IR 05000305/2010006

IR 05000305-10-006, on 08/16/2010 - 09/03/2010; Kewaunee Power Station; Routine Biennial Problem Identification and Resolution Inspection; Effectiveness of Prioritization and Evaluation of Issues

ML102870055
Person / Time
Site:	Kewaunee
Issue date:	10/14/2010
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Heacock D Dominion Energy Kewaunee
References
IR-10-006
Download: ML102870055 (31)

Text

ober 14, 2010

SUBJECT:

KEWAUNEE POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000305/2010006

Dear Mr. Heacock:

On September 3, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) team inspection at your Kewaunee Power Station.

The enclosed report documents the inspection findings, which were discussed on September 3, 2010, with Mr. Stephen Scace and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, the team concluded that, in general, problems were properly identified, evaluated, and corrected. There were two findings identified during this inspection during our review of your investigations and corrective actions for previously identified NRC findings. One finding involved your failure to provide licensed operators with correct procedures and instructions for determining which valves are containment isolation valves. The other finding involved your failure to update the Updated Safety Analysis Report (USAR) to describe for each containment penetration, the penetration category, the type of leakage test required, and the applicable leakage test method. These findings were determined to be violations of NRC requirements. However, because of their very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), in accordance with Section 2.3.2 of the NRCs Enforcement Policy.

If you contest the subject or severity of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Kewaunee Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Kewaunee Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, 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 document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-305 License No. DPR-43

Enclosure:

Inspection Report 05000305/2010006 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-305 License No: DPR-43 Report No: 05000305/2010006 Licensee: Dominion Energy Kewaunee, Inc.

Facility: Kewaunee Power Station Location: Kewaunee, WI Dates: August 16, 2010, through September 3, 2010 Inspectors: J. Rutkowski, Senior Resident Inspector, Davis-Besse, Team Lead K. Barclay, Resident Inspector C. Brown, Reactor Inspector, Electrical D. Szwarc, Senior Reactor Inspector Approved by: Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000305/2010006; 08/16/2010 - 09/03/2010; Kewaunee Power Station; Routine Biennial

Problem Identification and Resolution Inspection; Effectiveness of Prioritization and Evaluation of Issues.

This inspection was performed by the Davis-Besse senior resident inspector, two NRC regional inspectors, and the Kewaunee resident inspector. Two Green findings were identified by the inspectors. The findings were considered non-cited violations of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP).

Findings for which the SDP does not apply may be Green or be assigned a severity level (SL)after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Kewaunee was generally good. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter nuclear safety concerns into the CAP and were encouraged to enter items.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Barrier Integrity

Green.

A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified by the inspectors for the failure to correct a condition adverse to quality. Specifically, the licensee failed to provide their licensed operators with correct procedures and instructions for determining which valves were containment isolation valves.

The condition was previously identified on August 12, 2009, when the inspectors found MS-100A, the steam supply to the turbine-driven auxiliary feedwater pump, open without the capability to be remotely closed from the control room and without a technical specification entry for the containment isolation function. The licensee entered the issue, during the current inspection, into their corrective action program and took short-term corrective actions of placing a standing order in the control room directing operators to enter the appropriate containment isolation technical specifications for the valves in question.

The finding was determined to be more than minor, because, if left uncorrected, has the potential to lead to a more significant safety concern. The inspectors concluded this finding was associated with the Barrier Integrity Cornerstone. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609,

Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Barrier Integrity Cornerstone.

The inspectors answered no to the Barrier Integrity Cornerstone questions and screened the finding as having very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance within the resources component because the licensee did not maintain complete, accurate and up-to-date design documentation (H.2(c)). (Section 4OA2.1.b(2))

• Green SL IV. The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, having very low safety significance. The inspectors found that the licensee failed to update the Updated Safety Analysis Report (USAR) to describe for each containment penetration, the penetration category, the type of leakage test required, and the applicable leakage test method.

The licensee entered this into their corrective action program. The inspectors found the violation to be more than minor in accordance with the NRC Enforcement Policy,

Section 6.1.d, Example 3, in that the failure to update the Final Safety Analysis Report (FSAR) would not have a material impact on safety or licensed activities. This issue was determined to be a Severity Level IV violation since it was similar to a Severity Level IV violation example in the NRC Enforcement Policy. Additionally, in accordance with the Enforcement Policy, this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (Green).

Violations of 10 CFR 50.71 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. The underlying finding is evaluated under the SDP to determine the significance of the violation. In this case, the finding was determined to be more than minor because, if left uncorrected, it had the potential to lead to a more significant safety concern. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609,

Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Barrier Integrity Cornerstone.

The inspectors answered no to the Barrier Integrity Cornerstone questions and screened the finding as having very low safety significance (Green). The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current performance. (Section 4OA2.1.b(2))

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in IP 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC Problem Identification and Resolution (PI&R) inspection in May and June 2008. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed issue reports generated as a result of facility personnels performance in daily plant activities. In addition, the inspectors reviewed condition reports (CRs) and a selection of completed investigations from the licensees various investigation methods, which included root cause, apparent cause, equipment apparent cause, common cause, and human performance investigations.

The inspectors selected one of the high-risk systems, the turbine building ventilation system, to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of this system through effective implementation of station monitoring programs. A five-year review on the system was also undertaken to assess the licensee staffs efforts in monitoring for system degradation due to aging. The inspectors also performed partial system walkdowns of the turbine building ventilation system, emergency diesel generators, component cooling water system, switchgear rooms, and service water system.

The inspectors also reviewed the use of the station maintenance rule program to help identify equipment issues.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues.

The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non-cited violations (NCVs).

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, the inspectors concluded that the threshold for initiating CRs was appropriate and was consistent with the plant procedural requirements. The inspectors concluded that the program was effective at identifying issues.

Findings No findings were identified.

Observations Identification of Issues The inspectors generally found that issues were being identified and captured in the licensees CR system. The licensee initiated about 8,000 to 9,000 CRs per year with most being relatively low significance (level 4 or level 3). Interviewed personnel indicated that they were expected to write CRs for issues and did write CRs although construction personnel and security personnel did not necessarily write CRs at the working level. However, all groups, including construction and security stated that bringing problems/issues to supervisors was effective. The inspectors did not identify any issues where it was clear that personnel should have written CRs and did not.

Inspectors did question why Quality Surveillance Reports (QSRs) seemed to have identified issues but seldom did the reports indicate that CRs were written.

The inspectors were originally told that the surveillance issues were not conditions adverse to quality. That did not appear to comply with section 3.1.1 of licensee procedure PI-AA-200, Corrective Action. Specifically, the requirement to submit a CR for any issue or concern that does not meet specific requirements of procedures, policies, management expectations, or accepted industry practices.

Subsequently, the licensee indicated that after QSR issues were discussed with departments, CRs were generated for many of the identified items, although this not shown on the QSRs.

The inspectors reviewed assessments associated with all of the licensees major departments and also reviewed programs in addition to the CAP and the work order system. These included the Maintenance Rule process and use of operating experience (OE). Issues identified in those assessments and through those programs appeared to be appropriately captured in the CAP.

Review of Turbine Building Ventilation System The inspectors performed a detailed review of issues entered into the CAP for the past five years for the turbine building ventilation system. As part of that effort, the resolution of NCV 05000305/2007006-20, Inadequate Screen-House Ventilation Damper Maintenance, was reviewed. The inspectors interviewed the system engineer and determined that the resolution of the NCV appeared adequate but was difficult to follow using the documentation in the licensees CR system. The inspectors also reviewed a root cause evaluation (RCE) on the failure of turbine building fan coil unit A to start in 2009 (RCE 970). That RCE did not identify a root cause because adequate troubleshooting was not performed after the 2009 event. The licensee identified problems with inadequate troubleshooting which was also an issue during previous system failures in 2000 and 2007. The inspectors determined that the licensee had subsequently taken appropriate corrective actions to address the inadequacies identified with their troubleshooting methods. Review of effectiveness review EFR236 indicated that no similar troubleshooting issues had occurred since mid-2009.

(2) Effectiveness of Prioritization and Evaluation of Issues Inspectors reviewed the classification of CRs for resolution ranging from 1, for the most significant, to 4, the least significant. Inspectors also attended the Condition Review Trending meetings to observe the management review of CR classification.

All CRs were assigned appropriate prioritization and evaluation levels.

Findings a. Failure to Correct the Classification of a Containment Isolation Valve Introduction The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality. Specifically, the licensee failed to provide their licensed operators with correct procedures and instructions for determining which valves are containment isolation valves. The condition was previously identified on August 12, 2009, when the inspectors found MS-100A, the steam supply to the turbine-driven auxiliary feedwater pump (TDAFP), open without the capability to be remotely closed from the control room and without a technical specification entry for the containment isolation function.

Description On August 12, 2009, the inspectors observed a post-maintenance test of MS-100A, the steam generator 1A steam supply isolation valve to the TDAFP pump, after the control power transformer was replaced. The inspectors expected to find the valve closed prior to the start of the test, but when the inspectors arrived in the control room, the valve was open.

MS-100 is the first isolation valve outside of containment, in parallel with other isolation valves, for containment penetration 6W, the A main steam header penetration.

Penetration 6W was described in Table 5.2-3 of the Updated Safety Analysis Report (USAR) as a Class 4 penetration. The USAR describes Class 4 penetrations as normally operating incoming and outgoing lines which penetrate the Reactor Containment Vessel, and are connected to closed systems inside the Reactor Containment Vessel, and which have a low probability of being ruptured by the assumed accident. The USAR stated that these lines are provided with at least one remotely-operated valve located outside the Reactor Containment Vessel.

The inspectors were concerned because during the replacement of the control power transformer the valve was left open without the capability to be remotely closed from the control room.

The inspectors further reviewed the USAR and found that Table 5.2-3 did not list MS-100 as a containment isolation valve. The inspectors also found a statement that Table 5.2-3 was not intended to be an all-inclusive listing of containment isolation valves; only major components associated with each penetration were included. The inspectors review determined that a comprehensive list of containment isolation valves did not exist in a procedure, instruction, or the USAR, and that no resources existed to provide the operators information on which valves were containment isolation valves.

The inspectors presented the information to the licensee, who agreed that they should have entered the containment isolation technical specification (TS) action requirement 3.6.b.3.c when MS-100A was inoperable. The inspectors documented an NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, in the 2009 third quarter integrated inspection report (05000305/2009004) for the licensees failure to have adequate procedures to ensure TSs were entered and followed for containment isolation valves.

As part of this PI&R inspection, the inspectors reviewed the corrective actions from the violation in 2009 described above and found that the licensee had changed their position and now believed that the entire penetration did not have a containment isolation valve that was covered by the containment TSs. The inspectors interviewed two shift managers and asked how they would determine if a valve were a containment isolation valve. Both shift managers stated that they would review the in-service testing (IST) basis document for the valves in question and also rely on engineering support. The inspectors reviewed the IST basis, a non-controlled document, for MS-1 (main steam line isolation valve) and MS-2 (main steam isolation bypass valve) and found that both valves had been listed as containment isolation valves, which was inconsistent with the position presented to the inspectors by engineering.

The inspectors inquired about the discrepancy; the licensee found that a corrective action to train the operators on using USAR Table 5.2-3 as the comprehensive source of containment isolation valves was documented as complete but never occurred because other training became more of a priority. The licensee subsequently entered this into the CAP and created a standing order that directed the operators to use USAR Table 5.2-3 as the resource for determining whether valves were containment isolation valves.

The inspectors then reviewed the licensee response to an NRC staff request for additional information (RAI) dated March 7, 2001, related to License Amendment Request 165a, and found that the licensee stated Kewaunee has 14 penetrations with a single containment isolation valve. The licensee had provided in the response a table of the 14 penetrations. The inspectors discussed this 2001 document with the licensee and the licensee agreed that MS-100A and the valves associated with the penetrations listed in the RAI response were, in fact, containment isolation valves. The licensee entered this into the CAP and placed a new standing order in the control room directing operators to enter the appropriate containment isolation TS for the valves in question.

Analysis The inspectors determined that failing to correct the problem in 2009, with the condition adverse to quality, was a performance deficiency. The finding was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated December 24, 2009, because, if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, not entering the appropriate technical specification action requirement, when necessary, would result in not taking the appropriate actions when the containment valves were inoperable beyond the prescribed time limits. The inspectors concluded this finding was associated with the Barrier Integrity Cornerstone.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, Table 4a, for the Barrier Integrity Cornerstone, dated January 10, 2008. The inspectors answered no to the Barrier Integrity Cornerstone questions and screened the finding as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of human performance within the resources component because the licensee did not maintain complete, accurate, and up-to-date design documentation. Specifically, the licensee failed to maintain a comprehensive list of containment isolation valves and the USAR did not identify the valves that applied to the containment isolation TS (H.2(c)).

Enforcement Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected. Contrary to this, from August 12, 2009, through June 2010, the licensee failed to promptly correct a condition adverse to quality with containment isolation valves. Specifically, the licensee failed to provide to operators procedures or instructions containing an accurate, comprehensive list of containment isolation valves; the licensee failed to correct USAR Table 5.2-3 and identify MS-100A as a containment isolation valve; and lastly, the licensee failed to train their operators to use USAR Table 5.2-3 as the comprehensive list of containment isolation valves. Because this violation was of very low safety significance and was entered into the licensees CAP (as CR393475), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000305/2010006-01, Failure to Correct the Classification of a Containment Isolation Valve).

The licensee took short-term corrective action of placing a standing order in the control room directing operators to enter the appropriate containment isolation technical specifications for the valves in question.

b. Failure to Update the Updated Safety Analysis Report to Include Containment Penetration Leakage Testing Information Introduction The inspectors identified a finding of very low safety significance and an associated Severity Level IV, non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports. Specifically, the inspectors found that the licensee failed to update the USAR to describe for each containment penetration, the penetration category, the type of leakage test required, and the applicable leakage test method.

Description As part of this PI&R inspection, the inspectors reviewed the corrective actions from a 2009 NRC violation related to the licensees classification of containment isolation valves. During that review, the inspectors noted that on December 1, 1986, the NRC approved the licensees TS Amendment Request No. 52, titled Appendix J to 10 CFR 50 Containment Leakage Testing, thereby, incorporating it into the Kewaunee license. In this request, the licensee stated that USAR Table 5.2-2, pertaining to containment penetrations, would be updated to include for each containment penetration, the penetration category, the type of leakage test required, and the leakage test method. However, the inspectors identified that Table 5.2-3 (the re-designated Table 5.2-2) had not been updated with this information. This issue was discussed with a licensee staff person who entered it into the CAP.

Analysis The inspectors determined that the failure to update the USAR Table 5.2-2 to include the penetration category, the type of test required, and the applicable test method was a performance deficiency warranting a significance evaluation. The inspectors found the finding to be more than minor in accordance with the NRC Enforcement Policy, Section 6.1.d, Example 3, which addresses a failure to update the FSAR not having a material impact on safety or licensed activities. Specifically, the failure to include the penetration category, the type of test required, and the applicable test method in USAR Table 5.2-2 (now Table 5.2-3), would allow the licensee to remove or make changes to the type of test or test method without an appropriate safety evaluation or regulatory review. This issue was determined to be a Severity Level IV violation since it was similar to a Severity Level IV violation example in the NRC Enforcement Policy, dated September 30, 2010. Specifically, NRC Enforcement Policy, Section 6.1.d.3.

states, A failure to update the FSAR as required by 10 CFR 50.71(e) in cases where the erroneous information is not used to make an unacceptable change [i.e., one that results in a White, Yellow, or Red finding] to the facility or procedures.

Violations of 10 CFR 50.71 are dispositioned using the traditional enforcement process instead of the SDP because they are considered to be violations that potentially impede or impact the regulatory process. The underlying finding is evaluated under the SDP to determine the significance of the violation. In this case, the finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated December 24, 2009, because, if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, containment isolation valves requiring leakage testing may have had their testing requirement improperly removed or methods of test improperly changed. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, dated January 10, 2008, for the Barrier Integrity Cornerstone. The inspectors answered no to the Barrier Integrity Cornerstone questions and screened the finding as having very low safety significance (Green).

In accordance with Section 6.1.d.3 of Section D.5 of Supplement I to the NRC Enforcement Policy, this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (i.e., Green finding).

The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current performance.

Enforcement Title 10 CFR 50.71(e) requires, in part, that the licensee periodically update the USAR originally submitted as part of the application for the operating license to assure that the information included in the USAR contains the latest material developed. Contrary to this, since November 10, 1982, the licensee failed to update the USAR to describe, for each containment penetration, the penetration category, the type of leakage test required, and the applicable leakage test method. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees CAP (as CR392286 and CR393475), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000305/2010006-02, Failure to Update the Updated Safety Analysis Report to Include Containment Penetration Leakage Testing Information).

The finding is evaluated separately from the traditional enforcement violation and, therefore, the finding is being assigned a separate tracking number.

(FIN 05000305/2010006-03, [Failure to Update the Updated Safety Analysis Report to Include Containment Penetration Leakage Testing Information]).

Observations The inspectors briefly reviewed licensee prioritization of issues as reflected in an issues assigned due date. While no specific issues were identified, the licensee advised the inspectors that there were approximately 270 items classified as long-term corrective actions. Forty-two of those items were over two years old. Nine of those items were identified as significance level 2 or 1. Many other items, with their assigned due date, will be in excess of three years old when completed. Some items, such as NFPA 805 Transition Project, had a logical reason for its due date. The inspectors saw from performance indicators that the licensee had a number of long-term corrective actions with three or more deferrals, mostly in actions assigned to corporate engineering.

The inspectors also reviewed the number and status of items in the procedure change request database and the training defect database. Some of the items in those data bases were created from CR issues. Those CRs were closed in the CR database, in accordance with procedures, even though the items were probably not completed or corrected. While no specific issues were identified, the inspectors did note that that those databases, in conjunction with open CRs and open work orders, including minor work orders, represented what appeared to the inspectors to be a large backlog of work.

The inspectors also noted that a significant number of Apparent Cause Evaluations (ACEs) that were accessed were downgraded, which was permitted by station procedures under specific conditions. The inspectors did not any identify any issue other than noting the percentage of downgrades.

The inspectors reviewed elements of Kewaunee Power Stations trending program, as well as available trend reports from 2009 and 2010. The inspectors also reviewed Nuclear Oversight (quality assurance) Assessment 10-07-K (Performance Improvement and Learning). That assessment concluded that while the station trend program is providing statistical data, NOD (Nuclear Oversight Department) could not identify tangible improvements as a result of the station trending program. The assessment noted that 52 of the 58 potential adverse trend CRs were closed due to no adverse trend, no further action required, or closed to action already in progress as a result of the deficiency being previously identified by some other process. From interviews, the inspectors found that the trend coordinator has started the practice of independently reviewing 10 percent of the low level corrective actions (CAs) that were closed out and found several that required additional work to address the original CA cause. Closeout of CAs without addressing the original issue was an observation from the previous PI&R team inspection. The current inspection team did not identify any discrepancies in the sites trending program.

(3) Effectiveness of Corrective Actions In general, the licensees corrective actions for the samples reviewed were appropriate and appeared to have been effective. While the licensee identified in CRs several recurrences of issues, the inspectors did not identify any new issues of significance.

Findings No findings were identified.

Observations The inspectors reviewed numerous CRs and the associated CAs. Where either sufficient time had elapsed and/or the licensee had performed effectiveness reviews, the inspectors also looked at the effectiveness of the corrective actions. The inspectors did not identify any recurrence of issues beyond those identified by the licensee. However, while sampling corrective actions associated with CRs on previous NRC findings, the inspectors identified an instance of an ineffective evaluation and consequently ineffective corrective actions. The associated NCVs were discussed in the previous section of this report.

In reviewing the CRs, the inspectors had similar issues as the previous PI&R inspection team in following the trail of CRs and supporting documents. For many CRs, the inspectors had to use multiple links and on occasion, discussion with licensee personnel, to determine that an issue had been adequately addressed. In some cases, the plant staff that initially discussed the item with the inspectors had to talk with other staff to clarify the issues with the inspectors.

An example of this difficulty was the resolution of NCV 05000305/2007006-20, Inadequate Screen-House Ventilation Damper Maintenance. This issue was identified by the NRC during the 2007 component design basis inspection. During that inspection, the licensee generated CAP042281 to capture the NRCs concerns related to station blackout operation coping even though the violation was written against the Maintenance Rule (10 CFR 50.65(b)(2)). A condition evaluation (CE19955) was generated to evaluate the coping strategy but did not state that anything was done to address the NCV. That condition evaluation referred to CA30854, which determined that no additional actions were required. The licensee issued another CR (CR14343) that captured receipt of the NCV and referred back to CAP042281 but did not resolve the underlying issue. The licensee ultimately determined in CR22492 that CAP042281 did not adequately address the NCV and included CA19541, which added the closing function of the screenhouse dampers to be monitored under the Maintenance Rule.

The inspectors noted that for NRC findings there may be as many as four CRs originated to capture the issue. The licensee stated that they had plans to address this issue and reduce this to no more than about two for NRC issues. The licensee also explained that multiple documents potentially issued for a single issue was a design nuance of their system and processes. The licensee noted that their CR system incorporated a parent-child relationship between CRs and actions which could result in numerous documentation paths for one issue. Also, other CRs and actions, if relevant to an issue, could be linked within the CR system to facilitate a complete picture of an issue. When reviewing and printing documents for review, the licensee stated that all relevant documents may not be printed if there were embedded links to other CRs.

.2 Assessment of the Use of Operating Experience

Inspection Scope The inspectors reviewed the licensees Operating Experience (OE) program.

Specifically, the inspectors reviewed implementing operating experience program procedures, attended CAP meetings to observe the use of OE information, and reviewed completed evaluations of OE issues and events. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

Assessment The inspectors concluded that the station appropriately considered industry and NRC OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons-learned were communicated and incorporated into plant operations. In particular, OE information was discussed during Plan of the Day meetings and also incorporated into the work management process as part of pre-job briefs. The inspectors also observed that Dominion fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental assessments and audits.

Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area.

In many cases, these self-assessments and audits had identified issues that were not previously recognized by the station.

Findings No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

Inspection Scope The inspectors assessed the licensees safety-conscious work environment (SCWE)through the reviews of the facilitys employee concerns program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2008 Safety Culture Survey and partial results from a recently completed 2010 Safety Culture Survey.

The inspectors interviewed approximately 30 individuals from various departments to assess their willingness to raise nuclear safety issues. The individuals were selected to provide a distribution across the various departments at the site and included long-term contractors. The sample was of individuals predominantly at first-line supervision and below first-line supervision. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also addressed the changes in the CAP and plant environment over the past two years. Other items discussed included:

• knowledge and understanding of the program;

• effectiveness and efficiency of the program;

• willingness to use the program;

• managements support of the program;

• feedback on issues raised; and

• ease of input to the system.

Assessment Interviews indicated that licensee has an environment where people were free to raise issues without fear of retaliation. Documents provided to the inspectors addressing the 2010 safety culture assessment stated that Kewaunee Power Station maintained a healthy safety culture. From the inspectors review of the data elements that were provided with that statement, although not disagreeing with the statement, the inspectors could not determine how the data supported the statement. The recent assessment identified four repeat component focus areas from the 2008 assessment. These areas were work control, resources, continuous learning environment, and organizational change management. There were no identified issues in either the 2008 assessment or the current assessment that directly influenced peoples willingness to address nuclear safety concerns. From the inspectors review of the two assessments, it appeared that while some progress was achieved since the 2008 survey, overall progress was relatively flat, and on a few questions or areas there was some regression.

Findings No findings were identified.

Observations While interviewees expressed satisfaction with the CAP, there were two groups, despite licensee efforts, who did not actively write CRs at the craft level. Most of the individuals interviewed from those two groups said that if they had an issue they would talk to their supervisors and many times either they or the supervisor would write a CR. From the interviews, the inspectors concluded that plant staff viewed the processes for identifying and correcting issues as good. Several staff did voice an opinion that low-level issues needed to receive additional attention.

The inspectors review of SCWE surveys/assessments identified what appeared to be a disconnect between what the surveys were saying and what the plant staff were saying in interviews. The survey assessments have identified issues that plant staff did not mention in interviews. The recent survey instrument indicated that less than 50 percent of survey respondents either agreed or strongly agreed to several positive statements including:

• a high level of trust exists in the organization;

• effective horizontal communication across departments is used to facilitate understanding and workflow; and

• resources are used effectively and there is a balance between assigned work and resources to perform it.

The licensee stated that they also noticed this inconsistency and were developing plans to explore the reasons for the differences. The licensee also reiterated their belief that a healthy safety culture exist at Kewaunee Power Station. They stated that survey respondents indicated nearly unanimous agreement in their ability and willingness to raise a nuclear safety concern. The licensee also stated that only 6 percent of survey respondents disagreed with the statement that management does not tolerate retaliation of any kind for raising concerns.

The licensee also stated that the survey response to the statement concerning trust in the organization was not validated by other reviews. However, the licensee has stated that they initiated actions to investigate the potential for any issue and to ensure any problems regarding trust were resolved. The licensee also stated that the survey areas that received the least positive responses were identified as improvement areas by station management. Those areas, they stated, involved predominantly process-based execution areas such as work management and change management.

4OA6 Management Meetings

Exit Meeting Summary

On September 3, 2010, the inspectors presented the inspection results to Mr. Stephen Scace and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Aulik, Manager Design Engineering

J. Arnold, Motor-Operated Valve Engineer

M. Bernsdorf, Chemistry Supervisor

H. Fictum, Trending Coordinator

J. Gadzala, Dominion Licensing

S. Heironimus, Employee Concerns Program Specialist

S. Hills, Operating Experience and Self-Assessment Coordinator

A. House, Operations Trainer

B. OConnell, Ventilation System Engineer

T. Olsowy, Station Root Cause Coordinator

R. Repshas, Dominion Licensing

M. Rosseau, Electrical and Instrument and Control Design Supervisor

T. Schneider, Nuclear Engineer

M. Sievert, Component Engineer

J. Stafford, Manager Organizational Effectiveness

K. Zastrow, Supervisor - Corrective Action

Nuclear Regulatory Commission

R. Krsek, Kewaunee Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000305/2010006-01 NCV Failure to Correct the Classification of a Containment Isolation Valve

05000305/2010006-02 SL IV Failure to Update the Updated Safety Analysis Report to NCV Include Containment Penetration Leakage Testing Information

05000305/2010006-03 FIN Failure to Update the Updated Safety Analysis Report to Include Containment Penetration Leakage Testing Information

Discussed

None.

Attachment