IR 05000305/2013004

IR 05000305-13-004 & 05000305-13-009; 06/01/2013 - 09/30/2013; Kewaunee Power Station

ML13304B468
Person / Time
Site:	Kewaunee
Issue date:	10/31/2013
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Heacock D Dominion Energy Kewaunee
References
IR-13-004, IR-13-009
Download: ML13304B468 (22)

Text

UNITED STATES ber 31, 2013

SUBJECT:

KEWAUNEE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000305/2013004, 05000305/2013009

Dear Mr. Heacock:

On October 1, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities for June through September of 2013 at the permanently shut down Kewaunee Power Station (KPS) in Kewaunee, Wisconsin. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with Mr. A. Jordan, the Site Vice President, and other members of your staff on October 1, 2013.

During the inspection period, the NRC inspectors reviewed the following aspects of onsite activities: organization, management and cost control at the site; safety reviews, design changes and modifications; self-assessments, audits and corrective actions; decommissioning performance and surveillance; maintenance and surveillance; and spent fuel pool safety.

The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observation of work activities, and interviews with personnel.

Based on the results of this quarterly inspection, one violation of regulatory requirements that was of more than minor safety significance was identified by the inspectors. This violation was categorized as a Severity Level IV. However, because this violation was placed into the corrective action program with timely, planned corrective actions, and the violation was neither repetitive nor willful, the NRC is treating this issue as a non-cited violation (NCV) in accordance with Section 2.3.2.a of the NRC Enforcement Policy. No response is required for the non-cited violation. However, if you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Kewaunee Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

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

Sincerely,

/RA/

Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No: 50-305 License No: DPR-43

Enclosure:

Inspection Reports 05000305/2013004 and 05000305/2013009 w/Attachment: Supplemental Information

REGION III==

Docket No: 050-00305 License No: DPR-43 Report Nos: 05000305/2013004 05000305/2013009 Licensee: Dominion Energy Kewaunee, Inc, Facility: Kewaunee Power Station Location: Kewaunee, WI Dates: June 1, through September 30, 2013 Inspectors: R. Krsek, Senior Resident Inspector K. Barclay, Resident Inspector R. Edwards, Reactor Inspector, DNMS Approved by: Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Enclosure

EXECUTIVE SUMMARY Kewaunee Power Station NRC Inspection Reports 05000305/2013004 and 05000305/2013009 Kewaunee Power Station (KPS) operated at full power until May 7, 2013, when Kewaunee shutdown and permanently ceased power operation. On May 14, 2013, Kewaunee certified the permanent removal of fuel from the reactor vessel (ADAMS Accession No. ML13135A209). On May 31, 2013, the NRC notified Kewaunee that the Operating Reactor Assessment Program had ceased and that implementation of the Decommissioning Power Reactor Inspection Program would begin on June 1, 2013 (ADAMS Accession No. ML13151A375).

Currently, the Kewaunee Power Station (KPS) is a permanently shut-down and defueled power reactor facility that was maintained in a Safe Storage of Spent Fuel (SAFSTOR) condition with spent fuel in wet storage.

Organization, Management and Cost Controls The licensee adequately implemented organization, management and cost controls in accordance with regulatory requirements, license conditions and the Technical Specifications (Section 1.1).

Safety Reviews, Design Changes and Modifications The licensee adequately implemented safety reviews, design changes and modifications in accordance with applicable regulatory requirements, license conditions and the Technical Specifications (Section 2.1).

Self-Assessment, Auditing and Corrective Action Issues were identified by the licensee at appropriate thresholds and entered into the Corrective Action Program. Issues were screened and prioritized commensurate with safety significance.

Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions (Section 3.1).

Spent Fuel Pool Safety Overall the licensee maintained spent fuel pool equipment utilized to maintain spent fuel pool (SFP) water level and cooling in a safe manner. The inspectors did identify one instance, whereby the licensee failed to maintain their spent fuel pool design to prevent inadvertent draining below the Technical Specification required level. Specifically, the licensee did not repair check valve FPC-11A, which is a check valve in the SFP return lines that is credited for preventing a SFP draindown event during a system break upstream of the valve. The draindown event would have lowered SFP level below the Technical Specification 4.3.2 minimum of 645 feet 3 inches (mean sea level). One non-cited violation of very low safety significance was identified. At the end of the inspection period the licensee had planned corrective actions in place to correct the condition (Section 4.1).

1 Enclosure

Maintenance and Surveillance Plant material condition and housekeeping were adequate and had not adversely impacted safe decommissioning or transition to SAFSTOR. Workers followed work plans, surveillance procedures and industrial safety protocols and were aware of job controls specified in work instructions (Section 5.1).

Decommissioning Performance and Status Review The inspectors determined that the licensee and supplemental workforce conducted decommissioning activities in accordance with the regulations and license requirements. The inspectors also verified that the licensee and supplemental work force activities to transition to a SAFSTOR condition were in accordance with Technical Specifications, the Updated Safety Analysis Report and the Post Shutdown Decommissioning Activities Report. Finally, the inspectors conducted frequent plant tours to verify that the material condition of structures, systems and components supported the safe storage of spent fuel and conduct of safe decommissioning (Section 6.1).

Plant Procedures The inspectors verified that plant procedure deletions were reviewed and approved in accordance with Technical Specifications and regulatory requirements (Section 7.1).

2 Enclosure

Report Details Summary of Plant Activities During the inspection period, the licensee took actions to place the unit in SAFSTOR conditions.

Major onsite activities included implementation of the following: site organizational changes; preparation and submission of license amendments and regulatory exemptions; changes to the updated safety analysis report (USAR) following the docketing of the permanent cessation of operations and permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a); reclassification of remaining onsite systems; implementation of system abandonment plans, which included isolation, draining and abandonment of systems no longer in use; and the development and implementation of modifications to support placing the unit in a SAFSTOR condition.

1.0 ORGANIZATION, MANAGEMENT AND COST CONTROLS (IP 36801)

1.1 Organization, Management, and Cost Controls at Permanently Shutdown Reactors a. Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Procedures and processes the licensee established to resolve employee and safety concerns and to assess the licensees effectiveness at resolving identified problems;

• Implementation of corrective action program procedures;

• Implementation of a cost and personnel reduction strategy that did not adversely challenge public health and safety;

• Regulatory requirements were properly implemented with respect to the site organization, staffing and staff qualifications;

• Future licensee plans for decommissioning organization and staffing would continue to meet regulatory requirements;

• Certified fuel handler and employee training programs were implemented in accordance with licensee procedures and NRC requirements;

• Licensee appropriately implemented Technical Specification, Technical Requirements Manual, Post Shutdown Activities Report (PSDAR) and Fire Protection Plan requirements and commitments;

• Licensee continued implementation of regulatory requirements that remained applicable as described in NRC Bulletins, Generic Letters and Orders;

• Licensee decommissioning activities were initiated, sequenced and performed in a manner consistent with the PSDAR; and

• Licensee programs and policies accurately reflected requirements for decommissioning funding and expenditures.

As part of the inspection, the inspectors verified that licensee programs and procedures were appropriately implemented by licensee staff. In addition, the inspectors verified that when issues were identified that licensee personnel appropriately documented the issue in the corrective action program.

3 Enclosure

b. Observations and Findings The inspectors determined through direct licensee observation, reviews of newly established licensee programs and procedures, sampling of training programs and qualification matrices, and interviews with licensee personnel that the appropriate regulatory requirements and commitments were followed.

No findings of significance were identified.

c. Conclusions The licensee adequately implemented organization, management and cost controls in accordance with regulatory requirements, license conditions and the Technical Specifications.

2.0 SAFETY REVIEWS, DESIGN CHANGES, AND MODIFICATIONS (IP 37801)

2.1 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors a. Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Determination that licensee procedures and processes conform to the regulation and guidance associated with 10 CFR 50.59;

• Evaluation of the licensees onsite safety review committee to ensure the committee was appropriately staffed and trained to fulfill the charter;

• Verification that the licensees training program provided training for personnel preparing, reviewing and approving safety evaluations;

• Procedures that control and implement design changes and modifications to assess that the procedures provided adequate guidance for implementation, review and approval;

• Implementation of a sampling of design change modifications to verify procedures and controls were followed and confirm that the applicable changes were effectively implemented in the field and in plant procedures, drawings and training programs if applicable;

• Verification that changes made under 10 CFR 50.59 did not require prior NRC approval; and

• Verification that changes to preventive maintenance, corrective maintenance and operational procedures for required equipment were implemented in accordance with the licensees processes and procedures.

The inspectors verified that when issues were identified that licensee personnel appropriately documented the issue in the corrective action program.

b. Observations and Findings The inspectors reviewed the licensees programs for changes, attended a sampling of licensee weekly onsite safety review committee meetings throughout the inspection period to verify requirements were met and performed a review of procedure and modification changes on a sample of licensee approved changes. The inspectors 4 Enclosure

determined that when issues were identified, the issues were documented by the licensee in the corrective action program at an appropriate threshold.

No findings of significance were identified.

c. Conclusions The licensee adequately implemented safety reviews, design changes and modifications in accordance with applicable regulatory requirements, license conditions and the Technical Specifications.

3.0 SELF-ASSESSMENTS, AUDITS AND CORRECTIVE ACTIONS (IP 40801)

3.1 Self-Assessment, Auditing, and Corrective Actions at Permanently Shutdown Reactors a. Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Administrative procedures prescribed actions for the identification, evaluation and resolution of problems;

• Licensee procedures prescribed thresholds for the performance of self-assessments, audits and surveillances;

• Licensee management reviewed self-assessments, audits and corrective actions to remain knowledgeable of plant performance;

• Self-assessments were conducted with technically qualified personnel and sufficient independence from the licensee;

• Issues or problems were identified and corrected in accordance with the licensees corrective action program (CAP) through a sampling of select issues;

• Quality assurance personnel audited changes in the status of decommissioning and licensee organization; and

• Licensee management observed maintenance and surveillance activities, operations evolutions and training.

The inspectors reviewed CAP documents on a daily basis to determine: if a sufficiently low threshold for problem identification existed; if the quality of follow-up evaluations including extent of condition; if the licensee assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue. Issues that were repetitive and those with the potential for safety or regulatory consequence were evaluated further to assess apparent and/or common cause and significance. The inspectors also observed a sample of licensee corrective action review team and corrective action review board meetings to ascertain if the CAP documents were implemented appropriately.

b. Observations and Findings The inspectors determined that issues were identified by the licensee at an appropriate threshold within various functional areas of the site and entered into the CAP. Issues were effectively screened, prioritized and evaluated commensurate with safety significance. The scope and depth of evaluations were adequate in that the evaluations 5 Enclosure

reviewed addressed the significance of issues and assigned an appropriate course of remedial action.

The inspectors verified that self-assessments conducted during the inspection period were performed with technically qualified personnel and when appropriate utilized personnel independent of the licensee. Finally, the inspectors verified that quality assurance personnel continued to audit changes implemented at the plant.

No findings of significance were identified.

c. Conclusions Issues were identified by the licensee at appropriate thresholds and entered into the CAP. Issues were screened and prioritized commensurate with safety significance.

Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions.

4.0 SPENT FUEL POOL SAFETY (IP 60801)

4.1 Spent Fuel Pool Safety at Permanently Shutdown Reactors a. Inspection Scope The inspectors verified the safe wet storage of spent fuel in the auxiliary building. The review included: SFP siphon and drain down protection; SFP instrumentation, alarms, and leak detection systems; SFP chemistry and cleanliness controls; SFP criticality controls; and SFP system operation and electrical power supply adequacy.

b. Observations and Findings Siphon and Drain Protection Inspectors reviewed service water system, SFP cooling system, and SFP design drawings and performed a walk down of the SFP, accessible SFP cooling system piping, and areas of SFP makeup water piping to evaluate whether conditions existed that represented a siphon or drain path. The inspectors also confirmed that licensee procedures properly controlled temporary hoses to prevent an inadvertent drain down of the SFP. The inspectors also reviewed the licensees abnormal operating procedures relating to a drain down event of the SFP and confirmed that the procedure contained adequate actions to restore SFP water level and mitigate adverse effects from such events. The inspectors reviewed the worst case drain down event, which was determined to be a failure of the spent fuel transfer tube gate valve and blank flange leading to the reactor building. The inspectors confirmed that the spent fuel would remain covered with water and that the SFP system or the backup make-up source through the service water system remained available.

During the review, the inspectors identified a condition report that described that check valve FPC-11A was not completely closed when they performed radiography to satisfy in-service testing. A design and licensing basis review of the valve found that the check valve was credited in the Kewaunee design basis to prevent a SFP drain down event.

Specifically, USAR Table 9.5-2, Design Conformance with Safety Guide 13, Item 6 states, in part, that to ensure against inadvertently draining of the pool by a siphon effect, 6 Enclosure

each return line has a check valve to prevent reverse flow. The inspectors performed an in-depth review of the issue and determined that the condition existed prior to 2007. The license had spent a significant amount of time determining the best method to isolate the valve since no isolation existed between the valve and the spent fuel pool. The licensee eventually determined that they were going to use a plug to isolate the valve for maintenance and they opened temporary modification (TM) 2011-11, Install/Remove Pipe Plug in North SFP for replacement of FPC-11A, to design and procure the plug.

When the inspectors reviewed work order (WO) KW100848636, which was associated with TM 2011-11, they observed that it had been cancelled. The notes in the cancelled WO stated that per Design Engineering the TM for this work has been cancelled. The inspectors reviewed the closed TM and discovered that the licensee had closed TM 2011-11 in late 2012 after the licensee decided to permanently shut down Kewaunee Power Station. The inspectors reviewed TS Design Feature 4.3.2, which states, The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 645 feet 3 inches (mean sea level). The SFP Cooling return lines enter the SFP at 637 feet 6 inches. The inspectors concluded that check valve FPC-11A was a license basis design feature that prevented lowering of the spent fuel pool below 645 feet 3 inches. The inspectors also concluded that based on the time since discovery and the fact that the licensee canceled the repair after determining that they were going to permanently shutdown the plant, that the licensee did not maintain their spent fuel pool to prevent inadvertent draining of the pool below elevation 645 feet 3 inches (mean sea level).

Technical Specification 4.3.2, states, The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 645 feet 3 inches (mean sea level).

Contrary to the above, from November 21, 2012, to July 11, 2013, the licensee failed to maintain their SFP design to prevent inadvertent draining below elevation 645 feet 3 inches (mean sea level). Specifically, the licensee cancelled the planned corrective actions to repair check valve FPC-11A, which might not fully close to prevent a SFP drain down to 637 feet 6 inches in the event of a system breach upstream of FPC-11A.

The violation is of more than minor significance because the inspectors determined that it was similar to example (a) in Section 5, Work in Progress Findings, in IMC 0612, Appendix E, Examples of Minor Issues. Specifically, the example deals with design features in spent fuel pools that prevent draining below a specified level. Additionally, the example also discusses draining below the TS limit, but not uncovering the fuel, which is the same set of circumstances for the Kewaunee violation. The example concluded the finding would be more than minor if the system was returned to service without the needed design feature. The inspectors concluded that Kewaunees violation was more than minor because the SFP could have been drained below the TS limit during a system breach. However, since the spent fuel would not have been uncovered and local radiation levels would have remained low, the violation is categorized at Severity Level IV (very low safety significance), as provided in Section 6.1 and 6.3 of the NRC Enforcement Policy. The violation is dispositioned as a non-cited violation (NCV) consistent with the NRC Enforcement Policy because the issue was placed in the licensees corrective action program as CR520450 and met the additional NCV criteria provided in the policy.

(NCV 05000305/2013009-01; Spent Fuel Pool Siphon Protection Deficiency)

7 Enclosure

The licensee entered the issue into their corrective action program, restored their plans to repair the valve, and put short-term corrective actions in place. The short-term corrective actions included placing a shift manager status tag on drain valves that could have allowed SFP draining past FPC-11A, if the drain valve were inadvertent left open.

Instrumentation, Alarms and Leakage Detection The inspectors reviewed SFP drawings, integrated logic diagrams, instrument setpoints, and calibration records for the SFP level and temperature detectors. The inspectors concluded that the setpoints were appropriate and provided the licensee adequate time to implement abnormal operating procedures and restore SFP level or cooling if needed.

The inspectors also validated through a review of operator logs that the licensee was monitoring the leak detection collection container in the auxiliary building basement for signs of increased SFP liner leakage.

Chemistry and Cleanliness Controls The inspectors reviewed the results of the SFP chemistry analyses. The results of the analyses reviewed indicated that all parameters were within procedural and technical specification limits. The inspectors also confirmed that the foreign material exclusion, combustible material control and SFP chemistry procedures adequately protect the integrity and cooling of the spent fuel.

Criticality Controls The inspectors randomly selected spent fuel assemblies in the transfer canal spent fuel pool, which was the most limiting location for fuel storage, and verified that the spent fuel assemblies met the requirements for placement in their respective locations. Specifically, using original fuel receipt records and other licensee data, the inspectors obtained initial enrichment and burn-up information and confirmed that the assemblies fell into the Acceptable Domain portion of Figure 3.7.15-1, Fuel Assembly Burn up Limits in the Spent Fuel Pools, found in Technical Specification 3.7.15 Spent Fuel Pool Storage. The inspectors also reviewed the most recent completion of SP-21-015, Spent Fuel Rack Boron Carbide In Service Inspection, which confirmed the continued neutron absorbing capabilities of the spent fuel racks. The inspectors also confirmed that the spent fuel racks were constructed to prevent adverse geometric reconfiguration during a seismic event and that licensee procedure GNP-08.12.02, Controls for Use of Cranes Within the Protected Area, protected the spent fuel when operating cranes in the vicinity of the spent fuel pool.

Operation and Power Supply The inspectors reviewed electrical circuit drawings for the SFP pumps and confirmed that the pumps were still powered from their pre-shutdown vital buses. The inspectors also reviewed SFP procedures and operational strategies and confirmed that no significant changes occurred since the plant permanently shutdown.

c. Conclusions The inspectors determined that the licensee was safely storing spent fuel in wet storage.

Specifically, the SFP was adequately protected from a siphon or drain down event and adequate procedures were maintained to restore SFP water level and mitigate the 8 Enclosure

adverse effects from a drain down event. Spent fuel pool instrumentation, alarms, and leakage detection systems were maintained and adequate. Spent fuel pool chemistry and cleanliness controls were implemented and adequate. The licensees criticality controls for the wet storage of spent fuel were appropriate. Spent fuel pool cooling system electrical power supplies were reliable and licensee SFP operational strategies were consistent with those used during reactor power operations.

5.0 MAINTENANCE AND SURVEILLANCE (IP 62801)

5.1 Maintenance and Surveillance at Permanently Shutdown Reactors a. Inspection Scope The inspectors conducted plant tours throughout the inspection period to observe field conditions, discuss job safety with workers, and to review the impact of work activities on safe decommissioning. During these walkdowns, the inspectors evaluated material condition and housekeeping, assessed area radiological conditions, radiological access control and associated posting/labeling, and reviewed the overall condition of systems, structures and components that support decommissioning. Independent radiation measurements were periodically made by the inspectors in areas toured to determine if those areas were controlled properly and posted as prescribed in 10 CFR Part 20.

The inspectors also reviewed the maintenance history, backlog, work prioritization and surveillance activities for the major components at the station required to be available and/or operable following the permanent cessation of operation, which included:

emergency diesel generator A and B; service water pumps A and B; fire protection pumps A and B; spent fuel pumps A and B; required 480-Volt and 4160 Volt switchgear; equipment important to emergency preparedness; and station batteries. These activities included reviews of revised preventive maintenance schedules, routine walkdowns of the equipment and observation/review of surveillance activities.

At the end of the inspection period, the licensee was still revising the maintenance rule program.

b. Observations and Findings The inspectors noted that throughout the inspection period housekeeping remained satisfactory and changing radiological conditions were addressed in a prompt and timely manner by licensee staff.

The inspectors noted that the licensee appropriately prioritized corrective maintenance on the remaining systems required for permanent cessation of operations. The inspectors also verified that equipment, which remained available following the shutdown. had the appropriate preventive maintenance schedules established with input from equipment vendors. The inspectors also verified that available equipment had the appropriate checklists available to establish operability prior to any irradiated fuel movement. Finally, the inspectors verified that when equipment issues occurred, the licensee staff implemented the appropriate troubleshooting procedures to identify and correct the equipment deficiency identified.

No findings of significance were identified.

9 Enclosure

c. Conclusions Plant material condition and housekeeping were adequate and had not adversely impacted safe decommissioning or transition to SAFSTOR. Workers followed work plans, surveillance procedures and industrial safety protocols and were aware of job controls specified in work instructions.

6.0 DECOMMISSIONING PERFORMANCE AND STATUS REVIEWS (IP 71801)

6.1 Decommissioning Performance and Status Reviews at Permanently Shutdown Plants a. Inspection Scope The inspectors conducted document reviews, observations and interviews with plant personnel to assess the licensees performance as it related to the following areas:

• Status of decommissioning through the observation of licensee meetings that planned, reviewed, assessed and scheduled the conduct of facility decommissioning;

• Whether licensee activities were in accordance with license conditions and docketed commitments, as well as, with the bounds of the docketed post shutdown activity report;

• Operability and functionality of systems necessary for safe decommissioning was assessed through control room and plant walkdowns including the following systems: radioactive effluent monitoring, spent fuel pool cooling, level and temperature control, radiation protection monitors and alarms, equipment important to emergency preparedness and equipment that provided normal and standby electrical power;

• Operator logs and data taking for normal facility operations, surveillances, maintenance and verification that data out of specification was appropriately dispositioned and resolved;

• Assessed ongoing in-plant work activities to ensure work activities were evaluated for risk in accordance with 10 CFR 50.65(a)(4), operational work risk assessments were performed and operations shift turnovers appropriately communicated pertinent plant status;

• Verified appropriate plant staffing was maintained and that appropriate management oversight of licensee and supplemental activities were performed;

• Verified pre-job briefs were conducted for facility operations including maintenance, surveillance, operations and decommissioning activities;

• Verified that system isolations, boundaries and abandonment plans for service water, emergency core cooling systems, component cooling water and electrical distribution systems ensured proper control of systems important to safe shutdown and did not adversely affect the overall plant configuration;

• Performed plant tours, at least weekly, to assess field conditions and decommissioning abandonment activities;

• Observed in progress field work to verify activities were conducted in accordance with approved work instructions and workers were knowledgeable of tasks;

• Plant materiel condition of structures, systems and components was maintained at a high level to ensure safe storage of spent fuel;

• Reviewed updated fire plan and procedures to ensure the current status of the facility was reflected; 10 Enclosure

• Verified the storage of combustibles and flammables were in accordance with plant procedures and the fire plan for the subject location;

• Verified firefighting equipment and stations were properly maintained, inventoried and readied for use;

• Verified that the installed fire detection and suppression systems were effectively maintained, surveillances performed and were capable of performing their intended function;

• Verified the effectiveness of site fire brigade training and qualification; and

• Observed the conduct of announced fire brigade drills in the plant.

b. Observations and Findings The inspectors determined through the plant tours and activities observed that the licensee conducted activities in accordance with the regulatory requirements and plant procedures. Minor deficiencies identified by the inspector or the licensee were appropriately identified in the corrective action program in a timely manner and corrected commensurate with the safety significance of the issue.

No findings of significance were identified.

c. Conclusions The inspectors determined that the licensee and supplemental workforce conducted decommissioning activities in accordance with the regulations and license requirements.

The inspectors also verified that the licensee and supplemental work force activities to transition to a SAFSTOR condition were in accordance with Technical Specifications, the Updated Safety Analysis Report and the Post Shutdown Decommissioning Activities Report. Finally, the inspectors conducted frequent plant tours to verify that the materiel condition of structures, systems and components supported the safe storage of spent fuel and conduct of safe decommissioning.

7.0 Plant Procedures (IP 42700)

7.1 Plant Procedures a. Inspection Scope The inspectors performed a sample selection of deleted licensee procedures as a result of the permanent cessation of operations. The inspectors reviewed deleted procedures from every major onsite organization to verify that procedures could be deleted because the regulations or regulatory programs no longer applied. The inspectors also verified that remaining procedures addressed the regulations and regulatory programs required.

b. Observations and Findings The inspectors determined that the licensee established a methodical process for the deletion of procedures no longer needed because the regulations or regulatory programs were no longer required.

No findings of significance were identified.

11 Enclosure

c. Conclusions The inspectors verified that plant procedure deletions were reviewed and approved in accordance with Technical Specifications and regulatory requirements.

8.0 EXIT MEETING The inspectors presented the results of the inspection to licensee management during an onsite exit meeting on October 1, 2013. The licensee acknowledged the results presented and did not identify any of the documents reviewed by the inspectors as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION 12 Enclosure

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED A. Jordan, Site Vice President R. Simmons, Plant Manager S. Yuen, Decommissioning Director J. Stafford, Safety and Licensing Director B. Harris, EP Manager M. Hale, Radiation Protection Manager J. Grau, Maintenance Manager B. Gauger, Operations OMA T. Olson, Engineering Director M. Haese, Licensing R. Repshas, Licensing Manager J. Gadzala, Licensing Engineer INSPECTION PROCEDURES (IPs) USED IP 36801 Organization and Management Controls at Permanently Shutdown Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 40801 Self-Assessment, Auditing and Corrective Action at Permanently Shutdown Reactors IP 60801 Spent Fuel Pool Safety at Permanently Shutdown Reactors IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Plants IP 42700 Plant Procedures ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed Type Summary 05000305/2013009-01 NCV Spent Fuel Pool Siphon Protection Deficiency 1 Attachment

PARTIAL LIST OF DOCUMENTS REVIEWED

- 50.59/72.48 Screen for CR523147 and GNP-08.02.17; August 8, 2013

- Calculation CN-WFE-02-54; Kewaunee Spent Fuel Pool Criticality Analysis with Westinghouse 422Vt 14x14 Fuel Assemblies; January 17, 2005

- CM-KW-ETE-101; Quality Classification Changes for Kewaunee Decommissioning; August 15, 2013

- CMP-21-01; SFP - Spent Fuel Pool Filter 1A and 1B Filter Replacement; Revision 6

- CR437764; Radiograph of Fuel Pool Discharge to SF Pool Check Valve Shows It Partially Open

- CR5200450; NRC Question on TS Design Feature 4.3.2 for SFP Drain Limit

- Daily Log; Various Dates From October 29, 2007 to May 13, 2013

- DC No. KW-13-01085; OCA Vehicle Barrier System; August 22, 2013

- DC-KW-12-01162; Cardox Pressure Relief Valve, SV, and Low Point Drain Vent Connections; July 16, 2013

- DC-KW-13-01060-000; SFP Level Instrumentation

- DC-KW-13-01128; Discharge Structure Outfall Stop Logs and B.5.b Pump Suction Point

- DCR 3635; KPS ISFSI Modifications to Support Cask Loading and Preparations

- Drawing A-212; General Arrangement Miscellaneous Plans and Sections; Revision Z

- Drawing D-20776-0101; Single Failure Proof Crane No. 2949 Keyswitch KSW20 Restricted Zone Modes; Revision 2

- Drawing E-1341; Schematic Diagram MCC 1-52B Motors 1-583, 1-178; Revision U

- Drawing E-1421; S/D MCC 1-62E Motor 1-248 MCC 1-62H Motor 1-376; Revision R

- Drawing E-1617; Spent Fuel Pool Cooling & Cleanup; Revision G

- Drawing M-1890-1; ISFSI Vacuum Drying System Tubing Layout; Revision (-)

- Drawing M-320; Spent Fuel Pool Cooling and Clean-Up Piping; Revision R

- Drawing M-321; Spent Fuel Pool Cooling and Clean-Up Piping; Revision N

- Drawing OPERM-216-1; ISFSI Vacuum Drying System; Revisions (-) and B

- Drawing OPERM-218; Spent Fuel Pool Cooling and Clean-Up System; Revision AF

- Drawing S-413; Spent Fuel Pool and Transfer Canal Liner; Revision H

- Drawing S-414; Spent Fuel Pool and Transfer Canal Liner; Revision H

- Drawing S-709-1; High Density Spent Fuel Racks Rack Assembly and Details; Revision C

- Drawing S-709-2; High Density Spent Fuel Racks Rack Assembly and Details; Revision C

- ETE-NAF-2013-0077; Information for Kewaunee Spent Fuel Pool Postulated Loss of Inventory Calculation; July 10, 2013

- FPP-08-08; FP - Control of Transient Combustible Materials; Revision 11

- GNP-03.01.01-1 for: KPS Emergency Plan; Tracking and Processing Record Completed May 6, 2013

- GNP-03.01.01-1 for: SIP 30.02; Testing, Inspecting and Maintenance of Security Equipment; Tracking and Processing Record Completed May 1, 2013

- GNP-03.01.01-1 for: SIP 30.04; Compensatory Measures and Reportability Consequences; Tracking and Processing Record Completed May 2, 2013

- GNP-03.01.01-1 for: SIP 40.01; Security Patrols; Tracking and Processing Record Completed April 17, 2013

- GNP-03.01.01-1 for: SIP 40.04; Protective Strategy; Tracking and Processing Record Completed May 7, 2013

- GNP-03.01.01-1, Halon System Inspection and Testing; August 14, 2013

- GNP-08.12.02; Controls for Use of Cranes Within the Protected Area; Revision 30

- Holtec Report No. HI-992208; Licensing Report for Storage Capacity Expansion of the Kewaunee Nuclear Power Plant

- Inservice Testing Program Fourth Ten-Year Interval; Appendix E; Revision 29 2 Attachment

- Kewaunee - Key Objectives and Initiatives; One Nuclear - 2013

- Kewaunee Current (Planning Simulation) Spent Fuel Pool, Cycle 32; 2013 SFP Post-Core Offload

- Kewaunee Decom Timeline; Revision 0, April 16,2013

- KPS Asset Report for 1-178; Motor-Spent Fuel Pool Pump 1A; July 19, 2013

- KPS Asset Report for 1-248; Motor-Spent Fuel Pool Pump 1B; July 19, 2013

- KPS Asset Report for 16640; July 15, 2013

- KPS Asset Report for 169-120; Filter-Spent Fuel Pool Filter 1A; August 5, 2013

- KPS Asset Report for 169-131; Filter-Spent Fuel Pool Demin Post Filter; August 5, 2013

- KPS Emergency Plan; Revision 38

- KPS Inservice Testing Basis Valve Data Sheet; SFP Heat Exchanger To Spent Fuel Pools Check Valve

- KPS Inservice Testing basis Valve Data Sheet; Spent Fuel Cooling; cooling Water From Heat Exch. To Spent Fuel Pool A Check Valve

- KPS USAR 9.5.2.2.6; Auxiliary Building Crane; Revision 24.03

- KPS USAR B.2.1; Definition of Nuclear Safety Design Classifications; Revision 24.03

- KPS USAR B.2.1; Definition of Nuclear Safety Design Classifications; Revision 24.03

- KPS USAR Section 9.5.3; System Evaluation; Revision 24.03

- KPS USAR Section 9.5; Fuel Handling System; Revision 24.03

- KPS USAR; Revision 24

- KW100935290; Spent Fuel Pool Sample Data Sheet; Completed June 20, 2013

- LAR 256 - Permanently defueled License & TS; April 29, 2013

- License Basis Document Change Request (LBDCR) for TRM 8.8.1, August 21, 2013

- License Basis Document Change Request (LBDCR); April 26, 2013

- Linear Fire control Panel (LFCP-1) Inspection; April 26, 2013

- Magnetrol Inc. Form 45-601.1; Models A-152F, A-152F-EP, A-153F, A-153F-EP; May 1970

- Magnetrol International Inc. Form 45-610.4; Instruction Manual and Parts List Top Mounted Displacer Level Controls Models A10, A15, B10, B15 & C10; Effective February 1984

- MA-JW-MPM-FP-019B; Inspection of Plant, Fire and Watertight Doors; Revision 8

- MA-KW-MPM-FP-029A; Spent Fuel Pool Ventilation System Charcoal Filter 1A Heat Detector Test; Revisions 2 and 3

- MA-KW-MPM-FP-029B; Spent Fuel Pool Ventilation System Charcoal Filter 1B Heat Detector Test; Revisions 3 and 4

- MA-KW-MPM-FP-030C; Dry Test of CO2 System for Hose Reels; Revisions 6 and 7

- N-FH-53AD; Spent Fuel Pool Canal Pump Down; Revision 7

- NRC RG 1.191; Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown; May 2001

- NRC-03-088; Letter from Kewaunee Nuclear Power Plant to NRC; Subject: Inservice Testing Program Project; August 14, 2003

- Nuclear Material Transaction Report; From Exxon Nuclear Company, Inc. to Kewaunee Nuclear Power Plant; Shipped March 17, 1980

- Nuclear Material Transaction Report; From Westinghouse Electric Corporation to Wisconsin Public Service; Shipped September 19, 1973

- Nuclear Material Transaction Report; From Westinghouse Electric Corporation to Wisconsin Public Service; Shipped May 18, 1973

- Nuclear Material Transaction Report; From Westinghouse Electric Corporation to Wisconsin Public Service; Shipped December 10, 1975

- Nuclear Material Transaction Report; From Westinghouse Electric Corporation to Wisconsin Public Service; Shipped June 8, 1973

- ODM000245; ODM to Document Risk of Not Repairing FPC-11A Prior to KR-32

- OD-RAS 6 Month Review 7-17-13, IAW OP-AA-102; August 1, 2013 3 Attachment

- Offsite Dose Calculation Manual; Revision 15f

- OP-KW-AOP-SFP-001; Abnormal Spent Fuel Pool Cooling and Cleanup System Operation; Revision 5

- OP-KW-NOP-CVC-001; Boron Concentration Control, System 35; Revision 33

- OP-KW-NOP-SFP-001; Spent Fuel Pool Cooling and Cleanup System; Revision 3

- OP-KW-NOP-SFP-001; Spent Fuel Pool Cooling and Cleanup System; Revision 3

- OP-KW-ORT-MISC-019, Attachment C; SFP Level is Between 22 and 3/4 Below Floor

- Physical Security Plan; Revision 1

- Physical Security Plan; Revision 1

- RD 2.1; Kewaunee Spent Fuel Pool Time to 200°F (No Coolers), 18 Month Projection, HEATUP Version 1; Revised May 30, 2013

- RE-25; Fuel Movement During Non-Refueling Operations; Revision 17

- Serial No.13-278; Correspondence from KPS to NRC; Request for Approval of Shift Manager / Certified Fuel Handler Training Program; June 17, 2013

- Serial No.13-390; Correspondence from KPS to NRC; Request for Exemptions From Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E

- SFP-21; Annunciator No. 47055-N; May 7, 2009

- SP-21-015; Spent Fuel Rack Boron Carbide In Service Inspection; Revision 15

- SP-21-015; Spent Fuel Rack Boron Carbide In Service Inspection; Revision 14; Completed September 14, 2011

- SP-21-073; Spent Fuel Pool Sample; Revision 29

- SSC Categorization Determination Document - Residual Heat Removal; April 30, 2013

- SSC Category Determination Document; Chemical and Volume Control; Revision 0

- SSC Category Determination Document; Gaseous Radioactive Waste Disposal; June 7, 2013

- SSC Category Determination Document; Reactor Building Ventilation; Revision 0

- Station Logs; Various Dates August 12, 2011, to October 9, 2013

- SY-KW-PLN-040; Nuclear Security Organization; Revision 0

- SYS-32B-DSERT; Gaseous Radioactive Waste Disposal; Revision 0

- TRM 8.3; Instrumentation; Revision 0

- TRM 8.4; Reactor Coolant System; Revision 0

- TRM 8.7; Plant Systems; Revision 0

- TS 3.7.14; Spent Fuel Pool Boron Concentration; Amendment No. 207; February 2, 2011

- TS 3.7.15; Spent Fuel Pool Storage; Amendment No. 207; February 2, 2011

- TS 4.0; Design Features; Amendment No. 207; February 2, 20133

- TS 5.4; Fuel Storage; Amendment No. 162, September 19, 2002

- TS Bases B-3; Design Codes; Revision 24.03

- Various Procedure Deletions [CA079550]; April 17, 2013

- WO KW06-010101; Replace Valve FPC-11A

- WO KW100463780; ICP-21-04

- WO KW100499216; ICP-21-02

- WO KW100654065; ICP-21-03

- WO KW100706142; ICP-21-06

- WO KW100706161; ICP-21-07

- WO KW100828972; ICP-SFP-005B

- WO KW100831003; ICP-SFP-005A

- WO KW100846454; Video the North SFP Cooling Discharge Line

- WO KW100848636; TMod 2011-11, Install / Remove Pipe Plug in North SFP for Replacement of FPC-11A

- WPSC Commitment No.92-280; Inspection Report 92-19: Valve SW-1501; Completed September 17, 1993 4 Attachment

LIST OF ACRONYMS USED ADAMS Agencywide Document Access and Management System CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DNMS Division of Nuclear Materials Safety HEPA High Efficiency Particulate Air HRA High Radiation Area ICs Increased Controls LHRA Locked High Radiation Area NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission PSDAR Post Shutdown Activities Report SAFSTOR Safe Storage of Spent Fuel SFP Spent Fuel Pool TM Temporary Modification USAR Updated Safety Analysis Report 5 Attachment