ML110900537

Audit Report Tables 2 and 3

ML110900537
Person / Time
Site:	Kewaunee
Issue date:	04/11/2011
From:	Feintuch K Plant Licensing Branch III
To:	Heacock D Dominion Energy Kewaunee
Feintuch K, NRR/DORL/LPL3-1, 415-3079
Shared Package
ML110900569	List: ML101550684 ML110900537
References
TAC ME3804
Download: ML110900537 (10)

Text

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 1 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

An updated description of the station blackout alternate alternating current source, including the quality assurance program requirements for the TSC DG as defined in the Dominion Nuclear Facility No ML#,

10/29/2007 USAR Quality Assurance Program complete LC000111 since no 07-0436B 8.2.4.3, 1 None None Description, will be 4/18/2008; , separate LI* none Yes NA NA ML073100354 8.2.4.12, 8.2 incorporated into the KPS NC LA000697 response to Reference Updated Safety Analysis the NRC Report (USAR) and provided to the Nuclear Regulatory Commission (NRC) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.71 (e).

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 2 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

Prior to use of nonwelded valves with end connections other than flanges at KPS, procedures will be LC000142 developed for installation of ,

nonwelded valves with end LA000741 connections other than ("LA flanges that address type"soluti operating experience of on was 11/9/07 NRC Information Notices 92- incorrect. Maintenance Letter of 2/25/08 no response 07-0416A 15, 84-55 and 84-55, complete Data entry Procedure 2 MD6144 granting relief, to the NRC LI* None Yes NA NA ML073106750 Supplement 1. The specific 1/2/2008; NC was MA-KW-GMP-ML080240029 required provisions include: a) not performed 103 mixing the parts from one by manufacturer to another, b) inexperien following manufacturer's ced recommended instructions person -

for installing compression self fittings, and c) the training corrected) or familiarity with the procedure(s) for personnel doing this work.

3 1 - Audit Sample No.

11/9/07 07-0352 2 - DEK Submittal ML073170705 Amend. No. 3 - NRC TAC No.

MD7300 200, 11/20/08, 4 - NRC Issuance ML082971079 Notify the NRC when the modifications to the Auxiliary Building (AB) 5 - Summary of Commitment crane to make it single-failure proof are complete A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

LC000141 Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data complete B - KPS Tracking #

, Note 03-C LC#,, CAP#

6/12/08; NC C - If closed, then KPS LA000133 closeout information LI* D - Governed by KPS process document # (See Note LI*)

CA069210 says to E - Affected implementing update document procedure None GNP-08.12.02 plus tags.

F - Affected change document Yes- it was timely G - Closed RgCm implemented since it accomplis NA in timely manner (Yes / No / NA) hed a design change. H - Open RgCm is adequately Maintained (Yes / No / NA)

NA I - Changed RgCm is adequately managed (Yes / No / NA)

Page 3

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 4 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

All heavy load lifts in or around the spent fuel pool made using the upgraded AB crane lifting system will meet the guidance in NUREG-0612, Section 5.1.6, as follows:

• Special lifting devices, as defined in American National Standards Institutes (ANSI) N14.6 will meet the guidance in NUREG-0612, Section 5.1.6(1 )(a) and ANSI N14.6-1993, as clarified in Attachment 5 to this license Addressed in Yes.

amendment request (LAR). TRM [a Completio 11/9/07 Amend. No. LC000141 licensee TRM 3.8.1, n took Complete 4 07-0352 MD7300 200, 11/20/08,

• Lifting devices not , controlled LI* Rev 0, none place NA NA 1/16/09; NC ML073170705 ML082971079 specially designed will meet LA000135 document 1/15/09. within 60 the guidance in NUREG- kdf] See days, as 0612, Section 5.1.6(1)(b) Note 04-C planned.

and American Society of Mechanical Engineers (ASME) B30.9-2003, as clarified in Attachment 5 to this LAR.

• The AB crane will meet the guidance in NUREG-0612, Section 5.1.6(2) and NUREG-0554 as clarified in Attachments 5 and 6 to this LAR

• Interfacing lift points will meet the guidance in NUREG-0612, Section

5 1 - Audit Sample No.

11/9/07 07-0352 2 - DEK Submittal ML073170705 Amend. No. 3 - NRC TAC No.

MD7300 200, 11/20/08, 4 - NRC Issuance ML082971079 Crane operator training will 5 - Summary of Commitment complete meet the guidance in ASME 12/15/08 A - Action Completed (date)

B30.2-2005. Action in Prgress (no date)

Not Changed / Changed to what?

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data LC000141 B - KPS Tracking #

None to LC#,, CAP#

NRC LA000736 C - If closed, then KPS closeout information LI* D - Governed by KPS process document # (See Note LI*)

Lesson Plan M-MD-LP 2.2.1 E - Affected implementing "Cranes"; M- document None PM2-LP 1.9.1 "Crane Maintenance

/ Inspection" F - Affected change document Yes.

Lesson Plans had G - Closed RgCm implemented guidance incorporat NA in timely manner (Yes / No / NA) ed in reference to this Amd's approval. H - Open RgCm is adequately Maintained (Yes / No / NA)

NA I - Changed RgCm is adequately managed (Yes / No / NA)

Page 5

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 6 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

Yes.

During NRC ISFSI Inspection (6/09) issues were identified with crane inspection procedure s

TRM Bases concernin (TRM 3.8.1 11/9/07 Crane maintenance and g B30.2 Amend. No. LC000141 pg 381-2) 07-0352 inspections will meet the complete TRM Bases, guidance.

6 MD7300 200, 11/20/08, , LI* USAR Rev22 None NA NA ML073170705 guidance in ASME B30.2- 1/16/09, NC USAR REF CR ML082971079 LA000740 Sec. 9, pp 1976. 337889.

9.5-9, -10 Revised (6/30 MA-KW-MPM-CRN-007 Rev.

2 and TEC-MA-KW-MPM-CRN-002 Rev

3. ASME B30.2 is referenced in procedure s.

7 1 - Audit Sample No.

11/9/07 07-0352 2 - DEK Submittal ML073170705 Amend. No. 3 - NRC TAC No.

MD7300 200, 11/20/08, 4 - NRC Issuance ML082971079 Revise USAR Section 9.5.2 LC000141 5 - Summary of Commitment complete A - Action Completed (date)

Action in Prgress (no date)

Not Changed / Changed to what?

to remove the dropped cask , USAR Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data 1/15/09: NC B - KPS Tracking #

LC#,, CAP#

C - If closed, then KPS analysis from the USAR. LA000737 closeout information LI* D - Governed by KPS process document # (See Note LI*)

E - Affected implementing USAR 14.2.1, document none 9.5 F - Affected change document

Yes, implement ed in a timely manner.

Amd was issued 11/08 and G - Closed RgCm implemented implement ed 1/09.

Much work took place NA in timely manner (Yes / No / NA)

- USAR revision submitted 9/09 with the next scheduled update of USAR being 3/31/10. H - Open RgCm is adequately Maintained (Yes / No / NA)

NA I - Changed RgCm is adequately managed (Yes / No / NA)

Page 7

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 8 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

After LAR approval and relocation of TS 3.8.a.7 to the technical requirements 11/9/07 manual (TRM) is Amend. No. LC000141 TRM, 07-0352 authorized, add to the TRM complete 8 MD7300 200, 11/20/08, , TRM LI* licensee none Yes NA NA ML073170705 required actions to take if 1/16/09; NC ML082971079 LA000735 controlled the AB crane lifting system is found not to meet the TRM requirements during a heavy load lift.

None to NC, design NRC; Design change change recorded as DEK will complete required DCR3629 Yes.

Letter of 5/9/08 completed modifications to the AB was Bolting 11/9/07 (ML081150741), on 5/5/08 DCR3629 is crane bridge girder to end- LC000141 completed material is 07-0465 notice of according to the 9 MD7301 tie connections and confirm , on 4/22/09; LI* none confirmed, NA NA ML073180499 withdrawal of tTrack LAR implementing bolting material as LA000732 ready to per application for ML07318049 document described in Section 4.2.2.9 install ECN3629-amendment 9 withdrawn of this LAR. 9/10/07, 06.

by letter which is dated RgCm 4/11/08 closure.

Yes -

USAR tTrack The KPS USAR will be 2/8/2008 USAR 6.2.9.3 Change shows modified upon final LC000181 08-0017 Review is In progress; None to are planned Request completi 10 MC4691 resolution of GSI-191 and , LI* NA NA ML080650314 ongoing NC NRC to be (UCR) R21- on date response to Generic Letter LA000907 changed. 108 dated changed 2004-02.

9/19/08. to 6/1/11.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 9 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

1. DEK will place a restriction in the Kewaunee procedure governing the Yes.

use of the AB crane Verified 6/2/08 Changed Amend. No. prohibiting the use of LC000141 Step 4.15 08-0113 complete None to procedure 11a MD7300 200, 11/20/08, synthetic slings for heavy , LI* none of GNP- NA NA ML081550342 1/16/09, NC NRC GNP-ML082971079 load lifts with the AB crane LA000997 08.12.02 08.12.02 when this crane is in the Rev 26, "Cask Handling" or 7/18/2010 "Override" modes of operation.

2. For the AB crane bridge Preventive Yes.

welds whose failure could Maintenance None to Preventive result in a drop of the critical (PM) Task -

NRC; Maintenan 6/2/08 load, DEK will perform PM 53065.

Amend. No. LC000141 entered ce 08-0113 nondestructive complete Examinations 11b MD7300 200, 11/20/08, , Preventive LI* none Program NA NA ML081550342 examinations at least once 1/16/09, NC IAW AWS-ML082971079 LA000998 Maintenance RE89105, every four years following 01.1-1994.

Program, which completion of initial cold PM Card has RE89105 notes it is proof load testing of the AB TS Amend.

a RgCm.

crane. Referenced.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 10 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

3. DEK will not perform a heavy lift greater than 50 None to tons using the AB crane.

NRC; This commitment will be changed superseded when a seismic procedure Yes. GNP-6/2/08 analysis, using NRC- Chnged Amend. No. LC000141 GNP- 08.12.02 08-0113 approved methods, complete procedure 11c MD7300 200, 11/20/08, , 08.12.02, LI* none change NA NA ML081550342 demonstrates acceptable 1/27/09, NC GNP-ML082971079 LA000999 "Control for done results are achieved for the 08.12.02 use of 7/8/10 AB crane and establishes a cranes in new limit based on lifting protected heavy loads greater than 50 area" tons.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 11 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

1. DEK will submit the results of the analyses performed using the nonlinear seismic analysis methodology described in this LAR.

2. DEK will perform a "push" test to provide empirical data documenting 7/7/08 the force required to induce 08-0211 crane trolley and bridge ML081930317 SN 08-211 drive wheel rolling with the LC000228 is a resubmittal sent to NRC brakes applied. The results (No LAs of an on 7/7/08 of the test will be provided are amendment (DEK to the NRC. needed request from complete accomplishe Push Test since the 11/9/07. Amend. No, 7/15/10; NC d all RgCm details

3. DEK will have an actions 12 (i.e.,Audit MD9221 205, 4/30/09, [All 3 in the LI* provided in none Yes NA NA independent peer review can be Sample #12 is ML090570710 managed as sample. 9/19/08 performed of the nonlinear managed a pickup from one - kdf] Submitted to Supplement structural model and as a group

1. 9 with the NRC outputs of the nonlinear within the supplements within the analysis to confirm the LC dated 9/19/08 9/19/08 methodology is appropriate number.)

and 3/17/09) sample) for the application and provide a summary of the Note 12-2 review to the NRC.

[The three items are managed as one. The 4th (RgCm) Regulatory Requirement in the 9/19/09 supplement was not selected for the audit sample - kdf]

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 12 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

DEK commits to administratively control the amount of fuel oil in each fuel oil storage tank such Letter approving that a minimum usable USAR Rev LC000315 1/27/09 notice of amount of 32,858 gallons 22 update (No LA Yes.09-061 enforcement (including the day tanks) is complete None to 6/30/10 13 ME0435 number - LI* none Control is NA NA ML090510149 discretion, available to supply each 6/10/09; NC NRC pg 8.2-18, one item USAR edit 1/29/09, emergency diesel generator Section only)

ML090291061 (EDG) (without reliance on 8.2.3.1 a portable transfer pump),

for the duration of the enforcement discretion.

The installation of EDG 6/1/09 exhaust duct insulation LC000345 09-291 (SAMA 160) will be further In progress; None to Not yet 14 MD9408 Review ongoing , LI* Note 14-E No Yes NA ML091600037 evaluated as part of DEK's NC NRC determined LA001560 ongoing performance improvement programs.

Sample deleted at request of sample sample sample sample sample sample sample sample 15 Sample deleted MD9408 Project Manager See Note 15-5 results not results not results not LI* results not results not results not results results making the used. used used used used used not used not used selection..

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 13 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

1. Additional information will be included in the USAR Supplement (License Renewal Application, Appendix A), including license renewal commitments identified in Table A6.0-1, as applicable.

These USAR Supplement USAR (pages 8/17/09 Reportable changes will be consistent LC000343 to be defined;09-469 License renewal In progress; through 16a MD9408 with the responses to , LI* expected to none NA Yes NA ML092320093 review ongoing NC USAR Requests for Additional LA001541 be complete change Information (RAIs) B2.1.13- 4/4/11) 5, B2.1.14-3, B2.1.15-1, B2.1.18-1, B2.1.21-1, B.2.1.31-1, and B3.1-1, are proposed to support approval of the renewed operating license, and may change during the NRC review period.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 14 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

LC000343

2. The response to RAI LA001542 No change to Yes.

B3.2-2 will be provided [original RgCm. RgCm Complete Letter SN 10-8/17/09 following reevaluation of the tracking] Change was itself not and 033 dated 09-469 License renewal environmental effects of transferre Transferred to tTrack to changed 16b MD9408 transferred LI* dated 2/2/10 Yes NA ML092320093 review ongoing fatigue for the NUREG/CR- d to to LA001848 record (transfer for action by (responded to 6260-required evaluations LC000392 transfer from was LA001848 RAI B3.2-2) that used stress-based , LA001542 to successfu fatigue monitoring. LA001848 LA001848 l)

[Observati on 16b-B]

(The following commitments are selected from Attachment 5) [Three of nine commitments were selected for audit - kdf]

9/24/09 Conversion to LC000407 Tech Spec 09-491 In progress; None to 17a ME2139 Improved TS 2. DEK will establish the , LI* Bases LCO none NA Yes NA ML092440398 NC NRC review ongoing Technical Specification LA001897 3.0.8 Bases for Limiting Condition for Operation (LCO) 3.0.8, as adopted, with the applicable license amendment.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 15 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

7. DEK will have written procedures available describing compensatory measures to be taken in the Procedure event of an intentional or 9/24/09 OP-KW-AOP-Conversion to unintentional entry LC000407 09-491 Complete GEN-005 17b ME2139 Improved TS into LCO 3.7.12, Auxiliary , Procedure LI* none Yes NA NA ML092440398 12/6/10; NC "Unplanned review ongoing Building Special Ventilation LA001902 Barrier (ASV) System, Condition B, Control Two ASV trains inoperable due to inoperable ASV boundary.

8. DEK will add procedural direction to perform an Letter SN10-extent of condition 457 to NRC evaluation and perform withdrew 9/24/09 additional testing for Conversion to Withdrew via commitment 09-491 plausible common failure Withdrew LC000407 17c ME2139 Improved TS 8/18/2010 LI* (Letter is none Withdrew NA NA ML092440398 modes associated with the 12/6/10; NC , LA1903 review ongoing Supple 8/18/10 reactor protection system supplement and the engineered safety on TAC features actuation system ME2139) instrument analog channels.

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data Page 16 A - Action Completed (date)

G - Closed RgCm implemented I - Changed RgCm is adequately F - Affected change document D - Governed by KPS process H - Open RgCm is adequately 5 - Summary of Commitment C - If closed, then KPS E - Affected implementing 1 - Audit Sample No.

B - KPS Tracking #

2 - DEK Submittal 3 - NRC TAC No. 4 - NRC Issuance Action in Prgress (no date)

LC#,, CAP#

in timely manner (Yes / No / NA) closeout information document document # (See Note LI*) Maintained (Yes / No / NA) managed (Yes / No / NA)

Not Changed / Changed to what?

The revised Work Control Revised work 9/25/09 Process program will be LC000394 control 09-597 License renewal In progress; 18 MD9408 developed and implemented , Not closed LI* program none NA Yes NA ML092710045 review ongoing NC prior to the period of LA001858 document extended operation. (TBD)

The completion dates for the following two commitments have been revised from October 1, 2009, to October 15, 2009.

[This RgCm was managed as two separate items - kdf]

Complete 10/15/09 Leter SN 09- Change to (This RgCm LC000239 09-645 Letter of 4/1/10, 1. DEK will revise current fill 645 dated date only 19a MD7838 was changed , LI* Note 19-E Yes NA Yes ML092890560 ML100880212 and vent procedures to 9/15/09 to (10/1/09 to from 10/1/09 LA001178 provide a means and NRC 10/15/09) to 10/15/09) acceptance criteria to ensure that piping is sufficiently full after system fill and vent. This may include confirmation by ultrasonic testing or other appropriate means.

1 - Audit Sample No.

10/15/09 09-645 2 - DEK Submittal 19b ML092890560

2. DEK will revise current 3 - NRC TAC No.

inservice test procedures to 4 - NRC Issuance provide dynamic sweeping Letter of 4/1/10, MD7838 as part of the filling of the ML100880212 systems where needed to 5 - Summary of Commitment ensure systems are sufficiently full.

Complete A - Action Completed (date)

Action in Prgress (no date)

(This RgCm LC000239 Not Changed / Changed to what?

Table 2 - Kewaunee Power Station RgCm Data Table - Detailed Audit Data was changed ,

from 10/1/09 LA001179 B - KPS Tracking #

LC#,, CAP#

to 10/15/09)

C - If closed, then KPS closeout information LI* D - Governed by KPS process document # (See Note LI*)

E - Affected implementing Note 19-E document Uses LI* -

commitment change evaluation Change to F - Affected change document date only (10/1/09 to 10/15/09)

Yes G - Closed RgCm implemented in timely manner (Yes / No / NA)

NA H - Open RgCm is adequately Maintained (Yes / No / NA)

Yes I - Changed RgCm is adequately managed (Yes / No / NA)

Page 17

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and Legend Page 18 Topic or Word / Symbol Note, legend or discussion ADAMS Agencywide Document Access and Management System Amd or Amend. amendment The Preventive Maintenance Program would be improved if the Comment field on the PM (preventive Audit observation (general) maintenance) Data Sheet informed the user that the sheet had a RgCm associated with it.

Commitment management staff should consider preparing a Guideline to ensure consistent input to tTrack by Audit observation (training) stakeholders making infrequent use of tTrack.

The ability to transfer tracking from one LC/LA set to another is demonstrated in Sample 16b. The rationale for Audit observation 16b-B the transfer is explained in LA001848: The NRC wanted more items for another purpose. KPS consolidated LA001542 with LA001848.

CFR Code of Federal Regulations Column headings and cell Columns are labeled numbers 1 through 5 and letters A through I. Sample numbers are listed in column 1.

designations Notes are designated as "Note (row) - (column)"

Persons identified as making routine, standardized data entry into tTrack, identified as Noreen Wenborne, Commitment management staff MaryJo Haese, and Thomas Breene during the course of RgCm data collection.

ECN Engineering Change Notice "Potential Impact of Debris Blockage on Emergency Recirculation during Design Bais Accidents at Pressurized-Generic Letter 2004-02 Water Reactors," September 13, 2004 "Experimental Studies of Loss-of-Coolant Accident-Generated Debris Accumulation and Head Loss with GSI-191 Emphasis on the Effects of Calcium Silicate Insulation," May 2005 kdf Karl D. Feintuch (Mainly used in combination with brackets to indicate an auditor comment.)

KPS Kewaunee Power Station LA Licensing Action;one or more LA can be associated with one LC LC Licensing Commitment In this report LI* represents LI-AA-110, Rev. 0, "Commitment Management," which governs the management of RgCm. In addition, GNP-03.01.01, Rev. 41 during RgCm Audit and Rev 42 when the Report was issued, LI* "Directive, Implementing Document, and Procedure Administrative Controls" (commonly referred to at KPS as the "Procedure on procedures") governs tracing the effect of RgCm on procedures. Therefore, the management of RgCm, when it affects procedures is controlled by a combination of these 2 procedures.

"MLnnnnnnnnn" (i.e. ML followed by 9 digits) is the identifier used by the NRC to access documents and records ML#

within its Agencywide Document Access and Management System (ADAMS) document control system.

NC Not Changed (as used in column A)

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and Legend Page 19 Topic or Word / Symbol Note, legend or discussion A "Yes" in Column G, H, or I indicates that the RgCm was successfully managed according to the description in the heading.

Note 01-G, -H, -I (i.e., headings in NA applies if the particilar column does not apply. As examples, for a closed RgCm, "open" is NA; for column G, H and I) unchanged RgCm, "changed" does not apply.

Thus "No" would only appear in Columns G, H or I if the RgCm was not adequately managed.

Note 03-C NRC notified via suubmitted document SN 08-0113 dated 6/2/08, ML081550342 The Technical Requirements Manual (TRM) is a licensee controlled document for managing requirements that Note 04-C the NRC has approved to be transferred from control by the Technical Specifications.(TS)

Observation: Regarding the July 7, 2008 application, the licensing group should define a closeout event at which to terminate its ownership of a RgCm intended for its doownstream stakeholders (i.e., Design, Operations, Training, as examples)

Note 12-2, Audit Observation and Audit Finding: DEK lacks a documented instruction in LI-AA-110, "Commitment Management," that the instructs Audit Finding the commitment management staff to review all incoming / outgoing correspondence for impact on existing RgCm. Heretofore, commitment management staff has been performing this action without a documented instruction, within LI-AA-110, to do so.

[Suggestion pertaining to on-going RgCm: Stakeholders should report completion plans to Licensing staff for Note 14-E tTrack entry and for future reference.- kdf]

The sample contained proprietary information, an attribute not needed to assemble a valid audit sample. The audit results for the sample were consistent with results from other samples, and its removal did not change the Note 15-5 findings of the audit. Further, the sample population grew from the original 19 selections to a net population of 24 (1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11a, 11b, 11c, 12, 13, 14, 15 omitted, 16a, 16b, 17a, 17b, 17c, 18, 19a, 19b) to track the management of separate RgCm parts.

Affected procedures (21 documents, as indicated by separate serial numbers):

OP-KW-NOP-RHR-001, -003 SP-34-099A, -099B Note 19-E OP-KW-NOP-SI-002 OP-KW-MOP-RHR-001A, -001B, -002A, -002B, -003A, -005A, -005B, -006, -006A, -006B OP-KW-NOP-SI-001 [possible typo in KPS text: NOP should possibly be MOP - kdf], -002, -004 OP-KW-MOP-ICS-001, -002, -003 In this audit TS references are to the Custom Technical Specifications (CTS), which preceded the conversion to Note on references to TS Improved Technical Specifications (ITS) on February 2, 2011.

RgCm items closed and remaining the same = 1, 2, 3, 4, 5, 6, 7, 8, 9, 11a, 11b, 11c, 12, 13, 17b, 17c (16 items)

Note on sample characteristics for RgCm items changed and closed = 16b, 19a, 19b (3 items) the sample size of 24, categorized RgCm items open and remaining the same = 10, 14, 16a, 17a, 18 (5 items) from audit results RgCm items open and changed = none

Table 3 - Kewaunee Power Station RgCm Data Table - Notes and Legend Page 20 Topic or Word / Symbol Note, legend or discussion A discussion pertaining to Table 2, row number and column number, which is inserted in Table 3 due to space Note row-column limitation. (Example: Note 01-G, pertains to row 01, column G on Table 2.

NRC Information Notice 84-55 "Seal Table Leaks at PWRs," July 6, 1984 NRC Information Notice 84-55, "Seal Table Leaks at PWRs," May 14, 1985 Supplement 1 NRC Information Notice 92-15 "Failure of Primary System Compression Fitting," February 24, 1992 NUREG/CR-6260 "Application of NUREG/CR-59999 Interim Fatigue Curves to Selected Nuclear Power Plant Components," 1995 NUREG-0554 "Single-Failure-Proof Cranes for Nuclear Power Plants," May 1979 NUREG-0612 "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36," July 1980 Regulatory Commitment, as interpreted by NEI 99-04 (the industry document governing RgCm management)

RgCm and LIC-105 (the NRC document governing RgCm audits)

SAMA 160 is described in the license renewal submittal as "Insulate EDG Exhaust Ducts." The context is that SAMA 160 insulating the EDG exhaust ducts would reduce the heat load in thhe room and provide additional time to align alternate room cooling in the event that room cooling has failed.

A comment by auditor kdf, not specific to a RgCm, but offered as a suggestion. No action or response is Suggestion expected.

Suggestion (based on Audit Items [Commitment management staff should monitor processes that cause users to contact them for RgCm 11a, b, c) information and arrange to add RgCm information to relevant databases. - kdf]

Supple Supplement Title 10 The section of the Code of Federal Regulations pertaining to "Energy" Technical Requirements Manual - a licensee controlled document for managing plant specific technical TRM requirements. The TRM is incorporated by reference into the Updated Safety Analysis Report (USAR)

TS Technical Specifications, as described in 10 CFR 50.36 tTrack Name of database used to track RgCm.

UCR USAR Change Request USAR Updated Safety Analysis Report