review by the AR screening team.

3. The station also exhibited knowledge deficiencies concerning compression fitting leak failure mechanisms. (Leaks on compression fittings are different than leaks on piping joints since compression fittings have a history of fatigue failures internal to fittings.) Therefore, the relative risk significance of the compression fitting deficiency was not factored into the decision-making process for scheduling repair of the EDG A fuel oil leak.

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Attachment 1 Page 3 of 5

2. The corrective steps that have been taken and the results achieved.

The worker who failed to initiate an AR for the fuel oil leak was coached regarding management expectations for following procedures and paying attention to detail.

Key characteristics of this issue have been communicated to the site. These include procedural requirements for initiating ARs for degraded or non-conforming conditions discovered in the plant, and management expectations for procedural compliance. A variety of settings have been used including:

• Daily fifteen-minute information sharing publications, where group leaders discuss topics of interest with their group.

• Daily operational focus meetings, where station leadership discusses the maintenance activities scheduled for the day.

• Continuing training for non-licensed operators.

• Continuing training for maintenance personnel.

Enhancements have been made to the WR process procedure GNP-8.2.14, "Work Request Initiation, Screening and Processing," to clarify that an AR is required to be initiated when a WR identifies an equipment deficiency or an operability concern in the plant.

As an interim corrective action, an additional barrier to this human performance failure was instituted by requiring Outage and Planning (O&P) department reviews of all new WRs to ensure associated ARs have been initiated. If an AR is not generated, the WR initiator is contacted to initiate an AR. An AR is generated weekly to document cases where WRs were initiated without a corresponding AR by the initiator without prior prompting by O&P review. This additional barrier will remain in place until the AR and WR process transition to the new software for the work request process (Maximo) and for the corrective action process (Central Reporting System - CRS) is complete, as discussed in the response to question 3 below.

3. The corrective steps that will be taken to avoid further violations.

As identified in the NRC Annual Assessment Letter for KPS (reference 5), the site has a substantive cross-cutting issue in the area of human performance. The common cross-cutting aspects that apply to the human performance cross-cutting issue are failure to follow procedures and lack of complete, accurate, and up-to-date procedures.

An evaluation was performed to address these issues.

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Attachment 1 Page 4 of 5 A root cause evaluation has also been initiated as a result of the human performance failure identified in this violation. These evaluations have and will develop actions to address the causes of human performance issues that are leading to procedural non-compliance at the station.

New software for the work request process (Maximo) and for the corrective action process (Central Reporting System - CRS) are scheduled to be implemented. These new processes provide that equipment issues be captured within the corrective action program by having a single entry point through the corrective action program software (CRS). The new software controlled process requires that all equipment issues are entered as an AR, thus requiring a condition review before a WR can be generated.

These new software based processes are designed to preclude the possibility of entering equipment issues as WRs without entering them as ARs.

As an enhancement, lessons learned from this violation regarding procedural adherence, and sensitivity to risk significant systems and components, will be assessed by the Training Review Board for appropriate incorporation into fleet training applications.

The following actions will be taken to correct the knowledge deficiencies concerning compression fitting/tubing leak failure mechanisms:

" The Maintenance Training Review Board will determine lesson plan upgrade requirements and the appropriate Maintenance Department population to receive this training.

• KPS Leadership Training will be evaluated to determine the appropriate content of the training and the appropriate leadership population to receive this training.

" The Operations Training Review Board will determine lesson plan upgrade requirements and the appropriate Operations Department population to receive this training.

4. The date when full compliance will be achieved.

Full compliance for the specific violation was achieved when the interim action and procedural changes to assure appropriate WRs have a corresponding AR were put into place. This provides the necessary assurance that equipment deficiencies are identified and operability determinations are performed in a timely manner. KPS is now performing a review of WRs issued. WRs are matched to ARs issued, and if a discrepancy is observed, the required AR is generated. This interim action will

Serial No. 07-0285 Reply to a NOV (EA-07-058)

Attachment 1 Page 5 of 5 continue to be performed until the station adopts the enhancement of CRS and Maximo, which requires an AR to be generated before a work request can be issued.

The human-performance aspects of this violation are being addressed by the evaluation of the cross-cutting issue in human performance and the root cause evaluation initiated as a result of the human performance failure identified in this violation.

References:

1. Letter from James L Caldwell (NRC) to D. A. Christian (DEK), "Final Significance Determination for a Yellow Finding and Notice of Violation (NRC Inspection Report 05000305/2007009) Kewaunee Power Station," dated April 3, 2007.

2. Kewaunee Power Station Root Cause Evaluation K-2006-0736, "Organizational and Programmatic Issues Leading to EDG 1A Fuel Oil Fitting Leak," Revision 6.

3. LER 2006-009-00, "Fuel Oil Leak on Swedgelock Fitting Renders Emergency Diesel Generator A Inoperable," dated October 16, 2006.

4. LER 2006-009-01, "Fuel Oil Leak on Swedgelock Fitting Renders Emergency Diesel Generator A Inoperable," dated April 16, 2007.

5. Letter from M. A. Satorius (NRC) to D. A. Christian (DEK), "Annual Assessment Letter

- Kewaunee Power Station (Report 05000305/2007001)," dated March 2, 2007.