IR 05000305/2005005: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
 
(Created page by program invented by StriderTol)
Line 3: Line 3:
| issue date = 01/20/2006
| issue date = 01/20/2006
| title = IR-05000305-05-005; Dominion Energy Kewaunee, Inc.; on 11/28/2005 - 12/16/2005; Kewaunee Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems
| title = IR-05000305-05-005; Dominion Energy Kewaunee, Inc.; on 11/28/2005 - 12/16/2005; Kewaunee Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems
| author name = Louden P L
| author name = Louden P
| author affiliation = NRC/RGN-III/DRP/RPB5
| author affiliation = NRC/RGN-III/DRP/RPB5
| addressee name = Christian D A
| addressee name = Christian D
| addressee affiliation = Dominion Energy Kewaunee, Inc
| addressee affiliation = Dominion Energy Kewaunee, Inc
| docket = 05000305
| docket = 05000305
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:January 20, 2006 Mr. David Senior Vice President and
[[Issue date::January 20, 2006]]
 
Mr. David Senior Vice President and


Chief Nuclear Officer
Chief Nuclear Officer
Line 29: Line 26:
5000 Dominion Boulevard
5000 Dominion Boulevard


Glen Allen, VA 23060-6711
Glen Allen, VA 23060-6711SUBJECT:KEWAUNEE POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000305/2005005
 
SUBJECT: KEWAUNEE POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000305/2005005


==Dear Mr. Christian:==
==Dear Mr. Christian:==
Line 64: Line 59:
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the


Resident Inspector Office at the Kewaunee Power Station facility.D. Christian-2-
Resident Inspector Office at the Kewaunee Power Station facility.D. Christian-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and any response you provide will be av ailable electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and any response you provide will be av ailable electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS).
component of NRC's document system (ADAMS).


ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/Patrick L. Louden, Chief Projects Branch 5
Sincerely,
/RA/Patrick L. Louden, Chief Projects Branch 5


Division of Reactor Projects Docket No. 50-305 License No. DPR-43
Division of Reactor Projects Docket No. 50-305 License No. DPR-43


===Enclosure:===
===Enclosure:===
Inspection Report 05000305/2005005  
Inspection Report 05000305/2005005 w/Attachment: Supplemental Information
 
===w/Attachment:===
Supplemental Informationcc w/encl:M. Gaffney, Site Vice President C. Funderburk, Director, Nuclear Licensing
 
and Operations Support
 
T. Breene, Manager, Nuclear Licensing
 
L. Cuoco, Esq., Senior Counsel


D. Zellner, Chairman, Town of Carlton
REGION IIIDocket No:50-305 License No:DPR-43 Report No:05000305/2005005 Licensee:Dominion Energy Kewaunee, Inc.
 
J. Kitsembel, Public Service Commission of WisconsinDOCUMENT NAME:C:\MyFiles\Roger\ML060200325.wpd G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIIINAMEMKunowski:slsPLoudenDATE1/20/20061/20/2006 OFFICIAL RECORD COPYD. Christian-3-
ADAMS Distribution
: HKN JFS2 RidsNrrDirsIrib
 
GEG KGO SXB3 CAA1 C. Pederson, DRS (hard copy - IR's only)
 
DRPIII DRSIII PLB1 JRK1 ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IIIDocket No:50-305 License No:DPR-43 Report No:05000305/2005005 Licensee:Dominion Energy Kewaunee, Inc.


Facility:Kewaunee Power Station Location:N490 Highway 42 Kewaunee, WI 54216Dates:November 28 through December 16, 2005 Inspectors:M. Kunowski, Project Engineer (Team Leader)
Facility:Kewaunee Power Station Location:N490 Highway 42 Kewaunee, WI 54216Dates:November 28 through December 16, 2005 Inspectors:M. Kunowski, Project Engineer (Team Leader)
Line 836: Line 813:


===Closed===
===Closed===
: [[Closes finding::05000305/FIN-2005005-01]]FINNo Trending of Adverse Conditions Identified During
05000305/2005005-01FINNo Trending of Adverse Conditions Identified During
: Outages (Section 4OA2a.(2)(i))
Outages (Section 4OA2a.(2)(i))05000305/2005005-02NCVFailure to Correct Procedure Non-Adherence (Section 4OA2c.(2)(i))05000305/2005005-03NCVFailure to Adequately Correct Residual Heat Removal
: [[Closes finding::05000305/FIN-2005005-02]]NCVFailure to Correct Procedure Non-Adherence (Section 4OA2c.(2)(i))
Pump Seal Leakage (Section 4OA2c.(2)(ii))
: [[Closes finding::05000305/FIN-2005005-03]]NCVFailure to Adequately Correct Residual Heat Removal
: Pump Seal Leakage (Section 4OA2c.(2)(ii))


===Discussed===
===Discussed===
Line 850: Line 825:


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of licensee documents reviewed during the inspection, including documents prepared by others for the licensee.
: Inclusion of a document on this list does not
imply that NRC inspectors reviewed the entire document, but, rather that selected sections or
portions of the documents were evaluated as part of the overall inspection effort.
: In addition, inclusion of a document on this list does not imply NRC acceptance of the document, unless
specifically stated in the body of the inspection report.
: NMC Internal Correspondence:
: Charles Tomes to Dave Masarik; Subject:
: Hudson CAP
: Regarding Heavy Loads; dated May 19, 2005
: GNP 11.08.01; Action Request Process; dated August 30, 2005
: GNP 11.08.02; Action Request Process Trending; dated March 27, 2003
: RF-02.06; Refueling Procedure:
: Reactor Vessel Head Lift; Revision F
: RF-04.03; Refueling Procedure:
: Reactor Pressure Vessel Head Installation; Revision G
: SP-34-0 99 B Train B RHR Pump and Valve Test - IST
: SP-34-091 RHR Hydrostatic Test
: Work Order/Procedure # 03-012432 - Overhaul R H R Pump "B"
: Byron Jackson Installation and Operations Instructions, Residual Heat Removal Pump
===Procedure===
: A-MDS-30; Miscellaneous Drains and Sumps (MDS) Abnormal Operation; dated
: November 22, 2005
: NUREG-0737, Section
: III.D.1.1, "Integrity Of Systems Outside Containment Likely To Contain
: Radioactive Material For Pressurized Water Reactors and Boiling Water Reactors"
: Operability Recommendation Form
: OPR-133, "RHR System 34 and Its Impact on the Control
: Room Exclusion Zone (CREZ);" Revisions 0 and 1
: Memo from G. Reiter to R. Nicolai, responding to NRC inspector questions and identifying the
: Kewaunee containment as "Operable but Degraded," dated December 15, 2005
: Kewaunee System Integrity Program and Cont ainment Leak Rate Testing Program; dated January 27, 2003
: September 2005 KNPP [Kewaunee Nuclear Power Plant] Corrective Action Program
: Performance; dated October 20, 2005
: October 2005 KNPP Corrective Action Program Performance; dated November 15, 2005
: 2004 4 th Quarter and 2005 1
st Quarter Corrective Action Program Trend Report; dated October 18, 2005
: SA4784; Corrective Action Program Focused Self-Assessment Report; dated
: September 13-17, 2004
: Focused Self-Assessment Report (CAP029424); Problem Identification and Resolution -
: Corrective Action Implementation (September 26 - October 7, 2005)
: ACE002567; CAPS Not Being Written as Required; dated February 4, 2004
: ACE002632; Misposition CAPs Hit Management Threshold for Action; dated April 6, 2004
: ACE 003015; DG A Output Breaker Failed to Close; dated June 22, 2005
: ACE003010; Dose to Survey the High Integrity Container (HIC) >55 percent of the Estimate;
dated June 14, 2005
: CA016500; RHR Pump Seal Leakage Evaluation; dated July 6, 2004
: CA017909; Additional Evaluation of RHR Seal Leakage Issues Is Needed; dated
: January 5, 2005
: CA018094; Corrective Action Program Procedure and Guidance Document Use; dated
: January 31, 2005
: CA019697; Point Beach CAP063536 - Unable to Meet
: NUREG-0612 Phase II Requirements for
: Head Drop Analysis; dated May 23, 2005
: CAP021589; RHR Pump B Seal Leakage; dated June 16, 2004
: CAP021601; NRC Resident Question on SIP Impact With RHR Pump Seal Leakage; dated
: June 17, 2004
: CAP021744; Rigor of RHR Pump Seal Leakage Evaluation; dated July 2, 2004
: CAP024751; Additional evaluation of RHR seal leakage issues is needed; dated
: December 30, 2004
: CAP025177; Limited Knowledge of HU Barriers Seen in Causal Evaluations; dated
: January 26, 2005
: CAP025194; Corrective Action Program Procedure and Guidance Document Use; dated
: January 27, 2005
: CAP025199; Connection Between CAP and Work Management; dated January 27, 2005
: CAP025233; CAP/Non-CAP Cross Pollination; dated January 28, 2005
: CAP027482; Point Beach CAP063536 - Unable to Meet
: NUREG-0612 Phase II Requirements
for Head Drop Analysis; dated May 20, 2005
: CAP029513; "Surveillance" Hot Button Trigger Value Exceeded; dated October 6, 2005
: CAP029587; The CAP Trending Program Expectations Not Met; dated October 21, 2005
: CAP029618; CARB Fails to Document the Reasons for Rejecting RCE/ACE Evaluations; dated
: October 13, 2005
: CAP029620; PI&R SA, AFA [Problem Identification and Resolution Self-Assessment, Areas for
: Attention] - Shortfalls in Corrective Action Program Standards; dated October 31, 2005
: CAP029728; Overall RCE and ACE Quality Is Inconsistent; dated October 21, 2005
: CAP029730; Areas for Improvement:
: Monitor Age of Maintenance Rule (a)(1) Corrective Actions; dated October 21, 2005
: CAP029732; Certain Operability Determinations Did Not Contain Sufficient Information; dated
: October 21, 2005
: CAP029733; Programs Required to Identify and Co rrect Deficiencies Need Improvement; dated October 21, 2005
: CAP029734; RCE Cause Determinations Need to be Improved; dated October 21, 2005
: CAP029800; All Site Departments Need to Evaluate Administrative Procedure Adherence;
dated October 27, 2005
: CAP029885; RHR Pump B Seal Leakage; dated November 2, 2005
: CAP029888; Seal leak on B RHR Pump; dated November 2, 2005
: CAP030328; RHR Pump Seal Leakage Information Inadequate; dated November 30, 2005
: CAP030351; Procedures Communicate Procedure Changes to Ops & Training in Timely
: Manner; dated November 30, 2005
: CAP030487; IPEOPs [Emergency Operating Procedures] May Not Adequately Address the
: Occurrence of Sump Recirculation Leakage; December 12, 2005
: CAP030527; Further Actions on RHR Pump Seal Leakage, dated December 14, 2005
: CAP030536; NRC Question Related to Implem entation of Approved Amendment 136 (SIP
: Program); dated December 14, 2005
: CAP030538;
: CA-18094 Closed With No Actions Taken - CAQ Not Addressed; dated
: December 14, 2005
: CAP030543; CAP Screening Process Did Not Question Delay in
: CAP 30351; dated
: December 14, 2005
: CAP030553; Questions from RCE000689; dated December 15, 2005
: CAP030559; Implement Method of Rapid Trending for CAP Issues During Outages; dated
: December 15, 2005
: CAP030560; Establish One Problem - One CAP CAP Process; dated December 15, 2005
: CE014427; RHR Pump B Seal Leakage; dated June 18, 2004
: CE014437; NRC Resident Question on SIP Impact With RHR Pump Seal Leakage; dated
: June 22, 2004
: CE015294; Limited Knowledge of HU Barriers Seen in Causal Evaluations; dated
: January 31, 2005
: CE015301; Connection Between CAP and Work Management - Assessment; dated January 31,
: 2005
: CE016492; The CAP Trending Program Expectations Not Met; dated October 17, 2005
: CE016499; CARB Fails to Document the Reasons for Rejecting RCE/ACE Evaluations; dated
: October 17, 2005
: CE016500; PI&R SA, AFA - Shortfalls in Corrective Action Program Standards; dated
: October 17, 2005
: CE016523; Certain Operability Determinations Did Not Contain Sufficient Information; dated
: October 25, 2005
: CE016524; RCE Cause Determinations Need to be Improved; dated October 25, 2005
: CE016525; Programs Required to Identify and Correct Deficiencies Need Improvement; dated
: October 25, 2005
: EFR018881; Effectiveness Review:
: Provide Trend Information Related to Prior CAPs at the
: Daily Screening Meeting; dated March 25, 2005
: EWR017113; Engineering Work Request, Clarify Licensing Basis for RHR Pump Seal Leakage;
dated October 5, 2004
: CE015316; CAP/Non-CAP Cross Pollination; dated February 1, 2005
: OBD000085; RHR Pump B Seal Leakage; dated June 18, 2004
: OE002555; CROSFLOW Ultrasonic Flow Measurem ent System Performance Observations;
dated February 26, 2004
: OE002902; RCP Motor Recommended 1-Year, 5-Year and 10-Year Maintenance; dated
: March 22, 2004
: OE005168; Updated Reactivity Surveillance Policy for B10 Isotopic Concentration; dated
: August 26, 2004
: OE006343; Steam Generator Channel Head Bowl Drain Line Leakage; dated
: November 29, 2004
: OE010132; External Operating Experience:
: Point Beach CAP063450 - Reactor Vessel Head
: Lift Load Drop Analysis; dated August 1, 2005
: OTH005767; Review Evaluation of
: CE 14427 With Performer; dated October 5, 2004
: OTH016702; NRC Resident Question on SIP Impact with RHR Pump Seal Leakage; dated
: August 12, 2004
: OTH017112; Engineering to Monitor RHR Pump B Overhaul for Seal Leakage Evaluation; dated
: October 5, 2004
: PCR020623; Procedure Change Request:
: Revise Shutdown Safety Assessment and Related
: Refueling and Operations Procedure; dated August 16, 2005
: PCR021359; Procedure Change Request:
: Revise
: GNP 11.08.02 to Exclude Hot Buttons
: During "Outages" Not Just Refueling Outages; dated November 10, 2005
: RCE 669 (CAP24453);
: SP-55-167-5 Not Performed at the Required Frequency Causing
: Technical Specification 4.0.c Entry; event date December 7, 2004
: RCE 000675 (CAP25213); Personnel Inside Radiography Boundaries While Radiography
: Source Was Exposed; event date January 27, 2005
: RCE 674 (CAP025263);
: TLA-11 Reactor Thermal Power Event High; event date
: January 31, 2005
: RCE 682 (CAP025606); Uncontrolled Increase in Steam Generator Level Due to Service Water
: Flow; event date February 20, 2005
: RCE 689 (CAP 027932); High Radiation Area Not Controlled or Posted During Transfer of Filter;
event date June 11, 2005
: RCE 694; Missed Surveillance on
: SP-02-138B and
: SP-55-177; dated August 19, 2005.
: LER 2004-004-00; Procedural Deficiency Results in Automatic Containment Ventilation Isolation
: Being Disabled Contrary to Technical Specifications; dated January 17, 2005
: LER 2004-003-01; Control Room Boundary Door Found Ajar - Accident Analysis Assumptions
: Impacted - Personnel Error; dated February 22, 2005
: LER 2005-001-00; Reactor Thermal Power Eight Hour Average Limit Exceeded; dated
: April 1, 2005
: LER 2004-005-00; Safety Injection Accumulator Isolation Valve Position During Heat up
: Violates Technical Specifications - Procedural Deficiency; dated January 25, 2005
: LER 2005-002-00; Auxiliary Feedwater Pumps A
ssumed to Fail from Postulated Loss of Primary Water Source - Safe Shutdown and Accident Analysis Assumptions Not Assured -
: Inadequate Design of Pump Protective Equipment; dated April 12, 2005
: LER 2005-004-00; Safe Shutdown Potentially Challenged By Unanalyzed Internal Flooding
: Events and Inadequate Design; dated May 16, 2005
: LER 2005-003-00; Inadvertent to Reactor Protection Trip While Shutdown - Caused by
===Procedure===
: Adherence Deficiencies and Inadequate Shifted Management Oversight; dated
: April 19, 2005
: LER 2005-005-00; Emergency Diesel Generator Exhaust Ductwork Not Adequately Protected


from Potential Tornado Winds and Missiles; dated May 23, 2005
: LER 2005-008-00; Turbine Driven Auxiliary Feedwater Pump Inoperable Due To Insufficient
: Net Positive Suction Head; dated June 20, 2005
: LER 2005-007-00; Unanalyzed Condition:
: Design Deficiency - Component Cooling Water
: System Inoperable Due to Pump "Run Out" Conditions; dated May 27, 2005
: LER 2005-006-00; Auxiliary Feedwater Pumps Postulated to Fail Due to Air Ingestion Through
: Pump Packing; dated May 25, 2005
: LER 2005-014-00; Technical Specification LCO Not Entered for Diesel Generators Inoperable
: While In Refueling Shutdown; dated August 5, 2005
: LER 2005-013-00; The Throttle Valves to the Turbine Bearing Oil Coolers for the Turbine
: Driven AFW Pump Could be Blocked by Debris; dated September 9, 2005
: LER 2005-012-00; Residual Heat Removal Pump Run - Out Upon Loss of Instrument Air While
: Aligned for Sump Recirculation; dated August 10, 2005
: LER 2005-011-00; The Settings of a Permissive (P-10) in the Power Range Channels of the
: Nuclear Instrumentation System was Outside of Plant Technical Specification Requirements;
dated August 18, 2005
: LER 2005-010-00; Inadequate Engineering Analysis to Support Service Water Pump
: Operability; dated August 16, 2005
: LER 2005-009-00; Firearm Discovered During Security Search Process; dated July 15, 2005
==LIST OF ACRONYMS==
USEDACEApparent Cause EvaluationADAMSAgency Wide Access Management System
ARAction Request
CACorrective Action
CAPCorrective Action Program Document
CAQCondition Adverse to Quality
CARBCorrective Action Review Board
CATPRCorrective Action to Prevent Recurrence
CECondition Evaluation
CFRCode of Federal Regulations
DRPDivision of Reactor Projects
DRSDivision of Reactor Safety
: [[DRUMD]] [[epartment Roll-Up Meeting]]
: [[ECCS]] [[Emergency Core Cooling System]]
FINFinding
GLGeneric Letter
GNPGeneral Nuclear Procedure
gphGallons Per Hour
gpmGallons Per Minute
I&CInstrument and Control
IMCInspection Manual Chapter
IPInspection Procedure
IRInspection Report
KPSKewaunee Power Station
LERLicensee Event Report
NCVNon-Cited Violation
: [[NMCN]] [[uclear Management Company,]]
: [[LLC]] [[]]
NOSNuclear Oversight (Quality Assurance)
NRCNuclear Regulatory Commission
OEOperating Experience
OPROperability Recommendation (Operability Determination)
OTHOther (Corrective Action Program Document)
RCERoot Cause Evaluation
RCSReactor Coolant System
RHRResidual Heat Removal
RISRegulatory Issue Summary
SDPSignificance Determination Process
SIPSystem Integrity Program
TSTechnical Specification
: [[USARU]] [[pdated Safety Analysis Report]]
}}
}}

Revision as of 00:30, 14 July 2019

IR-05000305-05-005; Dominion Energy Kewaunee, Inc.; on 11/28/2005 - 12/16/2005; Kewaunee Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems
ML060200325
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/20/2006
From: Louden P
NRC/RGN-III/DRP/RPB5
To: Christian D
Dominion Energy Kewaunee
References
IR-05-005
Download: ML060200325 (25)


Text

January 20, 2006 Mr. David Senior Vice President and

Chief Nuclear Officer

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 23060-6711SUBJECT:KEWAUNEE POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000305/2005005

Dear Mr. Christian:

On December 16, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline team inspection at your Kewaunee Power Station. The enclosed report documents the

inspection findings, which were discussed on December 16 with Mr. Michael Gaffney and other

members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commission's rules and

regulations and the conditions of your operating license. Within these areas, the inspection

involved examination of selected procedures and representative records, observations of

activities, and interviews with personnel.

Based on the samples selected for review, the inspectors identified three findings of very low safety significance (Green), two of which were determined to be violations of NRC

requirements. However, because the violations were of very low safety significance and

because the issues were entered into your corrective action program, the NRC is treating these

violations as Non-Cited Violations (NCVs), cons istent with Section VI.A of the NRC Enforcement Policy. If you contest the subject or severity of an NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC

20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -

Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the

Resident Inspector Office at the Kewaunee Power Station facility.D. Christian-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and any response you provide will be av ailable electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/Patrick L. Louden, Chief Projects Branch 5

Division of Reactor Projects Docket No. 50-305 License No. DPR-43

Enclosure:

Inspection Report 05000305/2005005 w/Attachment: Supplemental Information

REGION IIIDocket No:50-305 License No:DPR-43 Report No:05000305/2005005 Licensee:Dominion Energy Kewaunee, Inc.

Facility:Kewaunee Power Station Location:N490 Highway 42 Kewaunee, WI 54216Dates:November 28 through December 16, 2005 Inspectors:M. Kunowski, Project Engineer (Team Leader)

P. Higgins, Resident Inspector, Kewaunee

J. Jandovitz, Reactor Engineer

J. Neurauter, Reactor EngineerApproved by:P. Louden, Chief Projects Branch 5

Division of Reactor Projects Enclosure 1

SUMMARY OF FINDINGS

IR 05000305/2005005; Dominion Energy Kewaunee, Inc.; on 11/28/2005 - 12/16/2005;

Kewaunee Power Station; biennial baseline inspection of the identification and resolution of problems. Two violations were identified in the area of corrective actions.

The inspection was conducted by a regional projects inspector, a resident inspector, and two regional engineering inspectors. Three findings of very low safety significance (Green) were identified during this inspection, two of which were classified as Non-Cited Violations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

Identification and Resolution of Problems The inspectors concluded that the licensee's implementation of its program for identifying, evaluating, and correcting nuclear safety problems was adequate. While the licensee was identifying plant problems at an appropriately low level, the inspectors had observations and one finding that indicated additional attention by plant management was warranted, particularly with the trending of conditions adverse to quality during outages to identify potentially more significant conditions or to effectively correct low-level repetitive conditions. One finding of very low safety significance was identified in this area.

In the area of prioritization and evaluation of issues, program implementation was effective, particularly with the licensee's evaluation of and corrective actions for recurrent problems with certain bistables and for operating experience related to replacement reactor head activities.

In the area of effectiveness of corrective actions, the inspectors identified two findings of very low safety significance, with associated Non-Cited Violations, for the licensee's failure to correct a procedure non-adherence issue identified during its 2004 self-assessment of the corrective action program and to correct leakage from a residual heat removal pump that could significantly increase control room and offsite doses during certain accidents. Leakage from the residual heat removal pumps has been an issue at Kewaunee since 1979.

From interviews conducted during this inspection and a review of corrective action program and employee concerns program documents, the in spectors concluded that workers at Kewaunee felt free to input nuclear safety findings into the corrective action program or the employee concerns program. A.Inspector-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance for the licensee not reviewing corrective action program documents (CAPs) during outages for potential trends of conditions adverse to quality. As part of the screening process of CAPs, the licensee assigned, as possible, CAPs to various "hot buttons." Hot buttons were searchable categories in the corrective ac tion program computer system that had been established for various problems, such as equipment tagging errors, security door control, and reactivity management. For non-outage times, the licensee assigned a monthly number of hits for each hot button that, if exceeded for 3 months in succession, would result in the generation of a CAP to investigate a possible trend. However, as of

December 16, 2005, the licensee did not use hot button action levels during outages when the number of CAPs written was much higher than during non-outage times.

This finding is greater than minor because if left uncorrected would become a more significant safety concern. This finding is not suitable for Significance Determination

Process evaluation, but has been reviewed by NRC management and is determined to be a finding of very low safety significance. The cause of the finding is related to the cross-cutting element of problem identification and resolution, because of not identifying potential conditions adverse to quality through trending of CAPs during outages.

(Section 4OA2a.(2)(i))*Green. The inspectors identified a finding of very low safety significance and a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to take corrective action for procedure non-compliance identified during the licensee's 2004 self-assessment of the corrective action program. As a result of the assessment, CAP025194, "Corrective Action Program Procedure and Guidance

Document Use," was written and documented that plant workers were not following corrective action program procedures for apparent cause evaluations and root cause evaluations, effectiveness review content, priority and due date assignments, initiator feedback, and documentation of corrective action completion. To correct this problem, corrective action CA018094, "Corrective Action Program Procedure and Guidance

Document Use," was written and specified one or 2 weeks of requiring "in-hand" use by the plant staff of the corrective action program administrative procedure. However, completion of this action was delayed several times and on July 25, 2005, CAP025194 and CA018094 were closed with the only documented action taken being a

July 18, 2005, meeting of the station human performance steering committee at which the licensee decided not to take action because of the pending transition to the corrective action program documents of the plant's new owner.

This finding is greater than minor because if left uncorrected would become a more significant safety concern. This finding is not suitable for Significance Determination

Process evaluation, but has been reviewed by NRC management and is determined to be a finding of very low safety significance. The cause of the finding is related to the cross-cutting element of problem identification and resolution, because of the failure to take corrective action for non-adherence to station procedures. (Section 4OA2c.(2)(i))*Green. A finding of very low safety significance that was a Non-Cited Violation of10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified for the licensee's ineffective corrective action to repair a leak on the seal of the "B" residual heat removal (RHR) pump. The leak was identified on November 2, 2005, when the pump was stopped following the performance of a required surveillance. The leak rate exceeded leakage control program limits. A similar leak was identified on

June 16, 2004, for which the licensee replaced the seal in November 2004.

3 This finding is greater than minor because it was associated with the "RCS (reactor coolant system) equipment and barrier performance" attribute of the barrier integrity cornerstone and does affect the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Although the RCS barrier was affected, the finding did not affect the mitigation capability of the RHR system and did not contribute to the likelihood of a primary or secondary system loss of coolant accident initiator or affect the containment integrity.

Therefore, the finding is of very low safety significance. (Section 4OA2c.(2)(ii))

B.Licensee-Identified Violations

None.

4

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2Problem Identification and Resolution a.Effectiveness of Problem Identification (1)Inspection Scope The inspectors reviewed items selected from the cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective

action program for evaluation and resolution. At Kewaunee, problems entered into the

program are documented as CAPs (i.e., condition reports). Included in this review were

numerous CAPs, the reports of the 2004 and 2005 Kewaunee self-assessments, Nuclear Oversight (quality assurance) reports, Licensee Event Reports (LERs), other

plant documents, and previous NRC inspection reports. The inspectors also conducted

plant tours and interviewed plant personnel to identify equipment or process problems

that had not been entered into the corrective action program. The previous NRC

problem identification and resolution team inspection was conducted at the end of 2003 (Inspection Report (IR) 05000305/2003010).

(2)Assessment The inspectors concluded that the licensee was generally effective in identifying problems and the threshold of the majority of plant personnel was appropriately low.

Both the previous operating company, t he Nuclear Management Company, LLC (NMC)and the current owner and operator (as of July 5, 2005), Dominion, emphasized to plant

personnel a low threshold for documenting problems in CAPs. The number of CAPs

generated in recent years have indicated that this emphasis has been effective:*in 2001, 4903 CAPs (outage year, including steam generator replacement),*in 2002, 3867 CAPs (non-outage year),

  • in 2003, 5208 CAPs (outage year),
  • in 2004, 5367 CAPs (outage year), and
  • in 2005, 5773 CAPs (outage year).

The inspectors, however, had several observations, including one finding, that indicated additional effort was warranted in the area of identification of problems. These

observations are discussed below.(i)Trending During Outages Introduction

The inspectors identified a finding of very low safety significance (Green) for the licensee not reviewing CAPs during outages for potential trends

of conditions adverse to quality.

5 Description

As part of the screening process of CAPs, the licensee assigns, as possible, CAPs to various "hot buttons." Hot buttons are searchable categories

in the corrective action program comput er system that have been established for various problems, such as equipment tagging errors, security door control, and

reactivity management. For non-outage times, the licensee assigned a monthly

number of hits for each hot button that, if exceeded for 3 months in succession, would result in the generation of a CAP to investigate a possible trend. However, the licensee does not use hot button action levels during outages. The

explanation was that outages were known to result in more CAPs being

generated and that developing appropriate action levels for the known increase

in CAPs in the various hot button categories would be problematic. The

inspectors concluded that timely hot button categorization and analysis during

outages could help prevent a significant program, process, or work group

problem that was currently showing up as lower level issues or could reduce or

eliminate repeat lower level issues.

Analysis:

The inspectors determined that the licensee's failure to review CAPs during outages to identify and address potential trends in conditions adverse to

quality was a licensee performance deficiency warranting a significance

evaluation. The inspectors concluded that the finding was more than minor in

accordance with Inspection Manual Chapter (IMC) 0612, "Power Reactor

Inspection Reports," Appendix B, "Issue Screening," issued September 30, 2005, in that, the finding if left uncorrected would become a more significant safety

concern. This finding (FIN 05000305/2005005-01) is not suitable for Significance

Determination Process (SDP) evaluation, but has been reviewed by NRC

management and is determined to be of very low safety significance (Green).

The inspectors also determined that the finding affected the cross-cutting element of problem identification and resolution, because of not identifying

potential conditions adverse to quality through trending of CAPs during outages.

Enforcement

No violation of NRC requirements was identified for this finding.

The licensee entered the issue into the corrective action program as

CAP030559.(ii)Additional Observations on Trending and Identification of Problems*The licensee's 2004 self-assessment of the corrective action program identified that the trend analysis program was adding little value; however, this was not

documented in a CAP. The explanation gi ven in the assessment report implied that one was not needed because the recently developed monthly department

"roll-up" process (DRUM process) would likely address the problems after

several months of run time. Among other items, the DRUM process had the

various departments assess department-related CAPs from the past month to

identify any trends. The inspectors concluded that a CAP should have been

written to ensure that the DRUM process was reviewed after several months to

assess if the original issue from the 2004 assessment was addressed. With the

imminent change from NMC to Dominion and a forced outage from February 20

to July 2, 2005, the DRUM process was not implemented. A similar Dominion 6 process has since been implemented.*Trend program concerns were again identified as part of the 2005 self-assessment of the corrective action program. The concerns, identified by an

NOS evaluator (Nuclear Oversight-quality assurance) were documented in

CAP029587, "The CAP Trending Program Expectations Not Met." Issues

documented included not using hot button trends during non-refueling outages;

the last published quarterly corrective action program trend report was for the

third quarter of 2004, as of the third quarter of 2005; and a backlog of 343 existed

for a final corrective action program quality check of completed apparent cause

evaluations and conditions evaluations. *At a CAP screening meeting attended by the inspectors, the screening team did not question why CAP030351 had just been written, on November 30, 2005, for

an issue regarding the use of current procedures in training that was first

identified on March 29. The licensee wrote CAP030543 to follow-up on the

inspectors' observation. *The resident inspectors, in their daily review of newly written CAPs, have identified instances where more than one potential issue was documented in a

CAP. The licensee's policy is "one issue, one CAP." The licensee entered this

apparent discrepancy into its corrective action program as CAP030560 for

evaluation.

b.Prioritization and Evaluation of Issues (1)Inspection Scope The inspectors reviewed the licensee's significance classification and evaluation of a sample of CAPs, apparent cause evaluations (ACEs), and root cause evaluations (RCEs). The inspectors' assessment included a review of the following attributes:

significance category assigned to a CAP, the adequacy of operability and reportability

determinations, the extent of condition evaluations, and the appropriateness of using

whatever causal investigation was used. The licensee's prioritization and evaluation of

selected operating experience issues regarding reactor vessel head lifting, in

Westinghouse technical bulletins, and with Foxboro instruments were also assessed by

the inspectors.

The inspectors also attended several CAP daily screening meetings and a corrective action review board meeting where ACEs and RCEs were reviewed by licensee

management. At these meetings, the inspectors assessed the licensee's evaluation of

issues in CAPs, ACEs, and RCEs. (2)Assessment(i)ACEs and RCEs

For the ACEs and RCEs reviewed, no significant problems were identified by the inspectors. The causes identified by the licensee

appeared appropriate and the identified corrective actions, if fully implemented, should correct the problems that caused the original issue.

7(ii)Operating Experience

For CAPS associated with external operating experience contained in Westinghouse technical bulletins, the inspectors did not identify any

significant problems but did have some observations regarding thoroughness of

the documentation of evaluation results. The licensee indicated that these

observations would be evaluated and appropriate corrective actions would be

taken, as necessary. *For Operating Experience OE002555, "CROSSFLOW Ultrasonic Flow Measurement System Performance Ob servations," three action items had been assigned to change three procedures. One procedure change had

been completed, one procedure deleted with no explanation in the file as

to whether another procedure had taken its place; and one change had

not yet been made. In addition, the OE evaluation mentioned the need

for additional training but no action item was assigned to provide the

training.*For OE002902, "RCP Motor Recommended 1-Year, 5-Year and 10-Year Maintenance," no basis was given for recommendations that would not be

followed. *For OE005168, "Updated Reactivity Surveillance Policy for B-10 Isotopic Concentration," the licensee stated that the recommended actions would

be taken, but the frequency of the surveillance was different from that

contained in the Bulletin and no basis for the difference was provided.(iii)Foxboro Instruments:

The inspectors reviewed the licensee's evaluation of and subsequent corrective actions for failures of certain Foxboro bistables. The

licensee's efforts were in followup to observations made by the resident

inspectors (IR 05000305/2005008). The resident inspectors had determined that

the licensee did not always address potential operability considerations when

bistables associated with safety-related Technical Specification systems were

found out-of-tolerance in the non-conservative direction. Also, the resident

inspectors identified that because the licensee considered Foxboro instruments

in their own Maintenance Rule system, out-of-tolerance bistables were handled

through the Maintenance Rule process and components that had out-of-

tolerance bistables were not individually evaluated. Lastly, the inspectors had

determined that when an out-of-tolerance condition was identified, a thorough

extent of condition was not always performed.

During the current inspection, the inspectors reviewed the history of the Foxboro bistable failures contained in the corrective action program, reviewed the results

and the trending data of the surveillance procedure of the safety-related Foxboro

instruments for approximately the last 1 1/2 years, and discussed these results

with station personnel. The inspectors determined through discussions with the

Maintenance Rule engineer that Foxboro instrument failures were now evaluated

against the plant system affected by the Foxboro instrument as well as the

simulated Foxboro system. Unavailab ility, if any, caused by the Foxboro instrument failure was being logged against the plant system. The results of the

monthly surveillance procedures for the last 12-18 months for the safety-related 8 bistables were reviewed with the instrument and control (I&C) engineer. In most cases, the failure of the bistable could be predicted with the trending data. The

Foxboro instrument would be recalibrated or replaced prior to the predicted

failure. In some cases, the data were not predictable due to large variances, but

still within acceptance criteria. The I&C engineer was now engaged with all the

Foxboro surveillances conducted and the results and operability determinations

resulting from failures of safety-related instruments. In addition, the I&C engineer

provided information on the replacement program for the Foxboro instruments which should be completed in 2006. The inspectors determined from this

information that the corrective actions taken since the previous inspection

adequately addressed the previous concerns of the resident inspectors.(iv)Reactor Head Drop Analysis

During the fall 2004 refueling outage, Kewaunee installed a new reactor vessel head that weighed less than the original reactor

vessel head. The effect of replacement reactor vessel head weight on the

original head drop analysis was evaluated by the licensee in its 10 CFR 50.59

analysis. The inspectors considered the original head drop analysis to be

bounding and conservative for the lower weight, replacement reactor vessel

head. Therefore, a review of the original head drop analysis was not performed

by the inspectors.

In later inspections at other licensees where replacement heads weighed more than the original heads, non-conservative assumptions and methodologies and

incomplete resolution of load drop analysis results were identified for head drop

analyses, as described in NRC Regulatory Issue Summary (RIS) 2005-25, "Clarification of NRC Guidelines for Control of Heavy Loads," dated

October 31, 2005. In addition, RIS 2005-25 also clarified NRC regulatory

guidelines for the control of heavy loads to assure the safe handling of heavy

loads in areas where a load drop could impact stored spent fuel, fuel in the

reactor core, or equipment that may be required to achieve safe shutdown or

permit continued decay heat removal.

During the current inspection, the inspectors reviewed the licensee's evaluation and corrective actions pertaining to industry operating experience and

RIS 2005-25 related to its reactor vessel head drop analysis and control of heavy

loads. The evaluation of operating experience had been entered into the

licensee's corrective action program as CAP027482. The licensee's review

identified that its reactor vessel head drop analysis used the same non-

conservative method of analysis as the Prairie Island Nuclear Generating Plant (IR 05000282/2005004; 05000306/2005004 (ML052020420) dated

July 21, 2005). The inspectors verified that the licensee's corrective action, CA019697, included a plan to update the head drop analysis using finite element

methods based on a "conservation of energy" methodology. The updated head

drop analysis will use a heavier weight, consistent with a head assembly upgrade

package. CA019697 indicated that the licensee's goal was to update the head

drop analysis prior to the fall 2006 refueling outage. Licensee senior

management confirmed this in a discussion with the inspectors.

The inspectors interviewed knowledgeable licensee staff to determine the 9 potential safety significance of the non-conservative methodology used in its current head drop analysis. The licensee's staff indicated that the Kewaunee

reactor vessel support design was very similar to that of Prairie Island, and the

results from the revised Prairie Island head drop analysis using finite element

methods gave reasonable assurance that the current lighter weight Kewaunee

head (approximately 140,000 pounds versus 200,000 pounds for Prairie Island)

could be safely lifted above the reactor vessel to an elevation necessary to

remove and replace the head during refueling operations.

The inspectors observed that current licensee procedures pertaining to removal and replacement of the reactor vessel head did not contain a maximum head lift

height restriction. The inspectors noted that licensee procedures may need to be

revised to specify a maximum head lift height restriction to be consistent with

results from the updated head drop analysis.

The inspectors concluded that industry operating experience and NRC issues identified in RIS 2005-25 related to Kewaunee's reactor vessel head drop

analysis and control of heavy loads have been identified by the licensee, entered

into its corrective action program, and corrective actions specified and scheduled

to resolve concerns and issues related to the current head drop analysis prior to

the fall 2006 refueling outage.

c.Effectiveness of Corrective Actions(1)Inspection Scope The inspectors reviewed selected CAPs and associated corrective actions (CAs)to evaluate the effectiveness of the licensee's corrective actions taken for issues.

The inspectors reviewed condition evaluations (CEs), ACEs, and RCEs to

determine if corrective actions, commensurate with the significance of the issues, were identified and implemented in a timely manner, including corrective actions

to address longstanding or repetitive issues.

The inspectors also verified the continued implementation of a sample of completed corrective actions. The sample that was selected for review was

based, in part, on the safety and risk significance of the issues pertaining to the

reactor safety strategic performance area. Included in the review by the

inspectors were corrective actions taken for licensee self-assessment findings, issues in licensee event reports (LERs), and for Non-Cited Violations (NCVs)

discussed in previous NRC inspection reports. (2)Assessment For most of the issues reviewed by the inspectors, appropriate and timely corrective actions were taken; however, as discussed below, two findings of very

low safety significance involving violations of NRC requirements were identified

by the inspectors.(i)Corrective Action Not Taken 10 Introduction

The inspectors identified a finding of very low safety significance (Green) for the failure to take corrective action for an

issue regarding procedure compliance identified during the licensee's

2004 self-assessment of the corrective action program.

Description

In the 2004 self-assessment of the corrective action program, one of the four CAPs written for identified problems was

CAP025194, "Corrective Action Program Procedure and Guidance

Document Use," January 27, 2005. This CAP documented that plant

workers were not following corrective action program procedures and

guidance documents (essentially, NMC procedures and documents)

for ACEs and RCEs, effectiveness review content, priority and due

date assignments, initiator feedback, and documentation of corrective

action completion. To correct this problem, CA018094, "Corrective

Action Program Procedure and Guidance Document Use," was written

and specified 1 or 2 weeks of requiring "in-hand" use by the plant staff

of the corrective action program administrative procedure (General Nuclear Procedure GNP-11.08.01, "Action Request Process") in

February-March 2005. However, completion of this action was

delayed several times and on July 25, 2005, CAP025194 and

CA018094 were closed with the only documented action taken being

a July 18, 2005, meeting of the station human performance steering

committee. At this meeting, it was decided that the "in-hand"

procedure use recommendation would not be implemented because

training would be provided to plant staff on standards and

expectations of procedure use and adherence when the Dominion

fleet corrective action program was implemented at Kewaunee.

During the current inspection, licensee representatives stated that the

Dominion corrective action program procedure was expected to be

implemented in late December 2005 or January 2006.

Although no specific corrective action was taken for this self-assessment problem, the licensee had emphasized corrective action

program procedure adherence to the plant staff in periodic plant

newsletters and daily alignment meetings ("D-15 meetings"). The

inspectors noted that several of the seven issues identified during the

2005 self-assessment of the corrective action program were caused, in part, by plant staff not following correction program procedures and

guidance documents.

Analysis:

The inspectors determined that the licensee's failure to take corrective action to address plant staff failure to follow the corrective

action program administrative procedure was a licensee performance

deficiency warranting a significance evaluation. The inspectors

concluded that the finding was more than minor in accordance with

IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue

Screening," issued September 30, 2005, in that, the finding if left

uncorrected would become a more significant safety concern. This

finding is not suitable for SDP evaluation, but has been reviewed by 11 NRC management and is determined to be a finding of very low safety significance (Green).

The inspectors also determined that the finding affected the cross-cutting element of problem identification and resolution (corrective

action), because of the failure to take corrective action for non-

adherence to station procedures.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures be established to assure that

conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and nonconformances are promptly identified

and corrected. Contrary to this, as of December 16, 2005, the

licensee had not corrected a condition adverse to quality, the failure

by plant staff to follow corrective action program procedures that was

identified during the 2004 self-assessment of the corrective action

program. Because this finding was of very low safety significance (Green) and because it had been entered into the corrective action

program (as CAP030538), it is being treated as an NCV, consistent

with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000305/2005005-02). (ii)Inadequate Corrective Action Taken Introduction

The inspectors identified a finding of very low safety significance (Green) for the failure to take adequate corrective action

for a leaky seal on a residual heat removal (RHR) pump. An NCV had

previously been identified for the leaky seal during a mid-2004 NRC

inspection.

Description

On June 16, 2004, during a routine quarterly surveillance, the licensee identified that the seal of the 'B' RHR

pump was leaking excessively after the pump was stopped. The

licensee estimated the leakage was approximately 1 gallon per minute (gpm) or 60 gallons per hour (gph). This was greater than the 6-gph

emergency core cooling system leakage allowed by the

System Integrity Program (SIP), as referenced by Technical

Specification 6.12, and greater than the 12-gph leakage discussed in

Chapter 14 of the Updated Safety Analysis Report (USAR) for

calculation of control room and offsite doses. The licensee entered a

7-day administrative Limiting Condition for Operation per the SIP and

the licensee declared the pump operable but degraded, on the basis

that the mechanical seal stopped leaking after the pump was

electrically started and stopped in short succession (i.e., "bumped").

The NRC resident inspectors determined that excessive seal leakage

had occurred on numerous occasions in the past and previous actions

had not been effective in correcting this condition adverse to quality.

An NCV (05000305/2004004-01) for failure to correct a condition

adverse to quality was identified and was documented in IR 2004004, 12 dated July 29, 2004. The licensee had documented the problem in its corrective action program as CAP021589 and CAP021744. For its

corrective action, the licensee replaced the seal in November 2004

during a refueling outage.

During the current inspection, the inspectors reviewed the effectiveness of the corrective action for the 2004 leak and identified

that on November 2, 2005, the "B" RHR pump replacement seal

leaked when the pump was stopped during a routine quarterly

surveillance. As in June 2004, operators stopped the leak by

"bumping" the pump. For the subsequent operability evaluation, the

licensee estimated that the leakage was less than 1 gpm-the leakage

had not been measured before the pump was bumped. The shift

manager declared the pump operable, on the basis that the leakage

stopped when the pump was "bumped" and that the radiological

analysis for the June 2004 leak, which assumed a 60-gph leak rate, determined that there was no significant impact on control room or

offsite doses.

In response to questions by the NRC inspectors, the licensee re-estimated the leakage on November 2, 2005, as greater than 6 gph

but less than 60 gph, a rate in excess of that allowed by the SIP. The

inspectors also noted that the initial operability evaluation for the leak

in June 2004 did not address the potential radiological consequences

of the RHR system barrier leaking reactor coolant outside

containment in excess of SIP and USAR limits. For the operability

evaluation for the November 2005 leak, the licensee reviewed the

potential impact of the estimated leakage on control room and offsite

doses and demonstrated that no dose limits were likely exceeded.

From interviews and a review of corrective action program records and work orders, the inspectors determined that leakage from the

RHR pump seals on both trains had occurred numerous times since

1979 following the shutdown of the pumps. Historically, the licensee

stopped the leakage by rotating the pump shaft, either electrically or

manually, until the leak stopped. This method had been incorporated

in Procedure A-MDS-30, "Miscellaneous Drains and Sumps (MDS)

Abnormal Operation," November 22, 2005. Section 4.10, "RHR Pump

Pit Sump," Step 2.a., stated, "IF RHR pump was NOT running, THEN seal leakage may be stopped by rotating shaft by hand or bumping

motor."

Analysis:

The inspectors determined that the licensee's failure to take effective corrective actions to address the RHR pump seal leakage

was a performance deficiency warranting a significance evaluation.

This self-revealed finding was greater than minor because the finding

was associated with the "RCS (reactor coolant system) equipment

and barrier performance" attribute of the barrier integrity cornerstone

and does affect the cornerstone objective of providing reasonable 13 assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide

releases caused by accidents or events.

The inspectors determined that the finding could not be evaluated using the SDP. Although the inspectors, with the assistance of a

Region III Senior Reactor Analyst, determined that the RCS barrier

was affected, the Phase 2 worksheets were not applicable because

this issue did not affect the mitigation capability of the RHR system.

The finding also did not contribute to the likelihood of a primary or

secondary system loss of coolant accident initiator or affect the

containment integrity. Therefore, this finding was reviewed by a

Region III Branch Chief in accordance with IMC 0612, Section 05.04c, who agreed with the inspectors that this finding was of very low safety

significance (Green).

The inspectors also determined that the finding affected the cross-cutting element of problem identification and resolution, because of

the failure to take effective corrective action to address the RHR pump

seal leakage.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XVI,"Corrective Action," requires that measures be established to assure

that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and

nonconformances are promptly identified and corrected. Contrary to

this requirement, as of December 16, 2005, actions taken to correct a

leaky seal on the "B" RHR pump, a condition adverse to quality, have

not been effective. Because this finding was of very low safety

significance (Green) and because it had been entered into the

corrective action program (as CAP030527, on December 14, 2005), it

is being treated as an NCV, consistent with Section VI.A.1 of the NRC

Enforcement Policy (NCV 05000305/2005005-03).

During the review of this issue, the inspectors questioned 1) the basis for a 2 gph limit on RHR train leakage that previously was in the

Technical Specifications and was a basis for the current 6 gph limit in

the SIP and, 2) whether the licensee had properly transferred all

requirements to the SIP and other administratively controlled

documents when the NRC approved (on February 25, 1998)

Kewaunee's implementation of Option B of Appendix J, "Primary

Reactor Containment Leakage Testing for Water-Cooled Power

Reactors," of 10 CFR 50. The licensee could not answer the

questions during the inspection and, consequently, the resident

inspectors will follow-up as part of their routine inspection activities. d.Assessment of Safety-Conscious Work Environment(1)Inspection Scope 14 To determine if plant personnel were reluctant to raise nuclear safety concerns, the inspectors questioned workers in the plant and interviewed the corporate

manager (and recent site manager) of the station employee concerns program.

The inspectors also reviewed program records to determine if employee

concerns had been properly evaluated and corrected, as necessary.(2)Assessment The inspectors concluded that licensee personnel were willing to raise safety concerns and that nuclear safety issues raised to the employee concerns

program were properly evaluated and corrected. 4OA6Meetings On December 16, 2005, the team presented the preliminary inspection results to Mr. M. Gaffney and other members of the licensee's staff, who acknowledged the

findings. The licensee did not identify any information, provided to or reviewed by the

team and likely to be included in the inspection report, as proprietary.4OA7Licensee-Identified Violations None.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

L. Armstrong, Director of Engineering
R. Bower, Technical Specialist, Corrective Actions
T. Breene, Manager, Nuclear Licensing
K. Davison, Director, Nuclear Station, Operations and Maintenance
M. Gaffney, Site Vice-President
D. Gauthier, Nuclear Quality Specialist
K. Hoops, Site Director
W. Hunt, Maintenance Manager
R. Nicolai, Organizational Effectiveness Manager
K. Peckham, Nuclear Oversight Manager
K. Peveler, Manager Engineering Programs
D. Sieracki, Dominion Fleet Manager, Employee Concerns Program
T. Taylor, Licensing and Compliance Group
T. Van Valkenburg, Technical Specialist, Corrective Actions
T. Webb, Director of Safety and Licensing

Nuclear Regulatory Commission

S. Burton, Senior Resident Inspector, Kewaunee
P. Louden, Chief, Reactor Projects Branch 5
M. Satorius, Director, Division of Reactor Projects

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000305/2005005-01FINNo Trending of Adverse Conditions Identified During

Outages (Section 4OA2a.(2)(i))05000305/2005005-02NCVFailure to Correct Procedure Non-Adherence (Section 4OA2c.(2)(i))05000305/2005005-03NCVFailure to Adequately Correct Residual Heat Removal

Pump Seal Leakage (Section 4OA2c.(2)(ii))

Closed

05000305/2005005-01FINNo Trending of Adverse Conditions Identified During

Outages (Section 4OA2a.(2)(i))05000305/2005005-02NCVFailure to Correct Procedure Non-Adherence (Section 4OA2c.(2)(i))05000305/2005005-03NCVFailure to Adequately Correct Residual Heat Removal

Pump Seal Leakage (Section 4OA2c.(2)(ii))

Discussed

05000305/2004004-01NCVNon-Cited Violation of 10 CFR Part 50, Appendix B,Criterion XVI, "Corrective Action," for the Failure to

Correct Historical Residual Heat Removal Pump

Mechanical Seal Leakage (Section 4OA2c.(2)(ii))

LIST OF DOCUMENTS REVIEWED