ML063390666

Closure of Kewaunee Improvement Initiatives to Corrective Action Program

ML063390666
Person / Time
Site:	Kewaunee
Issue date:	12/05/2006
From:	Matthews W Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
06-724
Download: ML063390666 (25)

Text

Dominion Energy Kewaunee, Inc.

i 0 0 0 I h r n m ~ o nRoulcvard, Glen Allen, VA 2 3 0 6 0 5 Dominion' December 5, 2006 U. S. Nuclear Regulatory Commission Serial No.06-724 Attention: Document Control Desk KPSILICIMH: R1 Washington, DC 20555 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION CLOSURE OF KEWAUNEE IMPROVEMENT INITIATIVES TO CORRECTIVE ACTION PROGRAM This letter provides notification that Dominion Energy Kewaunee, Inc. (DEK) no longer intends to provide the Nuclear Regulatory Commission (NRC) staff periodic updates regarding the Kewaunee Power Station improvement initiative commitments. These commitments were initially defined in a letter dated March 18, 2005 (reference 1).

These commitments were endorsed and adopted with clarifications by DEK in a letter dated September 15, 2005 (reference 2). In a letter dated November 14, 2005 (reference 3), DEK provided an update to these initiatives.

DEK will continue to monitor the implementation and effectiveness of the improvement initiatives through the site corrective action program and the station's excellence plan.

Adjustments to these improvement initiatives may be necessary in the future based on their effectiveness. These adjustments will be managed in accordance with the site corrective action program and during periodic review of the station's excellence plan.

As always, the status and dispositioning of these corrective actions remain available for NRC review. Therefore, DEK considers the November 15, 2005 letter (reference 3) containing our stated improvement initiatives closed.

The attachment to this letter restates the Kewaunee Power Station improvement initiative commitments and contains a reference to the corrective action program entry for the stated commitment.

If you have questions or require additional information, please feel free to contact Mr. Tom Breene at 920-388-8599.

Very truly yours, u W A W. R. Matthews Senior Vice President - Nuclear Operations

Serial No.06-724 Page 2 of 2

References:

1. Letter from C. W. Lambert (NMC) to Document Control Desk (NRC), "Kewaunee lmprovement Initiatives - Commitments," dated March 18, 2005 (ADAMS Accession No. MLO50820213).

2. Letter from E. S. Grecheck (DEK) to Document Control Desk (NRC), "Endorsement and Adoption of Licensing Actions," dated September 15, 2005 (ADAMS Accession No. ML052590234).

3. Letter from W. R. Matthews (DEK) to Document Control Desk (NRC), "Update on lmprovement Initiatives," dated November 14, 2005 (ADAMS Accession No.

0531 90099).

Attachment

1. Kewaunee lmprovement Initiatives with Reference to Corrective Action Program Entry Commitments made by this letter: NONE cc: Regional Administrator U. S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. L. Raghavan U.S. Nuclear Regulatory Commission Mail Stop 8-H4A Washington, D. C. 20555 Mr. S. C. Burton NRC Senior Resident Inspector Kewaunee Power Station

Serial No.06-724 Update On Improvement Initiatives Attachment 1 KEWAUNEE IMPROVEMENT INITIATIVES WITH REFERENCE TO CORRECTIVE ACTION PROGRAM ENTRY KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.06-724 Docket No.05-305 Attachment Corrective Objective Summary of Action Completion Methods to Verify Commitment Steps Program Date Commitment Met Entry Implement NMC Fleet Operations To provide an immediate Prior to Startup Fleet NOS Mentoring Program to improve CA 18561 improvement in the from the Spring observations.

Conduct of Operations. Conduct of Operations, 2005 Forced experienced SRO License Outage Documented holders from the NMC fleet feedback from have been temporarily mentors.

placed on shift with the Kewaunee Operations crews to provide mentoring Conduct a follow-up and feedback. assessment for an effectiveness review 3Q05.

Raise standards of performance This objective will be CA 18845 Revised Conduct of within Operations. achieved by: Operations Procedure issued.

1. conducting a gap analysis between Assess as part of current conduct of mentor follow-up Operations and effectiveness review industry best practices, 3Q05.

2. improving annunciator response expectations,

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

4. improving log keeping expectations and "operator at the controls" expectations.

5. implement Check Operator Program to Check Operator provide feedback on Program standard adherence. implemented.

3. implement Dominion Page 1 of 22 COM 21608 PPDNOS a roved and

Serial No.06-724 Docket No.05-305 Attachment Nuclear Operations issued.

Standards (DNOS).

COM 21609 Corrective Item 1 Summary of Action Completion Methods to Verify (Cont'd)

Objective Commitment Steps Program Date Commitment Met Entry lmprove understanding of what an To gain a broader CA 18846 Trip reports Operations - led organization looks perspective and improved documenting like. understanding of what an benchmarking trip Operations - led results, including organization is, all Shift improvement actions.

Managers will participate in a benchmarking trip to plants recommended by INPO or other industry groups.

lmprove Operations training. To improve performance of Documented the Operations feedback from Department, experienced mentors.

personnel from INPO and the NMC fleet have been Self-assessment of temporarily placed with the Operations Kewaunee Operations Training Programs.

Training staff. This will The self-assessment provide an immediate will include industry improvement in the peers.

conduct of Operations Training, recognizing that additional actions will be nitiated based on the scheduled self-wsessment.

mprove the effectiveness of The Kewaunee Operational Effectiveness Review

~perationaldecision making. Decision Making procedure of original procedure.

Nil1 be upgraded to align Nith a more effective Operational Decision 3perational decision Making Procedure making model, based on revision issued.

ndustry practices.

4ppropriate training and/or

~riefingwill be conducted Page 2 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 to revise the listed KPS COM 21 621 I EOPIAOPs into 2-column format. L ~ sPublished t

COM 21 621 Work-off curve established.

Corrective Item 1 Summary of Action Completion Methods to Verify (Cont'd)

Objective Commitment Steps Program Date Commitment Met Entry Improve Non-Licensed Operator Revise the Nuclear COM 21622 Program revised.

Continuing Training program Auxiliary Operator Training Program Description to improve the focus on systems.

Develop, review, and approve the 2006-2007 COM 21623 Develop, review and Non-Licensed Operator approve plan.

Continuing Two-Year Training Plan.

Perform effectiveness review.

COM 21624 Effectiveness review completed.

Page 4 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify 0bjective Commitment Met Commitment Steps Program Date Entry Improve the quality of Operability Combined Engineering and CAP 26045 Prior to Startup Training attendance Determinations. Operations training on from the Spring records.

Operability Determinations CE 15568 2005 Forced and Recommendations has Outage Effectiveness review been conducted. The CA 19128 4Q05.

audience for this training was and will be Shift Managers, Shift Technical Advisors, and those Engineers qualified to perform Operability Recommendations.

Validate the quality of existing open To confirm quality and CA 18563 Prior to Startup Documented Operability Determinations. applicability of the from the Spring summary of reviews.

operability determinations 2005 Forced for all Operable but Outage PORC concurrence Degraded and Operable of open operability but Non-conforming determinations.

conditions, an independent review of the associated operability recommendations will be completed. This review will encompass those which will remain open following startup from the Spring 2005 Forced Outage.

Page 5 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Confirm prior NRC commitments A representative sample of CAP 26046 Prior to Startup Documented have been implemented as existing commitments will from the Spring assessment results.

required. be performed to confirm CE 15569 2005 Forced the implementation of prior Outage commitments that CA 19103 Kewaunee has made to the NRC.

CAP 27239 CA 19531 Confirm assumptions made in A validation will be Prior to Startup Documented critical engineering calculations, performed of all time critical from the Spring assessment results of that require operator actions to be operator actions assumed 2005 Forced top 19 components performed within specific times, in engineering calculations Outage prior to startup from the reflect actual operator response for the top 19 high risk / low current outage.

times. margin components prior to startup from the current outage.

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

Provide reasonable assurance of Assessments and plant Prior to Startup Documented walk design basis compliance for high walk downs are being from the Spring down results.

energy line breaks, tornados, conducted to identify 2005 Forced flooding, and seismic events. significant issues with high 3utage energy line break, tornados, seismic and flooding. The walk downs are designed to identify:

1. potential vulnerabilities to pipe whip, and/or postulated concurrent equipment failures, and

2. potential component or Page 6 of 22

Serial No.06-724 Docket No.05-305 structural failures that could impact the operability of safety-related equipment.

Corrective Summary of Action Completion Methods to Verify Objective Date Commitment Met Commitment Steps Program Entry Resolve auxiliary feedwater Modifications will be CA 18934 Prior to Startup Modification system operability concerns due to implemented to restore from the Spring documents.

loss of suction from the operability of the auxiliary 2005 Forced Condensate System. feedwater system. The Outage scope of the modification will include re-routing of the auxiliary feedwater pump suction piping, and installation of a low suction pressure trip function.

Address the turbine building Modification and repairs Prior to Startup Modification flooding concerns. will be completed to from the Spring documents.

address the turbine 2005 Forced building internal flooding Outage issue.

Reduce potential for residual heat Implement modification to COM 21626 Approved design removal pump pit flooding during reduce flooding potential description, approved shutdown. for RHR pump pits. 10CFR50.59, completed work order.

Submit flooding license basis. Submit flooding license COM 21627 LAR submitted.

amendment request.

Resolve auxiliary feedwater local The auxiliary feedwater COM 21628 NLT RFO-29 Local operator actions operator actions system local manual eliminated.

operator actions as described in the license amendment request submitted May 5, 2005, and supplemented on June 9, 2005 will be eliminated.

Page 7 of 22

Serial No.06-724 Docket No.05-305 Attachment Update PRA Model Incorporate turbine building COM 21629 PRA Notebook issued flood modifications and operations procedure changes Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Validate and improve A project plan will be COM 21749 Internal flooding topical documentation of the design basis developed and report completed for: implemented to complete design basis topical reports. CA 18849 COM 21751 High energy line break Internal Flooding, topical report completed High Energy Line Breaks, COM 21753 Station blackout topical Station Blackout, report completed Tornados, and COM 21754 Tornado topical report completed Seismic Events COM 21756 Seismic topical report completed Complete documentation and A project plan will be COM 21737 AFW System completed validation of the license bases for developed and the safety functions of the most implemented for the SW System completed risk significant safety systems. documentation and field COM 21738 validation of license bases Interim project progress for the safety functions of COM 21748 review the Auxiliary Feedwater System, Service Water RHR System completed System, Residual Heat COM 21739 Removal System, COM 21740 CCW System completed Component Cooling Water System, and Emergency EDG completed Diesel Generators, 4kV COM 21741 electrical system and DC electrical system. CA COM 21742 4kV System completed 18850 COM 21743 DC System completed Page 8 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Item 5 Summary of Action Completion Methods to Verify Objective (Cont'd) Commitment Steps Program Date Commitment Met Entry Improve retrievability and control of The following will be CA 18851 Electronic database calculations of record. completed: population complete.

1. Complete populating Cross-referencing the current safety between calculations related calculations in database complete.

into the calculation database, and Effectiveness review.

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

Updating of Environmental Conduct a validation COM 21631 Perform assessment Qualification (EQ) Program assessment of a sample of of completed file completed EQ program upgrades and plan.

documents for adequacy in incorporating design basis information and assess prioritization of update plan.

Page 9 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Objective Summary of Action Completion Methods to Verify Commitment Steps Program Date Commitment Met Entry Complete AC electrical models and Complete AC electrical COM 21832 lnterim project calculations to provide clear bases for calculations for: progress review.

safety related settings and loads.

1. load flow, CA 18853 COM 21833 lnterim project progress review.

2. short-circuit currents, CA 18853 COM 21834 Calculations

3. EDG loading, CA 18853 completed, validated, and

4. relay setting, c A 18853 issued.

COM 21837

5. protection 0 lnterim Progress coordination, CA 18853 Review

6. control circuit voltage drops, c A 18853

7. cable ampacity, CA 18853

8. thermal overload relays. CA 18853 Complete DC electrical models and Complete DC electrical COM 21833 lnterim project calculations to provide clear bases for calculations for: progress review.

safety related settings and loads.

1. battery sizing, COM 21837 lnterim project CA 18854 progress review.

2. charger sizing, COM 21834 CA 18854 Calculations completed,

3. voltage drop, CA 18854 validated and issued.

4. short-circuit currents, CA 18854

5. control circuit voltage Page 10 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify 0bjective Commitment Steps Program Date Commitment Met Entry Improve the quality of Engineering An assessment of CE 15571 Prior to Startup Completed products. engineering has been from the Spring assessment report.

conducted using NMC 2005 Forced fleet and external Outage expertise to identify the key areas for improvement and to develop associated action plans.

To improve the quality of Engineering Prior to Startup from the Spring IRG Implemented products, an interim CA 18890 Independent Review 2005 Forced Group (IRG) has been Outage established to provide an in-line independent review of engineering Engineering quality products, including:

effectiveness review 4Q05.

1. Operability Recommendations,

2. 10 CFR 50.59 evaluations,

3. calculations important to safety, and

4. modifications important to safety.

Training will be conducted to reinforce Training attendance expectations regarding records.

Engineering product quality. CA 18891 Page 12 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Item 7 Summary of Action Completion Methods to Verify Objective (Cont'd) Commitment Steps Program Date Commitment ~ e t Entry lmprove Engineering knowledge and Training will be conducted CA 18855 Training attendance understanding of design and on design and licensing records.

licensing bases. bases for Engineering personnel. Effectiveness review 2Q06.

lmprove the interface between Roles and responsibilities CA 18856 Roles and Operations, Maintenance, and for Operations, responsibilities Engineering. Maintenance, and documented.

Engineering as they relate to Engineering support will Effectiveness review be examined and re- 4Q05.

defined as necessary.

lmprove Station Engineering Support Establish System COM 21808 Dominion Assist Visit Engineering COM 21809 Implement Dominion Plant Health Reports.

lmprove Equipment Reliability Establish a Station COM 21812 1Q06 Team established Equipment Reliability Team (SERT) and Station COM 21814 1Q06 List developed Equipment Reliability Issues List (SERIL).

Page 13 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Ensure station personnel are aware Actions will be taken to CA 18857 Employee briefings of their roles and responsibilities in ensure that station completed.

the Corrective Action Program personnel are aware of (CAP). their roles and New employee responsibilities as they training program pertain to the Corrective revised.

Action Program.

Implement communications Copies of D-15 and campaign to reinforce roles presentation and responsibilities. COM 21632 materials.

Validate the appropriateness of the An independent review of Prior to Startup Documented results significance level assigned for all all open conditions adverse from the Spring of the assessment.

wrrently open conditions adverse to to quality in the Corrective 2005 Forced quality in the Corrective Action Action Program is being Outage Dr~gram. completed.

4ssure CAP trends are identified and Trend information related h i o r to Startup Generation of

~ s e din the significance and level of to repeat CAP items will be 'rom the Spring adverse trend CAPS.

?ffort assigned during CAP provided to the daily CAP 2005 Forced screening. screen team. 3utage Effectiveness review 4Q05.

Page 14 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Item 8 Summary of Action Completion Methods to Verify Objective (Cont'd) Commitment Steps Program Date Commitment Met Entry Assure that managers recognize the Training on risk CA 18858 Training attendance significance of long standing issues. significance will be records.

provided to the management team. This Assessments training is also part of the indicate no corrective actions to significant CAP prevent recurrence from prioritization errors.

the containment equipment Goal is to have:

hatch close root cause evaluation.

No level " A misclassifications 2 90% level " B issues properly classified.

Page 15 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Validate the timeliness for resolution An independent review is CE 15567 Prior to Startup Documentation of of current open significant issues. being conducted of all open from the Spring results from the corrective actions from 2005 Forced review.

level " A and " B action Outage requests to validate the timeliness of resolution for significant issues.

Assure operable but degraded / non- Administrative procedures Revision to conforming issues are corrected in a have been revised to procedure GNP timely manner. include requirements for 11.08.01 issued.

timely resolution of operable but degraded / March 15, 2005 non-conforming issues. As backlog of open of March 15, 2005,28 open operable but OBDs remain. degraded / non-conforming conditions reduced by 2 50%.

Upgrade the KPS Emergency Action Conduct training. COM 21635 6 months after Training completed Levels (EAL) to the NEI 99-01 EAL NRC approval.

scheme as submitted to NRC on October 26, 2004 Implement new EALs. COM 21636 6 months after Procedures revised.

NRC approval Page 17 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Communicate Kewaunee "Picture of Action steps to meet this CA 18861 Training attendance Excellence" to employees to help objective include records.

facilitate sustained performance communicating and improvement. reinforcing the "Picture of Excellence" to improve NRC-05-118 stated to the NRC that accountability and DEK no longer commits to the individual behaviors.

Kewaunee Picture of Excellence but Training for managers and rather the Kewaunee Passion for supervisors has begun, Excellence. and will be completed prior to unit startup.

Page 18 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry Provide the necessary infrastructure The implementation steps and tools required to execute and include:

reinforce the "Picture of Excellence". Incorporating ACEMAN CA 18958 ACEMAN grading into daily Plan Of the Next employed at POND Day (POND) meetings. meetings.

Implementation of a daily C A 18958 D-15 meetings meeting (D-15) between implemented.

supervisors and individual contributors. The purpose of the D-15 meetings is to improve communication between employees, supervisors and managers. They are designed to enhance the information flow between employees and all levels of management and create an environment for open communication.

Alignment of Performance "Picture of Excellence" C A 18993 Management Plans to the and ACEMAN "Picture of Excellence" incorporated into station Performance Management Plans.

Establishing monthly C A 18958 PERG Picture of Excellence Review Group (PERG) meetings to foster accountability for implementation of the site Excellence Plans.

Build depth in Emergency Response Assess staffing needs and C O M 21637 Assessment Report Organization qualification in Emergency Preparedness positions.

Train additional personnel.

C O M 21 638 Training attendance records.

Page 19 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify Objective Commitment Steps Program Date Commitment Met Entry lmprove the leadership capability of A leadership assessment CAP 26038 Operations & Documented results supervisors in: will be conducted for the: Operations of the assessments.

Training will be

1. Operations, 1. Assistant Operations Engineering completed Individual Managers, CA 18562 2Q05 Performance

2. Operations Training, and CA 18972 Management Plans

2. Shift Managers, updated with

3. Engineering. improvement areas.

3. Control Room Supervisors, Engineering Operations will be

4. Operations Instructors, CA 18973 completed CA 19211 3Q05

5. Engineering Managers, and

6. Engineering Supervisors.

The assessment will focus on leadership capabilities and capacity to implement a continuous improvement zulture. Results of the assessments will be factored into individual Improvement plans.

lmprove the leadership capability of 4 leadership assessment supervisors in: Maintenance, tvill be conducted for:

Chemistry, Outage and Planning, Documented results Emergency Planning, & Radiation COM 21639 Maintenance Supervision of the assessments.

Protection COM 21643

hemistry Supervision Individual COM 21644 Performance 3utage and Planning Management Plans Supervision updated with COM 21641 improvement areas.

Emergency Planning Page 20 of 22

Serial No.06-724 Docket No.05-305 Attachment '

Supervision COM 21645 Radiation Protection Supervision Corrective Item 12 Summary of Action Completion Methods to Verify Objective Program Date Commitment Met (Cont'd) Commitment Steps Entry Improve line manager ownership and Implement DNAP 01 14, COM 21646 DNAP Approved.

accountability. Dominion Nuclear Self Evaluation Program. Station Self Assessment Meeting (SSEM) Held Page 21 of 22

Serial No.06-724 Docket No.05-305 Attachment 1 Corrective Summary of Action Completion Methods to Verify ltem 13 0bjective Commitment Steps Program Date Commitment Met Entry lmprove Nuclear Oversight (NOS) Implement mentors from CA 18862 3Q05 Rotation policy in-effectiveness. other NMC sites for a place.

period of 6 weeks, assign assessors to a functional Assessors assigned area, and implement a to functional areas.

rotation plan. An improvement plan Develop addressing assessor improvement plan.

performance will be developed which will include additional actions Review effectiveness of Nuclear Oversight processes.

Strengthen Nuclear Oversight Implement Dominion COM 21647 Establish and fill Assessment Processes Nuclear Oversight model positions which includes separate Specialist Assessment and Audit Programs Corrective Summary of Action Completion Methods to Verify ltem 14 0 bjective Commitment Steps Program Date Commitment Met Entry lmprove understanding of Site management will CA 18863 Training attendance conservative decision making by conduct training on records.

managers and supervisors. conservative decision making for managers and supervisors.

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